Annex A
POLICING: BUILDING SAFER COMMUNITIES TOGETHER
APA Response—Overview
INTRODUCTION
1. The Association of Police Authorities
(APA) welcomes the opportunity presented by "Policing: Building
Safer Communities Together" to consider, with our communities,
the future shape of policing and the wider community safety agenda.
2. This submission represents the APA's
initial contribution to that debate. We look forward to a continuing
dialogue with Government, our communities, partner agencies and
stakeholders, including actively testing out some of the ideas
we have put forward.
REFLECTING COMMUNITIES'
VIEWS
3. The APA's contribution has been developed
in the light of consultation with all police authorities and other
APA members; discussions in each of the APA's five policy groups
and the APA Black and Minority Ethnic Members Network; a special
meeting of the APA Plenary (comprising representatives of all
police authorities); and discussion and agreement by Police Authority
Chairs and Vice-Chairs. Our response has also been shaped by the
views authorities have gathered from their communities.
4. Sections 2A to 2D of this submission
provide detailed comments on the four key areas identified in
the consultation paper. Section 3 reflects some of the many initiatives
and innovative approaches already being implemented by authorities
and forces on which we can build.
5. Uniquely, police authorities have initiated
a real local debate and dialogue on the Green Paper within their
communities. Police authorities have undertaken widespread consultation
locally, encompassing their workforces; local people; community,
voluntary and other interest groups; Crime and Disorder Reduction
Partnerships; Local Criminal Justice Boards; partner agencies;
local authorities and other stakeholders, using a variety of methods
from public meetings to e-discussions.
6. Section 4 details the consultation undertaken
by each authority and provides an objective and impartial summary
of the outcomes of that consultation. More detailed reports produced
by authorities are appended, as listed in Section 5. Although,
it is not possible to quantify fully the extent of consultation
undertaken, as section 4 and the appendices listed at section
5 show, authorities have engaged with some 100,000 people; 55,000
partners; and more than 400 groups locally.
7. Accordingly, this submission reflects
not just the position of police authorities, but also the views
of both the local communities which police authorities serve and
the many agencies with which they work.
MORE RESPONSIVE
LOCAL POLICING
8. The APA wants local policing services
which:
— have the full confidence and active
support of all our diverse communities;
— deliver effective, high quality policing,
responsive to the needs and priorities of local people and resourced
accordingly;
— are intolerant of racism and any
other form of discrimination whether within the workforce or in
service delivery;
— uphold the highest ethical and professional
standards within a modernised and fully integrated workforce;
and
— crucially, are openly responsible
and accountable to local people.
Accordingly, the APA supports many of the key
principles underlying the consultation paper.
9. The APA recognises Government's role
in setting the broad strategic direction for policing, underpinned
by common national standards. We therefore supported the introduction
of the National Policing Plan as a vehicle for bringing together
the Government's expectations of policing. We welcome the Green
Paper's recognition that a much more "bottom-up" approach
is needed to give local people a real say in shaping and delivering
safer communities.
10. If Government is genuine in its desire
to give local people a real say in how they are policed, there
needs to be a fundamental rebalancing of the current tripartite
arrangements to significantly reduce central control and reinvigorate
local accountability by ensuring that police authorities have
the freedom and flexibilities to pursue local policing which suits
their communities. This is at the core of our proposals for change.
INCREASING COMMUNITY
ENGAGEMENT
11. Strengthening communities' engagement
and giving them greater influence over policing is at the heart
of the Green Paper: our response actively embodies that engagement
in reflecting our communities' views on the future shape of policing.
12. We share the Government's aim of ensuring
that local people have access to the information they need to
have more involvement in local decisions and solutions within
the strategic context of community engagement and civic renewal.
13. Police authorities recognise the fundamental
importance of engaging effectively with communities and are already
working proactively to extend and improve the range of consultation
and engagement which they undertake. Considerable information
about police performance is now being made available to local
communities through a range of innovative and diverse methods
as detailed in Section 3.
14. The Home Office research "Involving
the public: the role of police authorities" found little
public knowledge of the work of police authorities. In many ways,
this is unsurprising given that people are generally less interested
in structures and organisational issues than in how satisfied
they are with the service they are receiving. However, the widespread
consultation undertaken on the Green Paper suggests a much greater
degree of confidence in what police authorities do and a more
positive view of their role than the research seemed to suggest.
And, importantly, police authorities are well-known by those exercising
a representational role on behalf of the public such as, advice
agencies; county, district, town or parish councillors; and MPs.
15. Nevertheless, police authorities are
committed to continuous improvement and recognise that more can
be done to provide information which is easy to understand and
access and which meets communities' desires for very local information
about what is happening in their neighbourhood; what is being
done to tackle it; and how they can help. But authorities are
fully aware that engagement is about more than providing information
and about securing active participation on the part of local people
in making their communities safer, as Section 3 shows. We look
forward to the learning which should emerge from the joint Home
Office/APA project, including the three Action Research pilot
sites and the work of the National Practitioner Panel, as a basis
for further developments. Indeed, the APA is currently developing
guidance for authorities and forces on community involvement in
police training, including design and evaluation of training,
as well as delivery.
16. The existing statutory provisions relating
to police authority consultation (Section 96, Police Act 1996)
are loosely framed and, whilst this gives a welcome flexibility,
we believe authorities now need a much clearer remit. From the
public's perspective, there is now a confusing patchwork of consultation
carried out by a variety of bodies and agencies, in addition to
police authorities, including forces themselves, Crime and Disorder
Reduction Partnerships (CDRPs), Local Strategic Partnerships (LSPs)
and Local Criminal Justice Boards (LCJBs) with little effective
co-ordination and joining up across the piece risking the inevitable
"consultation fatigue". We believe that the suggestion
in the Green Paper of a possible new duty on Basic Command Units
(BCUs) to consult with local people would only add to the confusion.
