For General Release
REPORT TO:
CABINET 16 OCTOBER 2012
AGENDA ITEM:
SUBJECT:
LEAD OFFICER:
CABINET MEMBER:
6
COMPULSORY RECYCLING- CONSULTATION RESULTS
TONY BROOKS, DIRECTOR OF PUBLIC SAFETY AND
PUBLIC REALM
COUNCILLOR THOMAS, CABINET MEMBER FOR
HIGHWAYS AND ENVIRONMENTAL SERVICES
WARDS:
ALL
CORPORATE PRIORITY/POLICY CONTEXT: Increasing recycling within Croydon
has been a high priority and target area for reducing costs. Services were changed in
October 2011 to increase recycling and a move to compulsory recycling would assist in
delivering increased service participation, reduce landfill costs and increased recycling
rates.
Improvements to waste reduction and recycling support the Council’s corporate priority
of improving the environment. Increasing recycling rates, diverting waste from landfill,
and improving the Council’s assets will also address the value for money key priority.
FINANCIAL IMPACT
Increasing recycling participation will increase recycling tonnage, whilst reducing
landfill tonnage. Current landfill costs are approximately £106 per tonne and by
reducing tonnage to landfill it is estimated that £200,000 savings can be achieved. The
already high costs of landfill are exacerbated by the annual £8 escalator applied to the
tax element of the cost of landfill per tonne, which for 2012/13 is £64 per tonne.
Whilst there is a cost associated with the processing of recyclables, this is £30 per
tonne, as opposed to £106 per tonne for the landfilling of waste representing a saving
to the Council.
FORWARD PLAN KEY DECISION REFERENCE NO.: 1164
This is a Key Decision as defined in the Council’s Constitution. The decision may be
implemented from 1300 hours on the 5th working day after it is made, unless the
decision is referred to the Scrutiny & Strategic Overview Committee by the requisite
number of Councillors.
11
The Leader of the Council has delegated to the Cabinet the power to make the
decisions set out in the recommendations below
1.
RECOMMENDATIONS
The Cabinet is recommended to:
1.1 Consider the results of the public consultation regarding the introduction of
Compulsory Recycling scheme.
1.2 Agree to the implementation of a Compulsory Recycling Scheme with effect from 1
January 2013.
1.1
2.
2.1
EXECUTIVE SUMMARY
Croydon has developed a comprehensive range of waste and recycling
collection services, with the latest expansion to the service occurring in October
2011, when food waste collections were successfully introduced across the
borough.
2.2
Recycling rates within the borough have improved from 16% in 2005/6 to 33%
in 2010/11 and 38.1% during 2011/2012. This is against a backdrop of rapidly
increasing costs associated with the landfilling of waste due to the annual £8
increment on the per tonne cost of landfill tax, currently £64 per tonne and due
to increase to £80 per tonne on 1 April 2014.
2.3
Many residents habitually recycle and as detailed in the report, for those
residents that have difficulty accessing and or using the council’s recycling &
landfill collection services, assisted collections are available. However there are
a minority who have access to collection services who are able to recycle but
choose not to and this impacts upon their immediate environment and all waste
continues to go to landfill. It is properties of this nature that this policy is
targeted towards.
2.4
Compulsory recycling is considered to be the next logical step in the Council’s
approach to reducing landfill costs and decreasing the budgetary pressure from
increasing landfill taxes, whilst engaging with residents who impact upon the
public amenity of their locality.
2.5
The approach would involve identifying those properties and residents that fail
to recycle, or have not requested assistance, and then to observe what is
presented for collection over a period of weeks. This would be followed by
engagement with those properties who have presented nothing and monitoring
of their collections to assess whether they have started recycling. If they still
fail to recycle, communications and enforcement action will then be
implemented.
2.6
At its meeting on 9th July 2012 Cabinet agreed that officers undertake a public
consultation on the options for the introduction of compulsory domestic recycling (Min. A87/12).This report sets out the details of the recent public
12
consultation on the proposal to introduce compulsory recycling scheme and will
be seeking agreement from Cabinet to it’s introduction from 7 January 2013.
3.
DETAIL
3.1
Recycling within the London Borough of Croydon has improved significantly in
recent years with recycling rates more than doubling from 16.17% in 2005/06 to
33.46% in 2010/11 with further improvement achieved in 2011/12 as a result of
the changes to recycling services in October 2011 to 38.1%. As a result of the
changes in October 2011, the borough is expected to achieve a 46% recycling
rate in 2012/13.
3.2
The changes in service provision were structured as follows:
