13. Memorandum submitted by
the Association of Police Authorities
INTRODUCTION
1. The Association of Police Authorities
(APA) represents all police authorities in England, Wales and
Northern Ireland, as well as the newly established British Transport
Police Authority[11].
The Service Authorities for the National Crime Squad and National
Criminal Intelligence Service are associate members.
2. The APA welcomes the opportunity to submit
evidence to the Home Affairs Committee. This has been produced
after consultation and discussions with member authorities.
GENERAL COMMENTS
3. The APA strongly supports the principles
underlying the Government's police reform agenda, particularly
the aims of making policing more responsive to the needs of local
people, whilst at the same time driving up standards of performance
across the country.
4. The police reform programme is an extensive
one encompassing not just the Police Reform Act 2002, which was
in itself wide-ranging, but also workforce modernisation, pensions
reform and other issues which are being tackled alongside legislative
change. This submission therefore focuses on those issues on which
the Committee has specifically requested views and follows the
order set out in the terms of reference.
NATIONAL POLICING
PLAN
5. The APA welcomed the original proposals
for a National Policing Plan as a vehicle for bringing together
in one place the Government's strategic expectations and key national
priorities for the service. The two such plans produced so far,
whilst evolutionary, have yet to fully realise that strategic
clarity and focus. This all-encompassing approach has undoubtedly
impacted on the extent to which police authorities have been able
to reflect and tackle local policing priorities.
6. The APA is keen to see the next national
plan strike a better balance between setting a clear strategic
direction for the service based on a few key national priorities
and giving scope for authorities and forces to tackle the issues
which concern local communities. We welcome the indications that
this is the Government's direction of travel. We also strongly
support the need for the plan to embrace the wider community safety
agenda and to directly address the contribution which other agencies
and partners make to securing safer communities.
7. Police authorities have been producing
local annual plans since 1995 and have long recognised that it
is crucial to align planning and budgeting processes, so as to
be clear about what can be delivered with the resources available.
The APA has been a strong proponent of the development of activity
based costing (ABC) data, and the availability of such data for
all forces in England and Wales for the first time from 2003-04
will be a further welcome step in helping to achieve properly
costed local plans.
8. Likewise, the APA has strongly pressed
for the National Policing Plan to be properly costed so that the
costs of all the expectations set out in the plan are clear—and
it is clear what the funding provided by Government will deliver.
We recognise that the statutory requirement for the National Plan
to be published by 30 November and the traditional timing of the
provisional police settlement in early December presents a challenge
in this respect but this is not, in our view, insurmountable.
NATIONAL STANDARDS/PRIORITIES
AND LOCAL
DECISION-MAKING
9. The APA recognises the Government's role
in setting a broad strategic framework for policing and establishing,
with tripartite partners, national minimum standards which everyone,
wherever they live, can expect to receive. But national standards
should not inhibit the capacity of authorities and forces to provide
policing services which are tailored to the diverse needs of their
local communities.
10. There is no doubt that the degree of
central influence and control over policing has increased over
the years, culminating in the Police Reform Act 2002. This has
been accompanied by a performance framework which seeks to direct
policing through a regime of national indicators, targets and
centrally driven initiatives backed up by monitoring and inspection,
and use of ring-fenced funding. In turn, this has constrained
the extent to which authorities and forces are able to focus on,
and direct resources to, local priorities.
11. There is a need to recognise that truly
responsive local policing services can only be achieved if there
is scope to focus on issues which local people say matter. We
believe there now needs to be a fundamental shift away from central
direction in favour of local flexibility. Accordingly, the APA
has argued strongly that the developing Policing Performance Assessment
Framework (PPAF) must reflect performance against local policing
priorities, as well as national performance measures. The APA
has led work in this respect and as a first step has issued guidance
to help police authorities ensure that local policing priorities
are set in a way which genuinely reflects the concerns of local
communities, whilst at the same time being sufficiently robust
for PPAF purposes.
ACCOUNTABILITY MECHANISMS
FOR POLICING
AND THE
FUTURE OF
THE TRIPARTITE
STRUCTURE
12. The Committee will be aware from the
previous inquiry on police reform of the APA's concerns that certain
aspects of the police reform bill, as originally introduced, would
result in increased centralisation of control over policing, potentially
undermining the balance of the tripartite relationship. The final
Police Reform Act 2002, reflected a number of modifications to
the Government's proposals pressed for by the APA, which allayed
some of those concerns.
