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					                                                   Appendix A

               London Assembly Environment Committee
                  Protecting the City Environment


   1. The ALG welcomes the London Assembly Environment
      Committee   scrutiny   into  Protecting   the  City
      Environment, dealing with enviro-crime. The ALG has
      consulted widely with the boroughs and the matrix
      attached as Annex A, sets out the ALG response on
      the specific issues raised.

   2. The ALG and boroughs have identified and prioritised
      the broad range of public realm issues as being key
      to sustaining and improving their residents‟ quality
      of life. Many London boroughs, working with their
      various partners, are at the forefront of innovative
      approaches dealing with the quality of public realm
      in an integrated way.

   3. The Government published its vision for improving
      the public realm in Living Places: Cleaner, Safer,
      Greener   in   2003   and   undertook   an   associated
      consultation    Living    Places:    Powers,    Rights,
      Responsibilities, focusing on enviro-crime. This
      proposed a number of options for reforming the
      legislative framework as part of the Government‟s
      strategy for clarifying and improving the statutory
      powers, rights and responsibilities associated with
      achieving cleaner and safer public spaces and
      environments. The ALG looks forward to the outcome
      of   this   consultation   being   taken   forward   in
      legislation.

   4. The ALG response to Government stressed that it is
      particularly     important   that    the   Government
      recognises that it needs to take a lead in improving
      public spaces, particularly in the most deprived
      areas, whilst acknowledging that the solutions to
      these problems must be locally devised, owned and
      delivered. In addition it is essential that if the
      statutory role of local authorities is to be widened
      and increased then this must be in conjunction with
      ensuring   local   authorities  have   the  necessary
      powers, skills and adequate resources.

   5. The ALG London‟s Living Places conference, in April
      2003 discussed a range of liveability issues
      affecting the public realm, which was a great
      success. At this conference the ALG made the

ALG Transport & Environment Committee 209          23 March 2004
Assembly & Protecting City Environment            Agenda Item 20
      commitment to address key issues highlighted in more
      detail with more in depth detailed seminars. Two of
      these have taken place so far: graffiti and fly
      posting and fly tipping and litter. Both have been
      extremely well attended from a wide variety of
      stakeholders and stimulated great debate, sharing of
      best practice and highlighted issues which must be
      addressed if we are able to properly protect the
      city environment. These issues are set out below
      and, in more detail, in Appendix A.

   Powers

   6. Some   of  the   issues   raised   in  the   Assembly
      consultation are being addressed by the ALG in
      taking forward the 8th London Local Authorities Bill.
      This Bill promotes a number of proposals designed to
      deal with the improvement of the public realm in
      London, such as further powers to tackle graffiti,
      measures to cut down on flyposting and measures to
      deal with abandoned cars and exhaust emissions.
      The ALG is particularly pleased that the Government
      has decided to adopt many of the clauses in the Bill
      so they apply to the rest of the country rather than
      just in London and can be used immediately.       Key
      clauses are the inclusion of it being illegal to
      sell spray paints to under 18‟s in the Anti Social
      Behaviour Act 2003 and the early adoption of changes
      to the Refuse and Disposal Amenity Act 1978,
      reducing the time required before an abandoned
      vehicle can be removed from the streets.

   7. Many boroughs identify that their powers and
      subsequent ability to enforce, do not lie with them
      or are often not adequate enough, which causes a
      particular problem in their ability to fulfil their
      responsibilities in the public realm. These issues
      are summarised in the attached table relating to
      specific areas, identifying the problem and the
      desired change. Many of these relate to enforcement
      action, which is a tool to be used in improving the
      public realm. However, enforcement should not be the
      primary activity and does not provide significant
      results in terms of prevention, improving and
      enhancing the public realm – this is a resource-
      determined approach rather than a solution-led
      approach.

   8. Increased enforcement has a positive role to play in
      improving the street environment, but this needs to
      be balanced against a much broader range of

ALG Transport & Environment Committee 210        23 March 2004
Assembly & Protecting City Environment          Agenda Item 20
      approaches and the resources required to sustain
      them.   Robust powers and punitive measures need to
      be placed within an overall package of measures that
      seek to tackle the host of underlying issues that
      often sustain or exacerbate low level criminality.

   9. The   Fixed  Penalty   Notice   (FPN)  is   a   major
      enforcement   tool   for   boroughs,    yet   current
      legislation makes it difficult to actually use this
      tool effectively. For example when issuing a FPN for
      litter, borough officers cannot require an offender
      to provide their name and address; the offender
      simply gives no details or gives the incorrect
      information thus evading the penalty. It is also the
      case that many services are contracted out e.g.
      tackling litter, dog fouling, fly tipping are
      increasingly so, however, the powers to issue FPN
      cannot be delegated to the contractor, resulting in
      lower levels of enforcement. The ALG welcomes the
      ability for local authorities to retain the proceeds
      of fines for dog fouling and litter which has
      recently been introduced, and would recommend to
      Government that this is extended to include the
      proceeds from all FPNs issued, to be utilised to
      sustain and further improve the public realm.

   10.     When it comes to prosecutions being brought or
      the enforcement of a FPN arriving at court, many
      boroughs feel that the offences are not given the
      importance that they deserve. When an issue gets to
      court magistrates‟ fines do not reflect the gravity
      of the offence and are often never actually
      collected. Lack of enforcement and collection of
      fines undermines the great progress made. In
      principle, the likelihood of being caught must be
      high and the prospect of a significant penalty must
      be a certainty.




   Community

   11.     A key area stressed in all replies from
      boroughs is the role of the community, individual
      responsibility, civic pride and care for the local
      environment. The boroughs can undertake the best
      efforts to clean the streets but it is people that
      put it there in the first place, and significant
      changes in behaviour and culture are essential. A
      concerted   and  targeted  awareness  raising  and

ALG Transport & Environment Committee 211        23 March 2004
Assembly & Protecting City Environment          Agenda Item 20
      education    campaign  is   required   nationally,
      regionally and locally over a sustained period of
      time to effect change.

