Comment on 'Evaluation of main litter challenges' of Draft Litter Management Plan
Title:
The scourge of graffiti, fly-postering and stickers.
Castleknock TidyTowns is a very active Environmental, Sustainability & Climate Action Group operating for the past seven years. Thank you for giving us the opportunity to take part in your workshop and to contribute this submission.
In our view Litter Management is much more than about removing discarded refuse from public places. Personally, as the civic engagement lead for Castleknock TidyTowns (CTT) I have a particular interest in the scourge of Graffiti, Unauthorised Fly-Posters, Stickers, Election Poster Cable-Ties and Thrown-Away Chewing Gum etc as these issues come under my responsibility for CTT. We ask that these are more comprehensively addressed under the Fingal 2025-2027 Draft Litter Management Plan please. In our experience these issues do not receive the attention they deserve from our local authority. We suspect a significant part of the problem is they are not comprehensively addressed in Litter Management Plans together with the lack of adequate budgeted funding to tackle these problems. It appears very little, if any, money is set aside specifically to deal with them. This obviously must be addressed as they can take significant resources to manage. Without the necessary funding these issues will remain unresolved and eyesores in our communities
Chewing Gum.
On the question of discarded chewing gum perhaps FCC, together with other local authorities, can take the lead in encouraging central government to impose a special tax on the sale of gum which could be used for educational and cleanup purposes, IE “The Polluter Pays principal ” which is at the core of EU environmental policy. Additionally perhaps the local authority could take additional initiatives such as encouraging retailers not to sell gum in their areas (In Singapore the sale of gum is outlawed). We believe much could be done to improve the appearance of our villages, towns and cities by the removal of gum from our public areas. But it will take actions to bring this about. We suggest working with the National Gum Litter Task Force could achieve these aims.
Scourge of Graffiti.
I could talk for hours about the scourge of graffiti as I find it very objectionable and oppressive, especially in a residential environment. We in CTT have made it one of our top priorities over the past seven years. We believe strongly in the “broken window theory” whereby if a broken window is not replaced speedily it encourages further windows to be broken whereas if it is promptly replaced the likelihood of other broken windows greatly reduces. We have proven this theory definitively here in Castleknock as we have removed hundreds of pieces of graffiti over the past seven years and have found that only about 3 percent of locations have suffered from repeat graffiti. We find most graffiti is random, opportunistic and seldom targeted. Our efforts have been hugely successful. It’s a constant struggle and requires significant effort, especially in an urban environment, but it pays handsome dividends. We consider Castleknock, in the main, to be graffiti-free and sticker-free, quite a remarkable achievement. Most of this work has been carried out mainly by our volunteers with some help from FCC but much more assistance is needed please. Apparently due to their limited resources we struggle to get FCC to keep even their own installations, such as litter bins and traffic light control cabinets etc, graffiti-free/sticker-free . In fact we have frequently had to remove graffiti and stickers from FCC installations as they have not done so themselves on a timely basis. We find that it can often work against us when we remove graffiti from FCC traffic control cabinets as the Dublin Canvas Scheme of painting the cabinets is then not available to us. This is clearly counter productive and the rules need to be changed please. We have a number of ideas about the Dublin Canvas Scheme and would welcome an opportunity to discuss them please.
We believe, as the local authority with responsibility for the upkeep and appearance of the public realm, FCC should be leading by example by keeping on top of the graffiti scourge and set a top standard for utility companies and others with street-side infrastructure to follow. Sadly it appears this is not the case and it doesn’t appear to be a matter of priority for FCC and we at CTT earnestly seek this to be addressed in the Draft Plan please . After all if FCC is not maintaining their own installations they can’t expect others such as ESB Networks, Eir, An Post and Virgin Media etc to maintain theirs.
Stickers.
Stickers are a reasonably new nuisance and Vape Stickers a particularly common problem - the vape manufacturers must be pursued by the councils to change the packaging on their products. The stickers are a huge issue for FCC (and indeed CTT). Vape stickers need to be designed out of the packaging similar to how the plastic bottle tops can no longer be separated from the plastic bottles or cartons. The design of the bottle tops was changed universally and the problem of discarded bottle tops has now been solved. A similar initiative should be pursued with the vape stickers.
Election Posters.