13. Amongst other things, the APA highlighted
the potential for the additional powers in Part 3 of the 2002
Act around the suspension of chief officers to lead to tension
and difficulties within the tripartite structure. We would suggest
that there is now a need to review the arrangements and protocols
put in place as part of the legislation to ensure that the focus
is on ensuring that local people receive the standards of policing
they rightly expect.
14. The APA strongly believes that "policing
by consent" is the fundamental cornerstone of our policing
system and, at the heart of this, is a locally accountable policing
service. The reaffirmation in the Home Office Strategic Plan 2004-08[12]
that any future reforms will not damage the principle of the tripartite
approach is, therefore, welcome.
15. The Government's Green Paper "Policing:
Building Safer Communities Together"[13]
put forward options for accountability arrangements at neighbourhood,
BCU and force level. At the force level this included the possibility
of reconfigured or directly-elected police authorities/boards.
The APA's response to the Green Paper is summarised in the overview
attached at Annex A[14].
We have also contributed actively to the dialogue on these issues
as a key part of the analytical project jointly undertaken by
the Prime Minister's Strategy Unit and Home Office.
16. As we have made clear, we consider that
a strategic oversight body at force level, equivalent to the current
police authority, is essential. Whilst any such body should be
made up of local people with effective powers to hold the police
accountable on behalf of their communities, we are fundamentally
opposed to such bodies being directly elected for the reasons
given in Annex A.
17. However, there are a number of areas
where we consider that there is scope to strengthen and enhance
accountability at the force level, including support for the proposal
to move away from the concept of operational independence in favour
of operational responsibility.
18. Police authorities, through their strategic
scrutiny and oversight role are able to ensure a coherent approach
across the whole force area. However, the APA and authorities
support increased transparency and accountability of policing
services to local people at all levels. Authorities are well-seized
of the need to ensure effective accountability arrangements at
sub-force level. Most now have in place arrangements for allocating
link or lead members at BCU level and in some cases below that,
with members linked to local policing teams or units.
19. Police authorities, through their membership,
already have vital links with local government but we recognise
that there is scope to strengthen local authority engagement in
policing. However, we would suggest that rather than introduce
complex new structures the aim should be to build on what is there
and ensure that any new arrangements are easy for communities
to understand. Accordingly, the APA has advocated approaches based
on models already being put in place by some authorities such
as BCU partnership boards, similar to the Northern Ireland model,
whereby police authorities involve local councils, other partners,
voluntary agencies etc in oversight and scrutiny of performance
at BCU level.
20. Police authorities have welcomed their
statutory membership of local Crime and Disorder Reduction Partnerships
(CDRPs) as a significant step forward. CDRPs have undoubtedly
played a major part in enhancing multi-agency working although
performance, whilst improving, remains variable across the country.
As currently constituted, CDRPs lack transparency and accountability
and consideration needs to be given to how they might best be
engaged as part of any sub-force accountability structures.
21. The APA welcomes the development of
LCJBs which have begun to have a real impact in bringing a more
joined-up approach to criminal justice. The work of LCJBs is very
much centrally driven by the National Criminal Justice Board (NCJB)
and the Office of Criminal Justice Reform. However, there remains
an unresolved issue of how this fits with policing as a locally
accountable service—LCJBs meet in private, and there are
no clear mechanisms for scrutiny or oversight at local level.
Given that there are plans for LCJBs to hold budgets and commission
local services, this needs to be addressed as part of any consideration
of these issues.
A POLICE PERFORMANCE
CULTURE
22. The APA would suggest that there is
evidence that a performance culture is beginning to be embedded
in the police service. This is due to a sustained focus on performance
by police authorities and chief officers, as well as the Home
Office, and the efforts of the Police Standards Unit.
23. The APA has long recognised the importance
of focusing on police performance and has worked hard to help
ensure police authorities are equipped to carry out their responsibilities
for managing and monitoring police performance more effectively.
Since it was set up in 1997, the APA has had in place a policy
group dedicated to police performance issues which brings together
lead members from authorities to share and disseminate good practice.
In 2002, the group produced the APA's Performance Management Policy
Framework setting out the core elements of an effective police
authority approach to performance management.
24. The importance we attach to this area
is underlined by the significant investment made by the APA in
the development and delivery of a specially tailored, modular
training programme for authorities: "Can You Manage It?"