   12.      Surveys have shown that many people feel
      dissatisfied with their local environment and would
      like to see changes and be more involved in their
      local area. However, they also feel that they cannot
      achieve the type of environment desired due not only
      to a lack of involvement and consultation, but also
      (when they do try to become involved) a lack of
      resources    and    the  complex   bureaucracy   and
      legislation    involved.  Greater  involvement   and
      consultation with local communities would bring many
      benefits, including the community taking ownership
      and taking more pride in the environment around
      them.

   Fly tipping and litter

   13.     Fly tipping is a particular problem for
      boroughs, and the focus of many activities is on
      providing an effective clear up response rather than
      prevention. This is not necessarily the emphasis
      that boroughs would wish to give to the matter, but
      the   powers  and   resources  attributed   to  such
      activities do not allow for effective preventative
      actions, in addition to the clean up required.

   14.     The ALG in partnership with the Environment
      Agency held a seminar on fly tipping and litter in
      October. The responsibilities of fly tipping are
      historically split between the Environment Agency
      and local authorities and this seminar aimed to look
      at the ways in which fly tipping is being approached
      and the ways in which it can be tackled better
      together. The Agency are developing a new strategy
      for the Thames Region and a protocol for taking
      action.

   15.     The seminar looked at best practice from both
      the   Agency   as  well    as  borough  and   police
      perspectives in prevention and enforcement action.
      These presentations and subsequent debate generated
      a number of interesting and practical ideas that the
      ALG and Agency are looking at taking forward, such
      as the requirement for waste collectors and builders
      to show waste transfer notes when applying to
      advertise in local papers.



ALG Transport & Environment Committee 212       23 March 2004
Assembly & Protecting City Environment         Agenda Item 20
   16.     Many   boroughs   are   undertaking  innovative
      approaches to deal with problems under their current
      powers and resources. For example, Greenwich are
      making efforts to reduce the large amount of waste
      dumped, associated with re-development work, by
      making it a requirement of planning permissions‟
      consent that its main contractors undertake waste
      audits and are able to prove that all waste arising
      have been disposed of appropriately.



   Fly posting and graffiti

   17.     The graffiti and fly posting seminar held in
      October   2003,   saw   the   private  sector   well
      represented at the event, which stimulated both
      great debate but established contacts which are now
      being developed into concerted action. It provided
      an opportunity for the local authorities, utility
      companies and contractors to discuss their roles,
      responsibilities, constraints and perceptions, which
      established a good basis from which to develop
      projects.

   18.     A key issue is the time given for a notice to
      offenders is too long to be an effective deterrent
      or enforcement tool. For example, fly posting is a
      marketing tool, yet boroughs are required to give a
      48   hour   notice  to  the  beneficiaries   of  the
      advertisement to remove it. Within this timescale it
      is sufficient for the desired marketing initiative
      to be successful and the fly posters have achieved
      their aim. If the notice period was reduced from 48
      hours to 24 hours this may help reduce the
      effectiveness of such a medium and act as a
      deterrent, along with swifter action in terms of
      enforcement. However, there exists a loophole in the
      current   legislation  that  allows   the  companies
      responsible to simply cover previous posters with
      new posters, which causes a build up of posters and
      a worsening problem. It requires a change under Part
      III of the London Local Authorities Act 1995 to
      ensure that flyposting is removed and not simply
      „obliterated‟. The ALG is lobbying for this change.

   Abandoned Vehicles

   19.     The number of abandoned vehicles in London is
      rising and poses an increasing problem to local
      authorities and other agencies in London including

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Assembly & Protecting City Environment          Agenda Item 20
      waste disposal authorities, the Metropolitan Police
      Service (MPS), London Fire and Emergency Planning
      Authority (LFEPA), and others involved in dealing
      with nuisance vehicle crime. The introduction of the
      End of Life Vehicles Directive (ELVD) will result in
      the costs of disposal rising significantly to an
      estimated £65-100. Abandonment will get
      significantly worse because of increasing pressure
      to dispose of a vehicle illegally because of higher
      costs for legal disposal (as scrap metal prices
      continue to fall) and the initial impact of changes
      to the vehicle registration system for continuous
      registration and because of the ELVD.

   20.     In London in 2001/2 financial year, 235,389
      vehicles were reported to be abandoned and had to be
      investigated by local authorities. The cost to
      London in dealing with abandoned vehicles last year
      (2001/2) was £7,527,927.

   21.     With the introduction of the ELVD the ALG and
      the boroughs recognised that there was likely to be
      a significant increase in abandonment. The ALG was
      successful in gaining £13.5m over 2 years from the
      Home Office Anti Social Behaviour Unit to deal with
      nuisance vehicles (abandoned and untaxed). The
      project will start in October 2003 – boroughs will
      “go online” as soon as they are ready – with all to
      be active by October 2004.

   22.       The bid has two main elements which are:
         the development of a pan London free take back
          service, providing an opportunity to the public
          the chance to surrender a vehicle at no cost to
          themselves and therefore act responsibly.
         removal of abandoned and untaxed vehicles in 72hrs
          (3 working days) of a report and assessment.

   Resources

   23.     A primary concern in the ALG‟s response to the
      Government‟s Living Places paper is the contrast
      between the desired vision for our city environment
      and the resources available to implement this vision
      via the Government‟s current Spending Review.    The
      Environment, Protective and Cultural Services (EPCS)
      part of the formula share funds the type of services
      that Living Places aims to address in improving the
      local environment.     This funding stream although
      increasing year on year, has faced real terms
      reduction in available resources due to below

ALG Transport & Environment Committee 214         23 March 2004
Assembly & Protecting City Environment           Agenda Item 20
      inflation increases, passporting to education               and
      social services, increased responsibilities                 and
      statutory undertakings.

    24.     Whilst the Government believes that funding in
       recent years has increased, the ALG is concerned
       that this is not the case by the time funding
       reaches local authorities. The ODPM select committee
       on the Local Government Finance: Formula Grant
       Distribution has stated ”This is of particular
       concern as expenditure on the EPCS block has failed
       to rise as fast as expenditure on education and
       social services, with dire consequences for the
       local physical environment”1.