Food waste
Green box
New, existing or
enhanced?
New
Enhanced
Collection
frequency
Weekly
Every other week
(alternating with
the blue box)
Blue box
Existing
Textiles (in a
plastic bag)
Green waste
Existing
Every other week
(alternating with
the green box)
Every week
Existing
Every other week
(seasonal)
Landfill bin
Existing
Every other week
(previously was
weekly)
Input
Food waste
Tins, cans,
bottles, glass,
aerosols, foil and
plastic packaging
Paper and card
Clothing and
shoes
Green garden
waste, no food
waste
Items that cannot
be recycled
3.3
Whilst there are many enthusiastic recyclers in the borough there is a minority
who do not use recycling services. These households have access to the
service, but choose not to participate in the service despite previous
communication. Compulsory recycling is a tool which the Council can use to
encourage these households to participate in the service.
3.4
For some residents that have difficulty accessing and or using the council’s
recycling & landfill collection services, they have already advised the council
and have been included on the assisted collection available. This service
ensures that all recycling receptacles and landfill bins are collected and
returned to an agreed location on the resident’s property.
Compulsory recycling
3.5
Compulsory recycling requires residents to regularly present recycling for
collection at the kerbside. If the policy is implemented collections will be
monitored initially by a project team to identify non-recycling households who
will then be engaged with to identify any barriers and encourage them to start
recycling. Collections are monitored post-engagement to assess whether
13
behavioural change has been achieved. If the household, despite our attempts
to encourage wider recycling, fails to recycle, this will lead to a consideration of
enforcement.
3.6
Reflecting the present arrangements for offering assistance to those residents
who have difficulty accessing and or using the council’s recycling & landfill
collection services, it is proposed that the compulsory scheme will also provide
for a level of discretion to be given to officers implementing it to ensure that in
relation to compliance with it’s equalities duties, any affected protected groups,
for example Age or Disability are not negatively affected by this approach.
Some residents may have legitimate reasons why they are not presenting
recycling for collection, such as, a severe disability, committed home
composting or they may choose to recycle using other facilities such as the
Household Neighbourhood Recycling Centre. By affording officers a level of
discretion these properties would not be unfairly affected by the implementation
of this policy.
3.7
Compulsory recycling has been used by a range of other London boroughs.
Authorities who have used the ‘monitor, engage, monitor’ approach have
experienced a notable increase in recycling tonnage. By increasing recycling
and reducing landfill tonnage savings can be achieved in avoiding landfill tax.
Other benefits can also be realised in terms of improved standards of street
cleanliness in the local area. Persistent non-recyclers can in some cases blight
their neighbourhood with overflowing landfill bins and side waste causing
embarrassment and frustration for their neighbours. Implementing compulsory
recycling provides a tool to tackle locations where this is prevalent and
demonstrates support for the many enthusiastic recyclers within the borough.
Barnet’s compulsory recycling policy
3.8
The London Borough of Barnet was the first London council to adopt
compulsory recycling for their household properties in March 2005. The policy
was implemented using the ‘monitor, engage, monitor’ approach through a
project team. Barnet were very pro-active in communicating their policy with a
letter sent to all 113,000 affected properties signed by their Cabinet Member for
the Environment with a FAQ sheet, alongside a full range of communications
approaches including bin stickering to communicate the policy.
3.9
Results show a 28% increase in recycling tonnage collected in the first year of
the policy implementation, and their recycling rate increased from 19.87% in
2004/5 to 27.47 in 2005/6 (although they did introduce green waste collections
in this time also). Following policy implementation a participation rate of 80%
has been achieved. Participation rate is defined as the placement out of
recycling boxes by residents during a monitoring period.
3.10
In trialling and implementing the policy, box requests increased by 1,617
requests in the year of the trial period and by 5,218 and 6,158 in the first two
years of borough wide implementation. Preparations for implementing this
initiative will take this into account.
Advantages of adopting compulsory recycling
14
3.11
By adopting a compulsory recycling policy the Council could use this as a tool
to provide the following advantages:

Increased recycling service participation

Provide a tool to tackle persistent non-recyclers through a supportive
approach backed by legislation to enforce

The ability to respond to reports of poor management of waste and
recycling from residents

Reduced cost of landfill disposal

Positive environmental impact of reduced waste to landfill

Improved standards of visual presentation and street cleanliness

Increased recycling tonnage and recycling rate
4.
CONSULTATION RESULTS
4.1
A public consultation to seek the views of residents on the proposal to introduce
compulsory recycling was undertaken during 10 July to 31 August 2012.
4.2
The following consultative mechanisms were used:

Questionnaire – this was available online through the Council web site
and in paper form for those without internet access.

Face to face – resident’s views were sought by consulting face to face
with using questions based upon the online questionnaire.

Presenting to Focus Groups- Four groups were held on Wednesday 28
August and Thursday 29 August for residents who had indicated on their
questionnaire return that they would like to be involved in a Focus Group to
discuss this matter in further detail.
4.3
A full communications and engagement plan was established to ensure that a
broad range of views were solicited and the policy is positioned correctly, and
the consultation has been publicised by the following communication methods:
Two press releases

Posters, flyers and paper copies to all libraries (additional copies have
been delivered where required)

Online through the Croydon Council website

Your Croydon article

Mailing to 73 housing associations

Emails to minority groups

Posters provided to Access Croydon

Posters on staff notice boards

Presentation to mental health user group

Flyers out with engagement team

Hand held units face to face surveys in Norbury High Street, North
End/Surrey Street, Thornton Heath, Coulsdon, New Addington and
Purley.

Posters displayed on staff notice boards
15
a)
b)
c)
d)
4.4
Consultation was clear in so much that:It made clear what options were under consideration, and before a final
decision is made by the Council each option was described sufficiently enough
to allow for intelligent consideration of them and the impact on those who would
be effected by compulsory recycling;
There was sufficient time for those consulted to put their views to the Council;
Needs were considered in respect of all protected groups under the Equalities
Act 2010 to ensure that any particular needs appropriate to the group were
facilitated;
Residents were advised that the outcome of responses to the consultation was
to be reported back to a future meeting of the Cabinet on 16 October 2012, for
Members to fully consider in detail prior to a decision being taken by the
Council as to the most appropriate option to be pursued;
The views from residents have been reviewed and evaluated, and
372 responses have been received from four specific communication
methods;Paper based responses – 21
Online survey responses – 351
Talkaoke feedback – 33
Hand held face to face surveys - 110
4.5
Table 1 details the results relating to the Hand held and Talkaoke results:
Table 1
I believe
in
recycling
% agree
and
strongly
agree
%
disagree
and
strongly
disagree
% neutral
Total
We should
all recycle
to reduce
the amount
of waste
that goes
to landfill
and reduce
Croydon’s
environme
ntal
impact.
We should
all recycle to
reduce the
amount of
waste that
goes to
landfill to
help reduce
costs,
freeing up
money for
other
services.
I believe
those who
currently
do not
recycle
regularly
should be
encourage
d to start.
I think
Croydon
Council
should make
regular
kerbside
recycling
compulsory.
I think
Croydon
Council
should take
necessary
action against
those who are
unwilling to
recycle
(including
potential fines
for those who
continue to be
unwilling to
recycle).
73.77
67.80
90.91
92.42
90.77
89.15
4.20
7.58
1.54
3.10
8.20
14.41
4.90
100.00
0.00
100.00
7.69
100.00
7.75
100.00
18.03
100.00
17.80
100.00
16
4.6
Table 2 details the results relating to the paper based and online surveys.
Table 2
I believe
in
recycling
% agree
and
strongly
agree
%
disagree
and
strongly
disagree
% neutral
Total
4.7
93.55
We should
all recycle
to reduce
the amount
of waste
that goes to
landfill and
reduce
Croydon’s
environmen
tal impact.
We should
all recycle to
reduce the
amount of
waste that
goes to
landfill to
help reduce
costs,
freeing up
money for
other
services.
90.32
85.09
I believe
those who
currently
do not
recycle
regularly
should be
encourage
d to start.
88.15
I think
Croydon
Council
should make
regular
kerbside
recycling
compulsory
I think Croydon
Council should
take necessary
action against
those who are
unwilling to
recycle
(including
potential fines
for those who
continue to be
unwilling to
recycle).
62.67
58.33
2.96
3.49
7.05
5.51
27.52
31.18
3.49
100.00
6.18
100.00
7.86
100.00
6.34
100.00
9.81
100.00
10.48
100.00
The proposition put to residents in respect of introducing compulsory recycling
was;