The programme is designed to equip members and staff with the
knowledge and expertise to effectively monitor and manage police
performance: to date, over 45 modules have been delivered nationally
and regionally attended by some 400 members and staff. Accordingly,
police authorities are now better equipped than ever to undertake
effective performance scrutiny and drive forward continuous improvement.
25. The Police Standards Unit (PSU) has
also undoubtedly played an important role in helping inculcate
a performance culture through two key areas of work: the Policing
Performance Assessment Framework (PPAF) and i-Quanta. PPAF is
a significant step towards a more rounded assessment of police
performance than has been previous available. Although led by
PSU, the way in which PPAF has been developed is an example of
tripartite working and ownership at its best. Another PSU product,
i-Quanta has proved a valuable tool in providing police authorities
with direct access to comparative performance data at force, BCU
and CDRP level updated on a monthly basis.
26. Considerable progress has been made
and performance is rightly seen as a key issue by police authorities,
chief officers and BCU Commanders. However, there is still much
to do before it can be said that the performance culture is embedded
at all levels of the service. Crucial to this is having in place
an effective PDR system which links strategic aims and objectives
to the daily work of all officers and staff.
THE ROLE
OF THE
POLICE STANDARDS
UNIT AND
NCPE
Police Standards Unit
27. The PSU has undoubtedly given significant
impetus to performance issues and has made a considerable impact
in a short space of time in particular in relation to:
— Performance measurement and data:
the considerable value PSU has added in respect of the development
of PPAF and i-Quanta has already been acknowledged above.
— Engagement with "target"
forces: the APA welcomed the adoption earlier this year of the
"Stages of Engagement" framework agreed by all tripartite
partners which provides clarity around when PSU will become involved
with particular forces and look forward to the finalisation and
issue of a "disengagement" framework. The recent commitment
given to the APA by the Director of PSU that the police authority
will be more fully involved from the outset in all such future
engagements is welcome.
— Operational Support: the PSU has
been at the forefront in promoting the development of key initiatives,
such as Automatic Number Plate Recognition (ANPR), which have
undoubtedly been of considerable benefit to the service. Similarly,
the current PSU-led alcohol enforcement campaign is an important
and welcome initiative.
28. Over time greater clarity has emerged
around the respective roles of the PSU and HMIC and these are
now generally understood. However, we remain concerned about the
level of monitoring, inspection and auditing which is currently
undertaken and the number of those engaged in such roles centrally
whether in PSU, the Home Office, HMIC, or the Audit Commission.
There is undoubtedly scope to streamline and reduce radically
the extent of such activity. The aim should, in our view, be to
help ensure a sustainable self-improvement capacity within police
authorities and forces. To this end, as part of the APA Improvement
Programme, we have developed the "Police Authority Assessment
and Improvement Framework"- a self-assessment tool to
help authorities ensure continuous improvement in how they operate
and enable them to hold forces to account more effectively.
Role of the NCPE
29. The NCPE has started to produce codes
and guidance, perhaps more slowly than expected, but it has taken
time to establish itself and to set in place clear processes of
commissioning, consultation and implementation.
30. The NCPE needs to work closely with
ACPO, the APA and others to ensure that the codes and guidance
it issues can be implemented effectively. This includes ensuring
that products are issued at suitable intervals, accompanied by
the necessary training for officers and staff, in line with the
capacity of the service to absorb new requirements.
31. As part of Centrex, NCPE is currently
subject to tripartite governance. When NCPE is fully effective
it has the potential to standardise a great deal of police procedure
and practices, which will have a significant impact on the way
our communities are policed. It is right therefore that police
authorities, as communities' representatives, have an input into
the management and outcomes of that work.
32. The APA looks forward to sight of the
Government's detailed proposals for a new National Improvement
Agency but it would seem logical for the work undertaken by NCPE
to form part of the wider role of any such new agency. Likewise,
it is crucial that this new body has tripartite governance and
ownership if it is to prove successful.
IMPROVED USE
OF SCIENCE
AND TECHNOLOGY
33. Science and technology, if effectively
harnessed and used, has a considerable role to play in supporting
the agenda for reform and modernisation of the police and the
wider CJS. For example ANPR, expansion of the DNA database and
the work on forensics is already producing significant benefits.