    25.     Total   Formula  Spending Share  2004/05  has
       produced an extra £100 m added to the EPCS control
       totals. This increase is welcomed but provides
       limited increases above inflation, which coupled
       with a history of poor settlements such as 2003/04
       results in the continuation of intense pressure on
       the services funded by EPCS.

    26.      The new formulae for calculating EPCS grant is
       particularly poor at identifying need in urban areas
       with a diverse range of needs.      Funding is being
       redirected from deprived urban areas to more
       affluent Shires. Limiting the number of indicators
       also means that formulae find it more difficult to
       reflect scale and intensity because this may be a
       feature of the interaction of a range of factors
       rather than the small number in the final model. The
       Living Places document states that the relationship
       between    local   environmental   quality,   social
       exclusion and economic decline are complex, yet the
       new formulae has been simplified to such a degree
       that such factors cannot be taken into account and
       as such has resulted in a direct loss of funding in
       real terms. The new judgemental formulae have
       serious technical and intellectual inadequacies that
       need to be addressed urgently. The Association
       believes that the formulae need to use a much wider
       range of deprivation factors that identify both
       pockets of deprivation and the many dimensions of
       need.

Conclusion


1
 ODPM select committee on the Local Government Finance: Formula Grant
Distribution, First Report, 3 January 2003, para. 31

ALG Transport & Environment Committee 215                23 March 2004
Assembly & Protecting City Environment                  Agenda Item 20
   27.     The ALG and boroughs have identified and
      prioritised the broad range of public realm issues
      as being key to sustaining and improving their
      residents‟ quality of life and improving local
      environmental quality. In addition to the many
      issues outlined in this paper and the appendix the
      ALG is working on other projects affecting the
      public realm such as Commission for Architecture and
      the Built Environment (CABE) Housing Intensification
      and Sustainable Living project, to develop high
      density   housing   that  provides   for   sustainable
      living, a safe and high quality public realm. The
      ALG is a partner in the Capital Standards Network
      involving the GLA, 26 boroughs and other key
      partners tackling street environment issues. The
      Street Enforcement Academy has been a particular
      success training over 200 officers on using the
      legislation    available   effectively   and    taking
      successful prosecutions. The ALG is also a lead
      partner in the development of a London Anti Social
      Behaviour Strategy, that will focus on joining up
      the   key   agencies   in  London,   identifying   and
      addressing issues that London faces in a co-
      ordinated way.

   28.     London boroughs, working with their various
      partners, undertake an extensive range of services
      aimed at maintaining and improving the public realm
      and many are at the forefront of innovative
      approaches dealing with the quality of public realm
      in an integrated way.   Local solutions are the way
      forward but Government needs to play a major role in
      leading this change and providing the powers and the
      resources necessary to deliver.




ALG Transport & Environment Committee 216         23 March 2004
Assembly & Protecting City Environment           Agenda Item 20
                                                                                                    Annex A

                    Extent of            Causes                Actions being taken       What else is
                    problem                                                              needed
   Fly              A significant        Fly posting is        All boroughs remove       The fines issued
   posting          problem across       an organized and      fly posting with          for such offences
                    most boroughs.       commercial            many operating 7          need to be
                    Seems to be          venture. The          days a week removal       increased
                    particular           beneficiaries         teams.                    substantially.
                    problems in          gain free                                       This is a highly
                    major transport      publicity for         Anti     fly    posting   profitable,
                    areas e.g. main      their events /        paints and materials      organised
                    roads,               products, so          are       added      to   commercial
                    tube/rail            gain financially      surfaces to prevent       operation. Current
                    stations. Some       at the council‟s      them being erected.       fine levels do not
                                         and other
                    boroughs have                              Some boroughs have        act as a
                                         organisations‟
                    noted the                                  negotiated         with   deterrent.
                                         expense. The law
                    problem tends        requires only         utility and private
                    to increase          that the fly          companies to remove       There is little
                    around major         posting must be       fly     posting     and   financial
                    public holidays      „obliterated‟ in      apply      anti     fly   incentive for the
                    such as bank         48 hours of a         posting surfaces at       utility companies
                    holidays.            notice being          a discounted rate or      to maintain their
                                         served.               as    part    of    the   property         a
                    Private              Although there        negotiated service.       statutory duty to
                    property,            is some smaller       (where it has not         keep         their
                    utility and          scale fly             been negotiated it        property free of
                    street               posting               is normally the part      posters,   whether
                    furniture is a       undertaken for        of the company not        by        applying



ALG Transport & Environment Committee                 23
                                                     217 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken      What else is
                    problem                                                             needed
                    problem as the       local car boots,      wanting to work with     preventative
                    borough cannot       weight loss etc.      the        borough).     measures, locating
                    always take          by far the            Boroughs do notify       property
                    action.              largest               and serve notices to     underground or by
                                         offenders are         companies.               introducing a more
                                         the music                                      rigorous
                                         industry whether      Some         boroughs    maintenance
                                         it be clubs           encourage Owners or      regime. New powers
                                         promoting             management companies     coming in through
                                         specific events       of vacant property       the London Local
                                         or large multi        to              attach   Authorities   Bill
                                         national              horizontally slatted     and Anti Social
                                         companies such        hoardings    to    the   Behaviour Act 2003
                                         as Sony and           windows    of     such   should help this
                                         their music           property preventing      situation.
                                         releases.             the   attachment    of
                                                               posters.                 Large
                                                                                        multinational
                                                               Prosecutions       are   companies such as
                                                               taken    forward    by   Sony openly flout
                                                               some boroughs when       the law through
                                                               sufficient evidence      their    marketing
                                                               is         available.    contracts, yet it
                                                               However, such action     is difficult to
                                                               is    time-consuming,    take   prosecution
                                                               resource-intensive       action     against
                                                               and     with     small   them.    A    high
                                                               fines, unlikely to       profile     London



ALG Transport & Environment Committee                 23
                                                     218 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes             Actions being taken    What else is
                    problem                                                        needed
                                                            dissuade   companies   wide        action
                                                            from fly-posting.      against        top
                                                                                   offenders such as
                                                            Failure to comply      Sony, EMI could
                                                            with the 48 hour       yield significant
                                                            notice allows a fine   results long term
                                                            of £100 per poster.    as        repeated
                                                            An additional charge   discussions   with
                                                            for removal is often   them    has    not
                                                            added ranging from     improved       the
                                                            approx. £20-£100 a     situation.
                                                            poster.

