My dozen or so cats require at least five litter pans, even though
they are completely free to come and go as they please.  Some of them
haven't been outside in two weeks, a few since it started getting cold
in November.  If I remove the litter pans, and it's cold or raining,
one uses my bed, others use papers on my desk (with or without pushing
them to the floor first), and yet others just use the carpet or
baskets of dirty clothes and towels.  A couple of them prefer the
outdoors even in bad weather.

T.E.D. (tdavis@gearbox.maem.umr.edu)
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It is a question of time, and the cat. None of mine have ever needed a
litter tray except when they are either ill, or the weather is
extreme. Even in very bad weather they would rather go out an use a
litter tray in the shed than do it indoors. Cats hate to foul their
own dens, and indoors is their den as far as they are concerned.

One thing though, I've found that if you have to keep a cat indoors
because it is ill, it is best to start off using garden soil rather
than the commercial litters, gradually over a week mixing more of the
commercial litter in until you effect the change. I've watched rescue
cats walk around in obvious discomfort because they would not use the
litter provided in the shelter. My local vet now buys sterilized
top-soil (used in greenhouses) in very large bags to cope with any cat
who dislikes commercial litters.