Often the biggest wins can only be gained by significant medium-term
investment in research and development. It is therefore crucial
that Government finds the necessary resources for scientific research
and development to support the police service, including in areas
where there is no clear "quick win". Given this, and
put into the context of the rate of change affecting policing
over the past 10 years, convergence towards ISS4PS, and the greater
emphasis on the need for forces to share information and intelligence
with criminal justice partners and with each other, as recommended
by Bichard, there is a clear need to have in place sustainable
and progressive resourcing plans. Crucially, there is a need to
have clear medium to long term capital programmes both at national
and police authority level, to ensure the sustained investment
needed to reap real benefits.
GOVERNMENT'S
RESPONSE TO
O'DOWD REPORT
ON POLICE
BUREAUCRACY
34. Much good work has been done to implement
the recommendations of the O'Dowd report. As well as actively
contributing to the steering group set up to oversee implementation,
the APA has established a bureaucracy lead member network, so
that each police authority has a member who is a bureaucracy reduction
champion and works with the force in this area.
35. There remains a great deal to do, notably
in getting the best out of technology to reduce bureaucracy, for
example making best use of mobile data and automatic facial recognition
technology. And there needs to be constant vigilance to reduce
new post-O'Dowd bureaucracy burdens.
36. The APA remains committed to playing
a full and active part in this area, both through our lead member
network and involvement in the bureaucracy steering group as above,
but also more generally by taking a lead in ensuring that resources
are used as efficiently as possible. Police authorities have been
highly successful in meeting and exceeding annual 2% efficiency
targets in each of the last five years.
POLICE TRAINING
37. The APA welcomes the proposed changes
to the probationer training regime which will involve authorities
and forces taking responsibility for delivery of their own probationer
training. However, there are continuing concerns about the lack
of information on the resourcing of the revised probationer programme,
and how funding will be provided to police authorities to deliver
probationer training locally rather than to Centrex, which up
until now has trained probationers outside London. The move from
central to local delivery is a major change which needs to be
rolled out over time, with lessons from pilot forces learned by
the rest.
38. We are also very supportive of the development
of training programmes at other levels within the police service.
In particular the Core Leadership Development Programme (CLDP),
for post probationary constables and police staff, should prove
an essential tool in further developing this group. However, the
development of this programme, and a number of others, may be
affected by cuts in Government funding to Centrex. We are concerned
about the likely impact of these reductions in funding on training
and development across the service.
WORKFORCE MODERNISATION/REFORM
OF POLICE
PAY, CONDITIONS
AND WORKING
PRACTICES
39. Workforce modernisation is in our view
one of the most important aspects of the reform agenda: it is
only through people that successful reform can be delivered and
high quality responsive services can be provided to our communities.
Pay and conditions
40. The APA was, of course, involved in
negotiating and a key party to the PNB agreement which introduced
Special Priority Payments (SPPs), Competence Related Threshold
payments (CRTPs), the new approach to ill-health retirements and
the overtime targets. While SPPs have been controversial and many
officers feel they are unfair, they have helped authorities to
deal with recruitment and retention problems in certain areas
of the force, and reward officers in front-line, "24/7"
roles.
41. In many forces the large majority of
eligible officers receive CRTPs. However, It is not clear that
the aim of the agreement—to help drive up performance has
been met in practice. Performance pay—as well as rewarding
those taking on the most demanding challenges—has been part
of the recent pay agreements with Superintendents and chief officers.
It is too early to say what impact performance pay has had in
the superintending ranks and it is only now being put in place
for chief officers. Police authorities will have a key role in
monitoring the impact at local level, and will have particular
responsibilities in relation to the award of bonuses to chief
officers under the agreed scheme.
42. The APA has strongly supported appraisals
for chief officers but we have concerns about the current arrangements
under which Her Majesty's Inspectorate of Constabulary (HMIC)
has primary responsibility for appraisal, with the chair of the
police authority providing input only. Thus police authorities
are responsible for appointing and removing chief constables,
but not for appraisal, despite their role in overseeing and scrutinising
force performance. The APA considers that the balance should be
reversed so that police authorities have the primary role in the
appraisal of chief officers, supported by professional input from
HMIC.
43. The new approach to ill-health retirement,
agreed with the Police Federation, has been very helpful in bringing
down what were in some areas unacceptably high rates of ill-health
retirement and has helped officers to continue to use their very
valuable skills with the police service. But the combination of
a number of Government policy priorities, namely the drive to
reduce ill-health retirements, the drive to put police staff in
police officer posts where appropriate, and the drive to increase
and then maintain police officer numbers, can be in conflict and
create difficulties for police forces and authorities. In particular,
the requirement to keep police officer numbers at a certain level
to access the Government's Crime Fighting Fund can mean that forces
keep officers in posts which might otherwise be civilianised.