                                                            Some boroughs have
                                                            or are trying to
                                                            link the issue of
                                                            fly posters to the
                                                            issuing of
                                                            entertainment
                                                            licenses e.g. LB
                                                            Harrow working with
                                                            Met Police this
                                                            resulted in the
                                                            withdrawal of a
                                                            venues license.

                                                            The legislation
                                                            commonly used for
                                                            enforcement is the



ALG Transport & Environment Committee              23
                                                  219 March 2004
Assembly & Protecting City Environment            Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                                                               Town and Country
                                                               Planning Act 1990,
                                                               some boroughs use
                                                               other legislation
                                                               such as the Highways
                                                               Act for greater
                                                               efficiency and
                                                               flexibility.

   Graffiti         A significant        Three key causes      All boroughs have an   The ALG and
                    problem across       are highlighted:      in house or            boroughs are
                    most boroughs.       The lack of           contracted team that   looking forward to
                    Seems to be          recreational          removes graffiti.      the new powers of
                    particular           activities and        This is in many        the Anti Social
                    problems in          places for young      cases a dedicated      Behaviour Act 2003
                    town centres         people.               team for graffiti      that have been
                    and around           A lack of police      and fly posting, for   lobbied for and
                    transport hubs       or authority          others it is part of   will come into
                    and                  presence (e.g.        the more general       effect early 2004.
                    infrastructure.      CCTV).                cleansing service.     Also the London
                    There are also       Relatively small      All boroughs remove    Local Authorities
                    concentrations       threat of being       offensive graffiti     Bill when gaining
                    on housing           caught and if         within 24 hours of a   Royal Assent will
                    estates, parks       caught penalties      report. Other          complement the ASB
                    and open             imposed are           graffiti is normally   Act and provide
                    spaces.              small.                removed within 7       better „tools‟ for
                                         It was noted          days.                  boroughs.
                                         that it is



ALG Transport & Environment Committee                 23
                                                     220 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                                         predominantly         Boroughs remove        Additional
                                         committed by          large scale graffiti   resources are
                                         juvenile or           from domestic          needed to deliver
                                         adolescents           properties, public     the graffiti
                                         relating to           spaces and council     removal service
                                         peer-group            owned premises.        that boroughs
                                         recognition,                                 would like to
                                         self                  Some boroughs have     provide.
                                         gratification         issued graffiti
                                         and „bravado‟.        removal kits to        Resources and
                                         There is also         residents,             guidance to allow
                                         significant           caretakers,            communities, such
                                         amounts of            businesses,            as housing
                                         political,            cleansing              estates, to design
                                         religious,            operatives, estate     out graffiti.
                                         sexual and            managers, to remove
                                         racial graffiti       graffiti from estate   Improvements in
                                         that is highly        properties, private    the facilities and
                                         offensive.            domestic properties,   activities
                                                               small business and     available to young
                                         Graffiti is also      street furniture.      people to help
                                         known to be                                  prevent graffiti.
                                         linked into           Businesses
                                         criminal              encouraged to take     Education and
                                         activity e.g.         up borough service     awareness raising,
                                         graffiti symbols      to remove graffiti     particularly of
                                         used to show          (free/low cost) and    young people is
                                         where a certain       work with them to      required.



ALG Transport & Environment Committee                 23
                                                     221 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                                         drug can be           take advice and
                                         purchased, or         implement graffiti     There is a need to
                                         where an elderly      prevention measures.   break the link
                                         or vulnerable         E.g. trellis work on   between graffiti
                                         person lives to       sides of walls, anti   and the positive
                                         mark for              graffiti paint and     kudos associated
                                         household             „unfriendly‟ paint     with it.
                                         robberies.            colours such as
                                                               black.                 Resources provided
                                                                                      to allow for
                                                               Most boroughs          boroughs to offer
                                                               (either as members     reparation
                                                               of the Capital         placements and
                                                               Standards Network or   supervision for
                                                               individually) have     offenders to work
                                                               got businesses to      with graffiti
                                                               sign up to the         removal teams.
                                                               voluntary ban of
                                                               spray paints to        The penalties
                                                               Under 18‟s.            imposed by the
                                                                                      Magistrates needs
                                                               Boroughs are           to be commensurate
                                                               working in             with the offence
                                                               partnership to share   and reflect the
                                                               good practice and      costs of removal,
                                                               information through    prosecution and
                                                               such groups as SWAAG   impact on the
                                                               (South West Action     local environment.



ALG Transport & Environment Committee                 23
                                                     222 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes             Actions being taken    What else is
                    problem                                                        needed
                                                            Against Graffiti).
                                                                                   Raising the
                                                            Through                profile of
                                                            Neighbourhood          graffiti within
                                                            Renewal Funding a      the police to
                                                            graffiti database is   initiate greater
                                                            currently being        support for local
                                                            developed for          authority officers
                                                            reporting incidences   is required.
                                                            and to aid in
                                                            enforcement and
                                                            intelligence
                                                            gathering. This is
                                                            being piloted in
                                                            three boroughs Tower
                                                            Hamlets (funder),
                                                            Croydon and
                                                            Southwark.

                                                            Hot spots are being
                                                            targeted in many
                                                            boroughs with rapid
                                                            and constant removal
                                                            to deter re-
                                                            offenders and the
                                                            use of CCTV to
                                                            assist enforcement.