By way of background information CTT has been operating an extremely successful Election Poster-Free Zone (PFZ) initiative for the past few years and receives the support of the majority of candidates and parties for which we are very grateful. However following every election and referendum CTT is left with the significant task of removing many hundreds of single use plastic election poster cable-ties from poles throughout our area outside of the PFZ which are left behind by candidates. It’s impossible to identify which candidates are at fault as, unlike election posters, there is no requirement to brand every plastic cable-tie with any sort of reference number or colour code to aid the process. We believe this should be addressed at national level but it needs to be driven at local level firstly by the local authority. We will be making a submission on this matter to The Electoral Commission in the next few weeks. Disappointingly we consider the Draft FCC Litter Management Plan does not address the issue of election posters and cable-ties with any proposed solutions. Across Fingal (and in other areas of Dublin) so many unsightly cable-ties still remain on poles.
Unauthorised Fly Postering.
We suffer here in Castleknock, along with all other areas of Fingal, with unauthorised postering by commercial companies advertising their services in the public realm. Often their posters are stuck up on traffic poles and are a distraction to motorists. We have frequently informed FCC Environment Department of the offenders and requested appropriate action be taken to remove their posters and ensure they don’t reoffend and in the event of a recurrence they are dealt with appropriately under the law. Unfortunately we don’t receive an acknowledgement or response from environment and we continue to see repeated violations by the same offenders so it appears as if no action has been taken. We have frequently reported one commercial company with branches throughout Dublin who are prolific serial law breakers whose main advertising modus operandi is sticking up their posters with sticky tape on public and private property in high footfall locations all around the county and indeed the city. The company has been vandalising property in this way continuously for many years now and still continues to this day. This is unacceptable and extremely disheartening for us given our substantial voluntary efforts to keep our area looking it’s best. We earnestly believe a much more active approach by FCC Environment Department (Litter Warden) is needed and would be beneficial. For example some procedures and protocols could be improved so that when the public advise Environment Department about an issue they should always receive an acknowledgement and a case number for follow up. They should then be advised what action has been taken and the results of that action, this just doesn’t happen unfortunately.
In contrast when we deal with FCC Operations Department we always promptly receive an acknowledgement, case number and follow up response. It is a pleasure to deal with them and we always feel they are working with us for the benefit of our community to make Castleknock a better place to live and enjoy. Sadly this is generally not the case with Environment Department and we hope this can be rectified in the future please and hence why we have included this item here in our submission.
Fines for breaches of the law
We consider the amount of €35,000 in fines imposed seems astonishingly low given the enormous annual spend of €10 million, the size of the area covered in Fingal and the cost of providing litter wardens. Especially given just how many opportunities we can see for issuing fines even within Castleknock, where we are regularly reporting fly posting, illegal stickers and dumping etc . Perhaps there are not sufficient Litter Wardens to issue and pursue the fines? Also we would encourage increasing the basic fines. The minimum fines are not a sufficient deterrent.
Litter and Sustainability
In our view the Draft Plan does not link up the idea of Sustainability with Litter strongly enough. People are much more interested in the topic of sustainability now. That message is finally getting through. Recycling and composting bins need to be called out in the plan to greater effect. A banana peel is highlighted as taking 2 years to biodegrade. However, there appears to be no specific mention of the brown bins in the Draft Plan.
Recycling Centres
Upcycling centres such as Coolmine should be interesting places to go. In the UK each recycling centre has a small 'shop' area where suitable items rescued (from both the containers or from the people dropping off stuff) are given away freely or at a nominal cost. Items like vases, ornaments, books, small furniture items like desks /bookshelves /coffee tables etc. are on offer. People love to go 'to the tip' to see if they can find something interesting. This inspires more passing on of preloved items rather than those items being sent to landfill or being illegally dumped. Effectively the way the recycling centres are set up here encourages people to break items down into their constituent elements rather than nudging them to recycle in a more sustainable way by passing the item on for future use by someone else. As a Castleknock TidyTowns initiative we set up in October 2022 a hugely successful Castleknock CommunityCycle Facebook site which has almost 4,000 members and resulted in over 21,000 items so far being saved from landfill. It shows the potential for recycling and reusing.
Working Together Generally we are delighted with the excellent cooperation and support we receive from the various departments of Fingal County Council. Like everything in life some things can be improved and we look forward to continuing to work together with our FCC Partners to make Castleknock and Fingal better for the benefit of our communities.