44. We support the drive to reduce overtime,
both on cost grounds and to improve officers' work-life balance.
But we note that, according to HMIC, a number of forces are, behind
schedule in their attempts to meet the target to reduce overtime
by 15% in the three years to 2006-07. The APA produced guidance
for police authorities setting out how they should scrutinise
and monitor force attempts to meet the agreed targets and authorities
will be challenging forces' management teams to ensure that these
three-year targets are met.
Other developments
45. Whilst considerable moves towards modernisation
have already been made, we believe that there is scope for more
rapid and radical progress. A greater emphasis on qualifications
and accreditation together with new improved career pathways,
including multiple points of entry for officers are key to a professional
and modernised police service.
46. We strongly support an integrated workforce
without artificial divisions. We welcome police staff taking on
new and important roles within forces and welcome the recent HMIC
thematic report on modernisation. We now need to ensure its recommendations
are properly implemented. In doing so, however, it is crucial
that a proper supporting infrastructure is put in place and appropriate
investment made in training, development and career structures
for police staff.
47. Cultural and other issues militating
against modernisation which need to be addressed, include:
— the different legal status of police
officers as against employees
— single point of entry for police
officers
— the hierarchical rank structure
— the expectation that officers will
have a 30 year career in the service
— police regulations and the cumbersome
process for changing them
— Different sets of pay and conditions
and different negotiating machineries.
48. We also want to see the development
of common minimum standards for all those within the wider police
family and believe that authorities have a key role to play here.
49. A major barrier to faster development
of the integrated workforce is the political focus on police officer
numbers, and in particular the operation of the Crime Fighting
Fund, as discussed above. Government's recent announcements about
the maintenance of police officer numbers and an increase in 20,000
PCSOs do not make it clear how the necessary funding will be provided.
The APA wishes to see a situation where authorities have the freedom
and capacity to decide the right mix of staff to develop a workforce
which meets local communities' policing needs.
THE USE
OF COMMUNITY
SUPPORT OFFICERS
50. The introduction of police community
support officers (PCSOs) and similar posts has proved to be one
of the most pioneering and innovative aspects of the Police Reform
Act 2002. The Committee may recall that the APA had reservations
about certain aspects of the proposals, namely the absence of
any requirement on chief officers to seek approval from the police
authority before introducing PCSOs in an area and the proposals
to give PCSOs powers of detention.
51. During the passage of the Police Reform
Act we rightly emphasised the importance of consulting communities
before introducing PCSOs to an area, since different areas have
very different policing needs. Whilst we did not secure a statutory
role for the police authority in agreeing to the deployment of
PCSOs, the need for forces to have police authority approval in
order to receive ring-fenced Home Office funding means that, in
practice, authorities have an input into most decisions to recruit
PCSOs. All the indications to date are that Police Community Support
Officers (PCSOs) are extremely popular with local communities,
and local evaluations of their effectiveness have been positive.
This is a success story.
52. But some caveats:
— No proper national evaluation of
the impact of PCSOs has, as yet been undertaken. We look forward
to seeing the outcomes of the proposed Home Office evaluation
and learning lessons about optimum deployment of PCSOs. In particular,
it will be interesting to see whether there is a difference in
the effectiveness of PCSOs between urban and rural areas and whether,
for example, the distance from back-up resources in rural areas
may impact on the practicality of deployment. The extent to which
forces' have capacity to implement a dedicated beat manager policy
to supervise PCSOs may also be a limiting factor. We will be particularly
interested to see the findings in respect of the use by PCSOs
of powers to detain which is being trialled in a few areas and,
pending this, remain circumspect about extending further the powers
available to PCSOs. PCSOs need to be distinct from police officers,
fulfilling different roles and functions. They provide the kind
of visible policing communities like and it is to be hoped will
have an impact in terms of reassurance and reducing the fear of
crime. But it is important that the real costs and benefits are
properly assessed. Although less costly in pay terms than police
officers, PCSOs are not a cheap option and the costs of uniform,
training and the proper management and supervision needed for
PCSOs to be able to deliver effectively all need to be factored
into the equation.