ALG Transport & Environment Committee              23
                                                  223 March 2004
Assembly & Protecting City Environment            Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                                                               Many boroughs are
                                                               linking in with
                                                               youth services and
                                                               probation services
                                                               in addressing
                                                               prevention through
                                                               raising the
                                                               awareness of the
                                                               impact of graffiti.
                                                               Also to become
                                                               involved in the
                                                               restoration of
                                                               graffiti‟d surfaces
                                                               e.g. paint outs.

                                                               Key provisions as
                                                               part of the 8th
                                                               London Local
                                                               Authorities Bill, to
                                                               ban the sale of
                                                               spray paints to
                                                               under 18‟s has been
                                                               adopted in the Anti
                                                               Social Behaviour Act
                                                               2003.
   Fly              The boroughs         Fly tipping is        Enforcement forms a    It is important
   Tipping          and the              becoming              key part of tackling   that an
                    Environment          increasingly a        fly tipping for all    occupier/landowner



ALG Transport & Environment Committee                 23
                                                     224 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    Agency (EA)          highly                boroughs. Many         have a reasonable
                    have seen            profitable            boroughs have a        defence. However,
                    incidences of        business with         robust enforcement     as the law stands
                    fly tipping and      very low              regime using CCTV      at the minute it
                    dumping              associated risk.      cameras and re-        is far too easy to
                    continuously         The costs of          locatable cameras      abuse the law and
                    increase across      waste disposal        for example Haringey   results in
                    London. The          have been             have 60 re-locatable   enforcement
                    Agency has           increasing over       cameras.               activity being
                    noted a 19%          time and will                                limited as S.59 is
                    increase in          continue to do        Prosecutions are       seen as
                    levels in            so through such       taken forward but      unenforceable. Sub
                    England and          mechanisms as         the fines imposed by   section 3a states
                    Wales between        increases in          magistrates are not    that “the court
                    2001 and 2002,       Landfill Tax.         commensurate with      shall quash the
                    and a 70%            Fly tipping in        the crime committed.   requirement if it
                    increase in the      many instances                               is satisfied that
                    Thames region        is an economic        All boroughs operate   the appellant
                    alone (though        decision to           clean up teams that    neither deposited
                    fly tipping is       reduce costs.         work both pro-active   nor knowingly
                    dominated by                               and re-actively to     caused nor
                    construction         EU directives         incidences.            knowingly
                    waste).              and subsequent        Each borough has       permitted the
                                         UK legislation        their own hot spots    deposit of the
                    The London           is driving the        where they focus       waste” a clause
                    borough of           reduction in the      both their clean up    easily exploited
                    Lewisham             use of landfill       activities and         by a legal
                    counted 13,600       for waste             enforcement work.      professional.



ALG Transport & Environment Committee                 23
                                                     225 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    fly tipping          disposal, this        Some boroughs are      Suggest the use of
                    incidents in         is a position         trialling the use of   the term “knowing
                    2002 costing         the ALG               putting waste          permitter” as used
                    over £500,000        supports.             collection             in Part IIA of the
                    to clean up.         However,              facilities in          Act, which would
                                         instruments such      certain hot spots,     then include
                    There is             as Landfill Tax       which although this    action on
                    generally a          that have been        may encourage the      landowners who
                    lack of data         used as a             continuation of fly    failed to deal
                    across London        mechanism to          tipping it can work    with deposits once
                    and nationally       effect the            out cheaper and        they have been
                    on the actual        economic              easier than dealing    made aware.
                    amounts of           structure of          with the continuous
                    waste resulting      waste disposal        fly tipping.           In the case of
                    from these           have resulted in                             multiple
                    practices as         the increase of       Boroughs are working   ownership, those
                    these figures        illegal waste         to improve their       that can be served
                    are subsumed         disposal.             civic amenity sites    a notice should be
                    into the             Forthcoming           to ensure they         liable for all
                    general waste        legislation is        provide a service      costs if other
                    statistics for       likely to             that residents want    parties cannot be
                    most                 increase both         and need. These are    traced, this is
                    authorities.         the scale and         also being developed   likely to ensure
                                         the nature of         to meet requirements   greater co-
                                         fly tipping. For      of EU directives and   operation in
                    The                  example the           UK legislation.        finding all
                    interpretation       implementation                               owners.
                    of what              of the Hazardous      Many boroughs



ALG Transport & Environment Committee                 23
                                                     226 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    constitutes fly      Waste Directive       undertake clean up     The ability to
                    tipping,             is due to come        days/events with       recover the full
                    dumping and in       into effect in        communities            cost of expenses
                    some cases           July 2004. This       particularly on        incurred has
                    litter varies        will increase         estates and around     proved in practice
                    between              the amount of         parks and open         to be limited.
                    authorities and      waste that is         spaces. This proves    Preparing a cost
                    agencies a           classed as            particularly good at   and claim
                    matter that          hazardous and as      engaging the           beforehand would
                    needs to be          such will             community on the       be feasible, but
                    clarified.           require               impacts of fly         time consuming and
                                         treatment of the      tipping and the        any estimate given
                    Large scale fly      waste before or       dumping of household   would be merely
                    tipping              as part of the        waste.                 indicative.
                    commonly             waste disposal,
                    originates from      further               Using a variety of     Many of the
                    demolition and       increasing the        media - events,        vehicles involved
                    construction         cost to manage a      website, borough       in fly tipping are
                    waste, such as       wider spectrum        publications etc.      out of the legal
                    excavation           of waste              boroughs are           system. They are
                    spoil and            materials,            promoting the free     not registered or
                    building waste.      resulting in an       bulky waste            registered to non
                                         expected              collection services    existent people
                    The problem is       increase in fly       that are available     and addresses, do
                    widespread           tipping.              for residents to       not have tax and
                    across London                              use, to try and        insurance or waste
                    except in the        The proximity to      reduce the amount of   transfer licenses.
                    City of London       waste management      household waste        This makes it very