Observations
Castleknock TidyTowns is a very active Environmental, Sustainability & Climate Action Group operating for the past seven years. Thank you for giving us the opportunity to take part in your workshop and to contribute this submission.
In our view Litter Management is much more than about removing discarded refuse from public places. Personally, as the civic engagement lead for Castleknock TidyTowns (CTT) I have a particular interest in the scourge of Graffiti, Unauthorised Fly-Posters, Stickers, Election Poster Cable-Ties and Thrown-Away Chewing Gum etc as these issues come under my responsibility for CTT. We ask that these are more comprehensively addressed under the Fingal 2025-2027 Draft Litter Management Plan please. In our experience these issues do not receive the attention they deserve from our local authority. We suspect a significant part of the problem is they are not comprehensively addressed in Litter Management Plans together with the lack of adequate budgeted funding to tackle these problems. It appears very little, if any, money is set aside specifically to deal with them. This obviously must be addressed as they can take significant resources to manage. Without the necessary funding these issues will remain unresolved and eyesores in our communities
Chewing Gum.
On the question of discarded chewing gum perhaps FCC, together with other local authorities, can take the lead in encouraging central government to impose a special tax on the sale of gum which could be used for educational and cleanup purposes, IE “The Polluter Pays principal ” which is at the core of EU environmental policy. Additionally perhaps the local authority could take additional initiatives such as encouraging retailers not to sell gum in their areas (In Singapore the sale of gum is outlawed). We believe much could be done to improve the appearance of our villages, towns and cities by the removal of gum from our public areas. But it will take actions to bring this about. We suggest working with the National Gum Litter Task Force could achieve these aims.
Scourge of Graffiti.
I could talk for hours about the scourge of graffiti as I find it very objectionable and oppressive, especially in a residential environment. We in CTT have made it one of our top priorities over the past seven years. We believe strongly in the “broken window theory” whereby if a broken window is not replaced speedily it encourages further windows to be broken whereas if it is promptly replaced the likelihood of other broken windows greatly reduces. We have proven this theory definitively here in Castleknock as we have removed hundreds of pieces of graffiti over the past seven years and have found that only about 3 percent of locations have suffered from repeat graffiti. We find most graffiti is random, opportunistic and seldom targeted. Our efforts have been hugely successful. It’s a constant struggle and requires significant effort, especially in an urban environment, but it pays handsome dividends. We consider Castleknock, in the main, to be graffiti-free and sticker-free, quite a remarkable achievement. Most of this work has been carried out mainly by our volunteers with some help from FCC but much more assistance is needed please. Apparently due to their limited resources we struggle to get FCC to keep even their own installations, such as litter bins and traffic light control cabinets etc, graffiti-free/sticker-free . In fact we have frequently had to remove graffiti and stickers from FCC installations as they have not done so themselves on a timely basis. We find that it can often work against us when we remove graffiti from FCC traffic control cabinets as the Dublin Canvas Scheme of painting the cabinets is then not available to us. This is clearly counter productive and the rules need to be changed please. We have a number of ideas about the Dublin Canvas Scheme and would welcome an opportunity to discuss them please.
We believe, as the local authority with responsibility for the upkeep and appearance of the public realm, FCC should be leading by example by keeping on top of the graffiti scourge and set a top standard for utility companies and others with street-side infrastructure to follow. Sadly it appears this is not the case and it doesn’t appear to be a matter of priority for FCC and we at CTT earnestly seek this to be addressed in the Draft Plan please . After all if FCC is not maintaining their own installations they can’t expect others such as ESB Networks, Eir, An Post and Virgin Media etc to maintain theirs.
Stickers.
Stickers are a reasonably new nuisance and Vape Stickers a particularly common problem - the vape manufacturers must be pursued by the councils to change the packaging on their products. The stickers are a huge issue for FCC (and indeed CTT). Vape stickers need to be designed out of the packaging similar to how the plastic bottle tops can no longer be separated from the plastic bottles or cartons. The design of the bottle tops was changed universally and the problem of discarded bottle tops has now been solved. A similar initiative should be pursued with the vape stickers.
Election Posters.