— The initial time-limited ring-fenced
central funding for PCSOs has inhibited authorities from integrating
PCSOs into long-term policing strategies, presenting difficult
choices about whether to retain or increase PCSO numbers. We therefore
await with interest details of the proposed "Neighbourhood
Policing Fund" and how the Government is going to deliver
on its promise to provide 20,000 additional PCSOs. It is not yet
clear how the figure of 20,000 was arrived at—especially
given the lack of any national evaluation. It is to be hoped,
however, that any funding arrangements provide the flexibility
for local police authorities, along with the chief officer team,
to decide what the appropriate mix of police officers, PCSOs and
other police staff should be.
THE GOVERNMENT'S
GREEN PAPER
53. The APA welcomed many aspects of the
Government's Green Paper "Building Safer Communities Together"
with its emphasis on more responsive local policing as will be
seen from the overview of our response at Annex A. This response
reflected not just the views of police authorities themselves
but the outcomes of widespread consultations which authorities
undertook with local communities, partners and other agencies.
We look forward to seeing the results of the Green Paper consultation
and the public questionnaire which it is understood the Home Office
plans to publish in September.
Community advocates
54. The APA fully agrees with the premise
in the Green Paper that the public's concerns should be dealt
with effectively and appropriately—the question is how?
55. There is a strong feeling that there
is already a plethora of individuals and organisations who carry
out the sort of role envisaged for community advocates, including
local councillors, police authority members, Race Equality Councils,
Victim Support, Citizens Advice Bureau, Independent Advisory Groups,
voluntary agencies etc. We consider that there is a need to build
on what is already there including, for example, by Government
providing a source of sustained funding for existing advocacy
organisations, rather than creating a new role. The latter may
simply add another layer between communities and the police and
raises significant questions about the role and accountability
of such advocates. The best solution may be to give more publicity
to the existing arrangements so that the public can understand
how they can complain about individuals or the service received.
Neighbourhood panels
56. The APA sees value in engaging local
communities in policing at the "neighbourhood" level,
whilst recognising that the nature of "neighbourhood"
will vary from area to area, whether rural or urban and that there
are communities of faith, interest etc, as well as geography.
We strongly support an approach which builds on the panels, community
groups, and neighbourhood management teams already in place. We
welcome the recognition that prescription would be inappropriate
and that a "one size fits all" approach will simply
not work. We await with interest further details of the Government's
proposals for communities to have power to "trigger"
immediate action by the police or other agencies in relation to
issues of local concern. We would be concerned, however, to ensure
that this did not lead to local policing agendas driven by those
who are most vocal or able to articulate their concerns, at the
expense of equity of service to all the diverse communities in
an area.
Race and diversity
57. The APA nationally, and police authorities
locally, want to see a police service which fully reflects and
fully protects all of our diverse communities. Police authorities
are leading by example: over 9% of police authority members are
from Black and Minority Ethnic Communities and just under 30%
are women. Whilst much progress has been made in recent years
there is still a long way to go to before we achieve a truly representative
workforce whether in terms of black and minority ethnic officers
and staff or other groups currently under-represented in the service,
including women, gay/lesbian and disabled people. Attracting and
keeping the brightest and ablest people to serve whether as officers,
staff, specials or volunteers, should, in our view, be a top priority
in any reform programme.
58. As the bridge between local people and
forces, police authorities have a crucial role to play in building
trust and confidence in policing. The APA and police authorities
are determined to eradicate racism and discrimination of any sort
whether within the workforce and in the delivery of policing services.
Black and minority ethnic communities and other minority groups
need to be confident that they, like all our communities, will
receive high quality policing, responsive and sensitive to their
diverse needs.
CONCLUSION
59. The Police Reform Act 2002 was a complex
piece of legislation with far-reaching implications for many aspects
of policing. Two years on some parts are working well and can
be developed further; others need more time to bed in, whilst
others have proved more difficult to operate in practice. The
Committee's inquiry presents a useful opportunity to take stock
before further fundamental changes are introduced.
60. The APA hopes the above is helpful but
would be happy to elaborate or provide any further information
which may assist the Committee's deliberations.
1 August 2004
11 The British Transport Police Authority came into
being on 1 July 2004-its predecessor, the British Transport Police
Committee was an associate member of the APA. Back
12
Confident Communities in a Secure Britain, CM 2867, July
2004. Back
13
Home Office, November 2003. Back
14
A copy of the full response (106 pages) is available, if it would
be helpful. Back
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