ALG Transport & Environment Committee                 23
                                                     227 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    where it is          sites is a            dumped. Also raising   hard to trace
                    mainly an issue      particular            the issue that         vehicles to an
                    around markets.      problem in            dumping of waste is    owner to follow up
                    Any vacant land      London, where         illegal. This is       on intelligence
                    and open areas       waste needs to        undertaken in a        gathered. The DVLA
                    both public and      travel                number of languages.   needs to take
                    private              significant                                  action to improve
                    property are         distances             Boroughs have linked   the quality of the
                    subject to           through               up with community      information held
                    regular fly          sometimes heavy       and recycling groups   on its database.
                    tipping.             traffic,              to repair and          Continuous
                                         providing an          restore household      registration that
                    Private land         added incentive       goods e.g. furniture   was launched in
                    poses a              to dispose of         and white goods for    January 2004 is
                    particular           the waste in a        low income             hoped to go some
                    problem.             way convenient        households.            way to address
                    Boroughs can         to the person.                               this.
                    serve a notice       This is likely        Extensive work is
                    on the               to become an          undertaken             The ALG welcomes
                    landowners to        increasing            throughout the year    the powers in the
                    remove fly           factor as of          to ensure that         ASB Act 2003
                    tipping and          July 2004 when        residents are aware    giving the powers
                    take measures        the amount of         of the arrangements    for local
                    to prevent fly       Landfill sites        in place for waste     authorities to
                    tipping from         accepting             collection, such as    seize vehicles
                    occurring but        hazardous waste       days, times and any    suspected of being
                    it is often          will fall from        change in service.     involved in fly
                    difficult to         over 140 to just      This is done in a      tipping. However,



ALG Transport & Environment Committee                 23
                                                     228 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    trace and hold       14 in the UK –        number of languages.   due to the
                    accountable the      none of which                                hazardous nature
                    landowner.           will be in the        Dumping of waste is    of seizing a
                                         South East of         linked to recycling    vehicle and the
                                         England.              and some boroughs      type of offenders
                    There is also                              are working to         that are involved
                    considerable         In the                improve their          a police presence
                    amounts of           demolition and        recycling collection   would be required.
                    domestic waste       construction          service, for example   More police
                    dumped on the        business the          in relation to         resources are
                    streets and          propensity to         collecting garden      required to help
                    open spaces          contract, sub         waste.                 tackle fly
                    e.g. wardrobes,      contract and sub                             tipping.
                    beds, washing        contract again        Many boroughs
                    machines etc.        etc. leads to         operate a shifting     A London wide
                                         the lack of           programme of           campaign on fly
                    Under this           control or            awareness raising      tipping and
                    heading the          developer             and enforcement        dumping of waste
                    dumping of           responsibility        targeted at            is required to
                    domestic/trade       over the              businesses regarding   raise the
                    waste in bin         management of         trade waste. For       awareness that it
                    bags will also       waste produced        example, asking to     is illegal and the
                    be dealt with.       from any              see waste              options available
                    This is an           particular site       arrangements, if       such as the free
                    increasing           and the               these are not in       bulky waste
                    problem and          requirements of       place advising them    collections.
                    relates mainly       contractors           of their
                    to where there       dealing with          responsibilities.      Boroughs have the



ALG Transport & Environment Committee                 23
                                                     229 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    are small            waste to hold         After businesses       ability to issue a
                    business that        waste transfer        have been advised      Street Litter
                    avoid the duty       licenses/notes.       and warned and         Control Notice
                    of care              This is also          arrangements are not   (SLCN) for areas
                    requirements to      exacerbated by        in place when a        where there is a
                    dispose of           the limited           subsequent check is    prevailing
                    their waste          resources that        carried out then       problem. However,
                    properly. Trade      have been             enforcement action     the current
                    waste is often       available for         will be taken.         descriptions of
                    placed in bin        enforcement                                  who a notice can
                    bags and simply      (only the EA had      London boroughs have   be served on are
                    put out on the       the power to see      unique powers to       too limited.
                    streets or near      licenses/notes        issue a Street         Making specific
                    litter bins.         until 2003).          Litter Control         definitions of
                    This is also a                             Notice (SLCN) on       what type
                    problem with         Many boroughs         certain premises if    businesses can be
                    domestic             cite travellers       there is continuous    served a SLCN is
                    properties           as a particular       problem of litter      not satisfactory.
                    above shops          problem in fly        and dumping of         Better to have no
                    that have            tipping. Moving       waste.                 definition and
                    limited or no        from site to                                 leave it to the
                    space for waste      site leaving a        Boroughs are           boroughs to issue
                    storage and          trail of waste        operating in           them where it
                    place their          behind them,          partnership with       thinks it
                    rubbish out on       operating as a        other agencies such    appropriate,
                    the streets. In      business.             as the EA, police      provided the
                    some cases this                            and DVLA to stop,      authority can
                    is the               Boroughs offer        seize and prosecute    demonstrate there



ALG Transport & Environment Committee                 23
                                                     230 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    appropriate way      the bulky waste       people involved in     is a regular
                    to put waste         collection            fly tipping.           problem caused by
                    out, however,        services, a lack                             a specific
                    it needs to be       of awareness          A joint conference     situation. SLCNs
                    done on              that the service      was held in October    should not just be
                    specific days        is available or       2003 between the ALG   applied against
                    and times which      the feeling that      and the EA on fly      certain
                    is not adhered       „it is too much       tipping which          businesses; it
                    to.                  effort‟ to            provided               should be possible
                                         arrange are           clarification on       to use them
                    Bin bags placed      suggested             some key issues and    against any
                    on streets has       reasons for           generated good         premises or
                    a significant        people not to         debate and possible    landowner.
                    impact on the        take up the           solutions to
                    view of the          service.              tackling the issue.
                    cleanliness of
                    the area as the      Some of the           There has been
                    shops and flats      public are not        confusion over the
                    above shops          aware that            roles and
                    tend to be in        dumping their         responsibilities of
                    high street          household waste       different agencies,
                    areas, where         on streets and        particularly around
                    many people are      open spaces is        enforcement. This is
                    impacted.            illegal, they         being clarified with
                                         just know it          the development of a
                                         will get taken        new fly tipping
                                         away.                 protocol being
                                                               developed by the EA,