I think Croydon Council should make regular kerbside recycling
compulsory.
The results to this proposition were 73.77% agreed from the handheld and
Talkaoke surveys, and 62.67% agreed from paper based and online surveys.
4.8
A further proposition linked to the introduction of compulsory recycling the
wording of the question was:

I think Croydon Council should take necessary action against those who
are unwilling to recycle (including potential fines for those who continue to
be unwilling to recycle).
The results to this question were 67.80% agreed from the handheld and
Talkaoke surveys, and 58.33% agreed from paper based and online surveys
4.9
The responses to both of these questions show that there is significant support
to the council’s proposal to implement a borough-wide compulsory recycling
scheme.
17
4.10
Where residents who expressed a view that they disagreed with the proposal to
introduce compulsory recycling their concerns with (officers responses shown
in italics) are detailed below:

People should decide if they want to recycle – From the public
consultation it is clear that a significant number of residents participating in the
survey support the council’s proposal to introduce a borough-wide compulsory
recycling scheme.

Freedom of choice – When residents were asked their views on
whether we should all recycle to reduce the amount of waste that goes to
landfill, over 90% of residents agreed with this approach.

Better to educate – As part of the proposed scheme the focus will be on
engagement with residents to raise awareness of how to recycle, and to
promote reuse.

What if already recycle all waste and use council’s Reuse &
Recycling Centres – The council is clear that where residents can
demonstrate that they are already recycling, then officers will cease monitoring
their property.

More help & information. - As part of the proposed scheme the focus
will be on engagement with residents to raise awareness of how to recycle, and
to promote reuse.
5.
Scheme implementation
5.1
It is recommended that compulsory recycling, if implemented, should also have
a ‘monitor, engage, monitor’ policy approach prior to formal enforcement. This
approach, where introduced, has been successfully implemented along with an
engagement team supporting the service change where it has delivered
encouraging results within the borough.
5.2
As part of such an approach detailed records would need to be kept
regarding the lack of recycling presented for collection and to be able to
respond to enquiries, which experience shows would be forthcoming. It is
therefore proposed that a dedicated project team is formed to initially
implement the scheme. The team would be in place for six months to give
impetus to the policy and deliver the ‘monitor, engage, monitor’ approach. The
team will be advised to use a supportive, encouraging approach to ensure
residents are able to engage with staff that can answer questions and provide
advice. This will be funded through an investment of £60,000 from the
proposed savings (see Para 6.2 below).
5.3


There isn’t the need to deliver the ‘monitor, engage, monitor’ approach to all
addresses and evidence indicates that it would be possible to prioritise this
approach to key roads within the borough. Work has already been undertaken
on monitoring participation by residents in each of the five collection zones
covering the whole borough. Options as to the process for identifying areas
where activity will be focussed may include:
Target resource on the areas where we know there are high levels of nonrecyclers residing:
Information from recycling collection teams:
18