By way of background information CTT has been operating an extremely successful Election Poster-Free Zone (PFZ) initiative for the past few years and receives the support of the majority of candidates and parties for which we are very grateful. However following every election and referendum CTT is left with the significant task of removing many hundreds of single use plastic election poster cable-ties from poles throughout our area outside of the PFZ which are left behind by candidates. It’s impossible to identify which candidates are at fault as, unlike election posters, there is no requirement to brand every plastic cable-tie with any sort of reference number or colour code to aid the process. We believe this should be addressed at national level but it needs to be driven at local level firstly by the local authority. We will be making a submission on this matter to The Electoral Commission in the next few weeks. Disappointingly we consider the Draft FCC Litter Management Plan does not address the issue of election posters and cable-ties with any proposed solutions. Across Fingal (and in other areas of Dublin) so many unsightly cable-ties still remain on poles.
Unauthorised Fly Postering.
We suffer here in Castleknock, along with all other areas of Fingal, with unauthorised postering by commercial companies advertising their services in the public realm. Often their posters are stuck up on traffic poles and are a distraction to motorists. We have frequently informed FCC Environment Department of the offenders and requested appropriate action be taken to remove their posters and ensure they don’t reoffend and in the event of a recurrence they are dealt with appropriately under the law. Unfortunately we don’t receive an acknowledgement or response from environment and we continue to see repeated violations by the same offenders so it appears as if no action has been taken. We have frequently reported one commercial company with branches throughout Dublin who are prolific serial law breakers whose main advertising modus operandi is sticking up their posters with sticky tape on public and private property in high footfall locations all around the county and indeed the city. The company has been vandalising property in this way continuously for many years now and still continues to this day. This is unacceptable and extremely disheartening for us given our substantial voluntary efforts to keep our area looking it’s best. We earnestly believe a much more active approach by FCC Environment Department (Litter Warden) is needed and would be beneficial. For example some procedures and protocols could be improved so that when the public advise Environment Department about an issue they should always receive an acknowledgement and a case number for follow up. They should then be advised what action has been taken and the results of that action, this just doesn’t happen unfortunately.
In contrast when we deal with FCC Operations Department we always promptly receive an acknowledgement, case number and follow up response. It is a pleasure to deal with them and we always feel they are working with us for the benefit of our community to make Castleknock a better place to live and enjoy. Sadly this is generally not the case with Environment Department and we hope this can be rectified in the future please and hence why we have included this item here in our submission.
Fines for breaches of the law
We consider the amount of €35,000 in fines imposed seems astonishingly low given the enormous annual spend of €10 million, the size of the area covered in Fingal and the cost of providing litter wardens. Especially given just how many opportunities we can see for issuing fines even within Castleknock, where we are regularly reporting fly posting, illegal stickers and dumping etc . Perhaps there are not sufficient Litter Wardens to issue and pursue the fines? Also we would encourage increasing the basic fines. The minimum fines are not a sufficient deterrent.
Litter and Sustainability
In our view the Draft Plan does not link up the idea of Sustainability with Litter strongly enough. People are much more interested in the topic of sustainability now. That message is finally getting through. Recycling and composting bins need to be called out in the plan to greater effect. A banana peel is highlighted as taking 2 years to biodegrade. However, there appears to be no specific mention of the brown bins in the Draft Plan.
Recycling Centres
Upcycling centres such as Coolmine should be interesting places to go. In the UK each recycling centre has a small 'shop' area where suitable items rescued (from both the containers or from the people dropping off stuff) are given away freely or at a nominal cost. Items like vases, ornaments, books, small furniture items like desks /bookshelves /coffee tables etc. are on offer. People love to go 'to the tip' to see if they can find something interesting. This inspires more passing on of preloved items rather than those items being sent to landfill or being illegally dumped. Effectively the way the recycling centres are set up here encourages people to break items down into their constituent elements rather than nudging them to recycle in a more sustainable way by passing the item on for future use by someone else. As a Castleknock TidyTowns initiative we set up in October 2022 a hugely successful Castleknock CommunityCycle Facebook site which has almost 4,000 members and resulted in over 21,000 items so far being saved from landfill. It shows the potential for recycling and reusing.
Working Together Generally we are delighted with the excellent cooperation and support we receive from the various departments of Fingal County Council. Like everything in life some things can be improved and we look forward to continuing to work together with our FCC Partners to make Castleknock and Fingal better for the benefit of our communities.