ALG Transport & Environment Committee                 23
                                                     231 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                                         Trade waste           setting out roles
                                         being dumped on       and responsibilities
                                         streets is            along with other
                                         largely due to        areas such as
                                         businesses            clarifying the
                                         avoiding the          definition of fly
                                         costs involved        tipping and dumped
                                         in managing           waste. This is due
                                         their waste in        to be launched by
                                         the manner in         April 2004.
                                         which they have
                                         a duty. Even          The ASB Act 2003
                                         when businesses       also gave the
                                         have                  Secretary of State
                                         arrangements n        powers to require
                                         place dumping         authorities to
                                         may still occur       provide information
                                         to reduce the         on fly tipping. The
                                         amount of waste       EA on behalf of
                                         being handled         Defra was tasked
                                         and thus paid         with developing a
                                         for through the       database, which is
                                         contract.             being developed to
                                                               be launched in April
                                         Many businesses       2004 called
                                         feel that waste       „FlyCapture‟ this
                                         collection and        will enable robust
                                         disposal should       data to be gathered



ALG Transport & Environment Committee                 23
                                                     232 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                                         be included in        on the scale and
                                         their business        extent of the
                                         rates and dump        problem. This will
                                         waste to avoid        see the reported
                                         costs as above.       incidences increase
                                                               massively as it will
                                         Domestic              be classifying a
                                         properties above      rubbish bag as a fly
                                         shops dump            tip.
                                         wastes for a
                                         variety of
                                         reasons as any
                                         other property,
                                         such as bulky
                                         household waste
                                         outlined above.
                                         In addition the
                                         lack of space
                                         for storage of
                                         waste in flats
                                         and communal
                                         areas results in
                                         people dumping
                                         their waste on
                                         the street.

                                         The transient
                                         nature and the



ALG Transport & Environment Committee                 23
                                                     233 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken   What else is
                    problem                                                          needed
                                         diversity of
                                         languages of
                                         London‟s
                                         population means
                                         it is difficult
                                         for boroughs to
                                         ensure residents
                                         are fully aware
                                         of their
                                         responsibilities
                                         for waste, the
                                         times and days
                                         of collection
                                         and when waste
                                         can be put out
                                         on the streets.

                                         There is the
                                         clear fact that
                                         waste attracts
                                         waste. Whether
                                         it be fly
                                         tipping or
                                         dumping of waste
                                         if it is not
                                         removed quickly
                                         more waste will
                                         be put there.



ALG Transport & Environment Committee                 23
                                                     234 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed


   Litter           Litter is a          The primary           Boroughs are           Reducing the
                    widespread           cause is people       increasing the         amount of litter
                    problem across       not disposing of      number of litter       dropped or the
                    London. There        their waste in a      bins on the streets.   number of people
                    are particular       responsible                                  who drop litter
                    concentrations       manner. A lack        Boroughs are           requires a
                    of litter in         of care or pride      investing more in      cultural change.
                    heavily              in their local        street cleansing,      This will require
                    pedestrian           environment           for example            a continuous,
                    areas, such as       results in            increasing the         active campaign to
                    high streets         people                frequency of street    alter people‟s
                    and near shops,      discarding            cleaning and           behaviour. It is
                    near education       litter without        emptying of bins.      evident that
                    facilities, car      any thought.                                 despite many
                    parks, bus                                 Some boroughs have     people dropping
                    stops, around        Lack of litter        signed Local Public    litter they are
                    rail and tube        bins results in       Service Agreements     also concerned
                    stations and         people dropping       to invest further in   about the amount
                    parks and open       litter                improving street       of litter on the
                    spaces               immediately as        cleansing, with        streets. Making
                    especially in        they think it         associated targets.    people feel
                    summer.              doesn‟t matter,                              responsible for
                                         rather than           Boroughs are           their actions and
                    Although             keeping hold of       undertaking local      the environment
                    generally there      it until they         education and          around them is
                    appears to be        come across a         awareness raising      essential.



ALG Transport & Environment Committee                 23
                                                     235 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    less of a            bin.                  campaigns to the
                    problem with                               general public and     More litter bins
                    cigarette ends       The type of           through schools,       are required and
                    there are            goods that are        with the production    would help reduce
                    concentrations       packaged is           of posters, leaflets   litter in some
                    of cigarette         increasing and        and school visits.     instances.
                    ends found           the packaging of
                    outside office       those goods is        Boroughs are           The amount of
                    areas,               increasing. This      undertaking            packaging on goods
                    particularly         is increasing         enforcement, issuing   needs to be
                    since more           the amount of         fixed penalty          minimised.
                    buildings are        packaging that        notices for litter.    Packaging that is
                    banning              needs to be           Many are engaging      biodegradable also
                    smoking.             discarded to get      the police to assist   needs to be
                                         to the goods you      in targeted            encouraged.
                    Chewing gum is       have just             enforcement to
                    a particular         purchased. This       ensure a correct       The power for
                    problem that         is increasing         name and address are   borough officers
                    appears to be        the waste             provided.              to require a
                    increasing.          arising.                                     verifiable name
                    Discarded                                  A benefit of           and address to be
                    chewing gum is       Increase in           providing wheelie      provided.
                    difficult and        offices banning       bins to households
                    costly to            smoking from          is that waste can be   It is strongly
                    remove.              their building        contained more         felt that this is
                                         without               effectively and        just not a
                    Staining is a        providing a           prevents bags          regional issue but
                    problem              suitable smoking      splitting and          national and an