5.4



5.5



Undertake analysis to understand which areas present the lowest weight of
recycling, and target resource accordingly.
Once roads are selected the following process can be used to identify which
properties consistently do not recycle:
Letter drop households to alert them their collections will be monitored:
Undertake three weeks of early morning collections monitoring to identify
relevant properties. If recycling is presented on one or more occasions they
are removed from the scope of the project:
Door knocking of properties identified from monitoring to engage with
householders, advise their property has been identified, answer questions and
offer caddies and recycling boxes. If no answer a letter with a pre-paid
envelope is delivered. Delivery of required equipment will be made.
Once any required equipment has been delivered, there will be further
monitoring as set out below:
Three weeks of early morning monitoring to assess the impact of the
engagement and if no recycling is presented a ‘yellow’ letter to be issued:
Three weeks further monitoring and if recycling continues not to be presented a
‘red’ letter to be issued:
Three weeks of further early morning monitoring, and if no recycling is
presented the details are passed to the Area Environment Enforcement Officers
in order to issue the fixed penalty notice.
Appendix A details the proposed process.
5.6
This gives the resident sufficient opportunities to present recycling and an
opportunity to engage face to face with the council. It is important the approach
gives residents every opportunity to recycle and an opportunity to ask questions
or seek clarification.
5.7
Whilst issuing fixed penalty notices and taking residents to court is a possibility,
other boroughs have found this is a rare occurrence. Where fixed penalty
notices are issued fines will be at £80 with a reduction for early payment.
5.8
The experience from other councils indicates almost all residents respond to
the series of communications accompanying the implementation of the policy,
so there is little requirement to use the legal process, although the council must
be prepared to use the legal process in the event it is required.
5.9
Only after a red letter has been issued, officers will then check the landfill bin
for any recyclables as part of evidence gathering.
5.10
It is proposed that subject to the outcomes of the consultation, if adopted, the
compulsory recycling scheme will be implemented on 7 January 2013.
Scheme parameters
5.11
It is proposed that initially compulsory recycling is applied to properties which
currently receive the recycling box and food waste service (houses and flatted
locations of up to five dwellings). This excludes properties such as blocks of
flats and flats above shops. These properties could form a further phase of
activity following the initial policy implementation.
19
5.12
The policy is to be applied to all recyclable material currently collected as part
of the kerbside collection services including paper/card, glass, plastic, green
waste and food waste.
5.13
There are some avid composters on the borough who through the consultation
have shown concern about their low frequency of collection box presentations
as they compost so much and others who choose to use the Neighbourhood
Recycling Centres rather than the kerbside collections. Where there are clear
reasons like these why the resident does not recycle, then they will be removed
from the procedure.
5.14
Some residents have already advised the council of concerns that they have
with accessing recycling and landfill bin collection services and these residents
have been included on the council’s assisted collection service. This service
ensures that all recycling receptacles and landfill bins are collected and
returned to an agreed location on the resident’s property.
6.
FINANCIAL AND RISK ASSESSMENT CONSIDERATIONS
6.1
Revenue and Capital consequences of report recommendations
Medium Term Financial Strategy – 3 year
forecast
2013/14
2014/15
2015/16
Current year
2012/13
£’000
£’000
Revenue Budget
available
Expenditure
Income
Effect of decision
from report
Expenditure on
awareness work
Savings from
recycling
£’000
£’000
(200)
(200)
(200)
(140)
(200)
(200)
60
Remaining budget
Capital Budget
available
Expenditure
Effect of decision
from report
Expenditure
Remaining budget
20
6.2
The effect of the decision
The assumed savings in the diversion of some 2,357 tonnes of household
waste which is currently landfilled for recycling will result in the Council making
a full year saving of £200,000 in 2013/14.
This assumed tonnage diversion is based on the net saving of around £85 per
tonne, based on assumed rates for landfill Tax, landfill gate fee and recycling
processing costs for 2013/2014.
In order to achieve this diversion a one off investment of £60,000 will be
required to enable the necessary waste awareness officers to be engaged to
undertake the required visits to specific roads within the borough where existing
recycling levels are low.
It is assumed that in 2013/14 there will be a net saving of £140,000, and an
ongoing annual saving of £200,000.
Furthermore, it is expected that as a result of this initiative there will be a
requirement for an additional 20,000 recycling boxes at a cost of £77,000.
There is currently provision in the 2013/14 capital programme of £150,000 for
replacement bins.
6.3