ALG Transport & Environment Committee                 23
                                                     236 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    associated with      room or area,         littering the          extensive, high
                    litter and is        results in the        streets.               profile campaign
                    predominantly        gathering of                                 is required to
                    from food waste      employees at          Encouraging            change people‟s
                    such as chewing      exits to the          businesses to          behaviour. There
                    gum but other        building and          maintain their         is a role for
                    foods such as        discarding their      frontage,              London wide
                    chips, burgers       cigarette ends.       particularly in high   campaigns.
                    and kebabs.                                street areas.
                                         The relatively
                    Littering from       low likelihood        Boroughs that are
                    cars is a            of being caught       members of Capital
                    problem with         and enforcement       Standards are
                    people throwing      action taken,         involved in the
                    litter out of        means that this       London School
                    the window.          does not act as       Environment Awards
                                         a deterrent.          which involves over
                    From the ALG                               200,000 pupils and
                    Londoners            People throwing       focuses on litter
                    survey 20% of        litter out of         along with other
                    people stated        the car feel          environment issues.
                    the extent of        they are safer
                    litter in            and less likely       Capital Standards
                    London is of         to be caught.         boroughs also
                    concern.             Motorists will        engaged schools
                                         be driving            through the Pick It
                    There are links      through an area       Up song and book.
                    here with trade      and less likely



ALG Transport & Environment Committee                 23
                                                     237 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    waste which has      to care about         Capital Standards
                    been dealt with      the quality of        boroughs are also
                    under dumping        the local             involved in the
                    above.               environment.          forthcoming cinema
                                                               and poster ad
                                                               campaign
                                                               highlighting
                                                               Londoners
                                                               responsibilities in
                                                               keeping the city
                                                               clean.
                                                               Most boroughs are
                                                               part of ENCAMS
                                                               People and Places
                                                               programme, and link
                                                               in with the national
                                                               campaigns undertaken
                                                               by ENCAMS which
                                                               predominantly centre
                                                               around litter.




   Abandoned        The ALG              Abandoned             Boroughs have been     It is expected
   Vehicles         undertook a          vehicles are the      removing abandoned     that Operation
                    comprehensive        result of a           vehicles effectively   Scrap It will help
                    survey of            vehicle dropping      since the problem      reduce the number



ALG Transport & Environment Committee                 23
                                                     238 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    abandoned            out of the legal      arose.                 of vehicles
                    vehicles in          system. There is                             abandoned through
                    London in            a significant         In 200/03 19           tackling those
                    2001/2, that         relationship          boroughs had special   that are untaxed,
                    showed 235,389       between               (Operation Cubit or    whilst ensuring
                    vehicles were        abandoned             Scrap-It)              the speedy removal
                    reported to be       vehicle and           arrangements with      of any vehicles
                    abandoned and        untaxed               their local Police     abandoned.
                    had to be            vehicles.             colleagues to manage
                    investigated by      Vehicles that         the problem, 18 of     The DVLA
                    local                are untaxed are       which had developed    introduced
                    authorities.         often not             special information    continuous
                    The cost to          insured, not          sharing protocols.     registration in
                    London in            registered and        16 Boroughs had        January 2004, to
                    dealing with         not MOT‟d. This       special arrangements   ensure the owner
                    abandoned            makes the car         with their local       of a vehicle is
                    vehicles in          untraceable and       London Fire and        identified and
                    (2001/2) was         easy to abandon.      Emergency Planning     responsible for
                    £7,527,927.                                Authority (LFEPA)      that vehicle.
                                         Abandoned             colleagues.            Although this has
                    37% of all           vehicles is a                                been started it
                    abandoned            relatively new        With the               will take some
                    vehicles in          problem and is a      introduction of the    years for the
                    England are in       result in the         ELVD the ALG and the   impact of the
                    London.              fall in the           boroughs recognised    initiative to
                    (Municipal           price of scrap        that there was         fully take effect.
                    Waste                metal that meant      likely to be a
                    Management           instead of being      significant increase   It is necessary to



ALG Transport & Environment Committee                 23
                                                     239 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    Survey 2000/01,      paid by a scrap       in abandonment. The    ensure that
                    DEFRA)               dealer for your       ALG was successful     producers take
                                         car a person          in gaining £13.5m      full
                    Abandoned            would have to         over 2 years from      responsibility and
                    vehicles are         pay them to           the Home Office Anti   the costs of
                    often                dispose of it.        Social Behaviour       taking back their
                    vandalised and                             Unit to deal with      vehicles for
                    set on fire.         The introduction      nuisance vehicles      disposal. The
                    Vehicle fires        of the End of         (abandoned and         Government is
                    cost London          Life Vehicles         untaxed). The          currently
                    £50m per annum       Directive             project will start     consulting on this
                    (Home Office         (ELVD) will           in October 2003 –      element of the
                    Statistics,          significantly         boroughs will “go      ALVD and the ALG
                    cost of fires).      increase the          online” as soon as     will be responding
                                         cost of disposal      they are ready –       to it.
                    Abandoned            of a vehicle and      with all to be
                    vehicles             is likely to          active by October
                    attract the          increase the          2004.
                    dumping of           number of             The bid has two main
                    waste in and         abandoned             elements which are:
                    around the           vehicles. The          the development
                    vehicles.            directive places        of a pan London
                                         a responsibility        free take back
                    The vehicles         on the producer         service;
                    and the waste        of a vehicle to        removal of
                    they attract         take back and           abandoned and
                    add to the           dispose of the          untaxed vehicles
                    sense of an          vehicle free of         in 72hrs (3


ALG Transport & Environment Committee                 23
                                                     240 March 2004
Assembly & Protecting City Environment               Agenda Item 20
                    Extent of            Causes                Actions being taken    What else is
                    problem                                                           needed
                    uncared for          charge. However,         working days) of
                    environment an       producer                 a report and
                    increases the        responsibility           assessment.
                    fear of crime.       does not come
                                         into effect           The free take back
                                         until 2007, till      element of the
                                         that point            proposal gives the
                                         boroughs are          public the chance to
                                         responsible for       surrender a vehicle
                                         abandoned             at no cost to
                                         vehicles.             themselves and
                                                               therefore act
                                                               responsibly.

                                                               The operation has
                                                               the potential to
                                                               reduce all street
                                                               crime.




ALG Transport & Environment Committee                 23
                                                     241 March 2004
Assembly & Protecting City Environment               Agenda Item 20

				
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