6.4


Risks
There are some risks in implementing a compulsory recycling policy:
Adequate resource needs to be available to handle increased recycling box and
food caddy requests.
Comprehensive records need to be kept in implementing this policy, if these are
not maintained ability to enforce will be compromised.
Whilst the policy would be implemented initially by a project team the question
about how this is delivered and enforced long term is to be resolved.
The council may need to consider the possibility of taking enforcement action
against residents.
Potential for negative press and resident reaction to the scheme.
Options
Alternative options to compulsory recycling for consideration are:
The alternative to compulsion is incentivisation. This has been used by a small
number of councils, most notably Windsor and Maidenhead. There would be
barriers to overcome in funding the provision of incentives and equipping the
vehicles to support implementation.
Alternative approaches to implementation:
Detail of the policy could be printed on future leaflets and the website without
implementation or a project team. By not monitoring and engaging with
residents the policy could risk being ineffectual.
The main priority for this policy is street properties rather than flats (of five or
more dwellings) as the flats food waste service introduction is still being rolled
out and bedded in. These properties receive a different service from
households in there is a communal bin which is shared by residents which
leads to a more complex enforcement process. Properties of this nature could
be part of a later project.
21
6.5
Future savings/efficiencies
The investment of £60,000 for the waste awareness officers will enable an
assumed yearly saving in 2013/14 of £170,000, and £200,000 in later years as
the officers encourage residents who do not currently recycle to divert more of
their waste from landfill.
(Approved by: Richard Simpson, Director of Finance and Deputy Section 151
Officer)
7.
COMMENTS OF THE COUNCIL SOLICITOR AND MONITORING OFFICER
7.1
The Council Solicitor comments that compulsory recycling can be enforced by
local authorities under section 46 of the Environmental Protection Act 1990 (as
amended). It’s provisions give a waste collection authority the power to require
an occupier to place waste for collection in receptacles of a kind and number
specified. A person who fails, without reasonable excuse, to comply with any
requirements imposed may be liable on summary conviction to a fine not
exceeding level 3 on the standard scale (currently £1000). Alternatively, an
authorised officer may give that person a notice offering them the opportunity of
discharging any liability to conviction for the offence by payment of a fixed
penalty to the waste collection authority.
7.2
While the legislation does not raise a statutory duty to consult, the DEFRA
website indicates its expectation that all local authorities should seek the views
of their customers when designing and delivering waste services. Further the
Local Government Act 1999 sets out the duty of Best Value – local authorities
must show that their services have been influenced by resident’s views, and
provide the best possible value. Insofar as consultation will help demonstrate
this, case law has emphasised the duty in doing so to consult property, the key
elements of which can be summarised as:
 Consult when proposals are at the formative stage;
 Reasons for proposed changes should be given;
 Options should be given including the option to do nothing;
 Sufficient time should be given;
 Full information should be given, not partial;
(Approved by: Gabriel MacGregor, Head of Corporate Law on behalf of the
Council solicitor and Monitoring Officer)
8.
HUMAN RESOURCES IMPACT
8.1
There are no human resources impacts arising from this report.
8.2
Approved by: Adrian Prescod, HR Business Partner, on behalf of the director,
Human Resources Organisational Effectiveness.
9.
EQUALITIES IMPACT
9.1
An initial Equality Impact Assessment for this new policy has been prepared,
and there is no further equality impact assessments required.
22
9.2
The council operates an assisted collection service for residents who are
unable to place out their recycling receptacles or landfill bins for collections.
9.3
The assisted collection service allows for the recycling and waste collection
contractor to collect and return recycling receptacles and landfill bins to an
agreed location within the residents property. This service is accessed by
contacting the councils Contact Centre on 020 8726 6200, or by e-mailing
contact.thecouncil@croydon.gov.uk or by texting 60660.
10.
ENVIRONMENTAL IMPACT
Decreasing the amount of household waste which is currently land filled will
assist the council in improving its recycling performance and reduce our carbon
emissions relating to the landfill of that waste.
11.
REASONS FOR RECOMMENDATIONS/PROPOSED DECISION
The Council has made significant progress with encouraging residents to
recycle as much of their household waste as possible. Unfortunately some
residents still resist participating in using the comprehensive kerbside recycling
service offered by the council. The introduction of a compulsory recycling
scheme will enable the council to engage & monitor residents who continue to
not use the council’s recycling services.
12.
OPTIONS CONSIDERED AND REJECTED
These are detailed within paragraph 6.4 of this report.
Appendices
Appendix A - Process for monitoring and engaging with properties. Please see below.
CONTACT OFFICER: Malcolm Kendall, Head of Environmental and Leisure
BACKGROUND DOCUMENTS: none
23
Appendix A – Process for monitoring and engaging with properties
Letter drop to
households in the
selected road/s
Three weeks of
early morning
monitoring
Door knock properties not
presenting recycling to
check they have
boxes/caddies,
understand any barriers
and answer any
Three weeks of
questions
early morning
monitoring
If there are clear
reasons why the
property cannot or
are already
recycling, then they
will be removed from
the procedure.
If no recycling
presented a
‘yellow’ letter is
delivered
Three weeks of
early morning
monitoring
If no recycling
presented a ‘red’
letter is delivered
Three weeks of
early morning
monitoring
Details passed to
Area Enforcement
Officers to issue
FPN
24