17. In our view, considerable benefits could
be gained by introducing a much clearer, more structured approach
to securing effective community involvement in policing and community
safety issues. Police authorities would welcome being given a
clear statutory remit to develop and co-ordinate implementation
of a community consultation and engagement strategy for the police
area. Such a duty would empower police authorities to ensure that
there are arrangements in place for effective and proactive engagement—in
the widest sense—with communities, at every level from the
local to the strategic and across different communities of interest.
A useful parallel is the power which local authorities have to
secure the well-being of their communities (Local Government Act
2003). This approach would both give police authorities more credibility
with communities, enhance their capacity to deliver and help secure
greater transparency and accountability below the strategic level
, as discussed in Section 2B.
We propose that: police authorities be given
clear statutory responsibility to develop, co-ordinate and secure
implementation of, a coherent community consultation and engagement
strategy at all levels and across all community interests within
the police area.
A MORE VISIBLE,
ACCESSIBLE SERVICE
TACKLING COMMUNITIES'
CONCERNS
18. Police authorities are fully seized
of the public's desire for a more visible policing presence and
have been proactive in responding by driving the introduction
of initiatives such as Community Beat Officers, Neighbourhood/Community
Policing Models and Local Policing Units/Teams. However, we share
the Government's concerns that despite higher than ever police
officer numbers, there is still a "reassurance gap"
and that fear of crime remains high even though the chances of
being a victim are at an all-time low. It must be recognised that
the apparent failure of increased police numbers to deliver that
reassurance is the result of the adoption of more intelligence-led
targeted policing which, whilst effective in solving crime, does
not provide the visibly reassuring presence that the public want
to see. Implementation of the National Intelligence Model (NIM)
could potentially compound this. The introduction of Police Community
Support Officers (PCSOs) has helped to respond to the public's
clearly articulated demands and authorities strongly support making
more effective use of specials, volunteers and the wider police
family as all contributing to this end.
19. Equally, the indications are that we
can have a considerable impact on reassurance through improving
the state of the local environment and more needs to be done to
hold partner agencies and CDRPs to account for delivering against
their responsibilities. If we are to provide both a highly visible
policing presence, including through the extended policy family,
and continue to improve performance in tackling crime, we need
to be able to marshal joint resources and the efforts of communities
and partners far more effectively.
20. Police authorities share the view that
there is a need to build from the bottom up by identifying and
tackling with communities the issues that most concern them at
neighbourhood or local level.
21. We suggest that the solution lies in
extending NIM to capture "community intelligence" generated
through engagement with communities and partner agencies such
as CDRPs, Drug Action Teams (DAT/DAATs) and Youth Offending Teams
(YOTs). This would ensure that the problems identified by communities
at a very local level are used to help inform NIM assessments;
tasking and co-ordination; and priorities for action.
22. Since NIM assessments will then generate
actions for CDRPs and other partner agencies, (such as improving
the visible appearance of the neighbourhood, drugs rehabilitation
or providing facilities for young people), it would also strengthen
the accountability of partner agencies for tackling issues which
fall within their responsibilities. Certainly, there is a pressing
need to find ways of ensuring that other partners represented
on CDRPs, such as health and probation services, play a fuller
part and commit at senior level to delivering shared outcomes.
We believe this approach could finally start to give practical
effect to the potentially very powerful statutory duty on all
responsible bodies to consider the crime and disorder implications
of everything they do (Section 17, Crime and Disorder Act 1998),
the benefits of which have yet to be fully realised.
We propose that: police authorities be given
a clear remit to drive the extension of NIM to embrace community
intelligence and engagement to ensure that the efforts of both
the police and other partners are directed at tackling community
safety priorities identified by communities at neighbourhood level
and that this include responsibility for assessing the impact
on communities of such engagement in delivering reassurance.
ACCOUNTABILITY
23. The APA strongly believes that local
accountability for policing services should continue to be the
bedrock of our system. Equally, we believe that there continues
to be a need for a strategic accountability and oversight body,
equivalent to the current police authority, comprising members
drawn from communities and which is responsible for securing the
provision of local policing services.
24. We have already made clear our very
strong objections to directly elected police authorities. In our
view, this would undermine the effectiveness of any strategic
oversight body, since there is no guarantee that those successful
in being elected would have the skills and abilities needed to
undertake the role. There is also a very real danger that this
would lead to the politicisation of policing and the possibility
of extremist groups targeting such elections to gain influence
over the police with disastrous consequences for securing much-needed
trust and confidence amongst minority ethnic communities. Moreover,
as long as police forces remain under the direction and control
of chief officers, directly elected members would find it difficult
to deliver against any election promises, which is likely to produce
further disillusionment and disengagement on the part of local
people. As the Green Paper recognises, police authorities have
made considerable strides in securing membership which reflects
the diversity of their communities: direct elections would pose
a real threat to that progress.
25. However, we recognise that current accountability
structures, whether at the strategic or CDRP level, lack transparency
and this needs to be addressed. In the case of police authorities
this is in part due to the traditional reluctance of authorities
to invest resources in "marketing" themselves when such
funds could be directed to improving frontline policing services.
We question whether any new strategic oversight body or Board
would necessarily be more visible, accountable or effective, without
investing significantly in their own profile—authorities'
current total expenditure on their own support averages around
0.5% of local policing budgets. However, we recognise that authorities
could do much to raise their own profile and make the public more
aware of the benefits of locally accountable oversight. In this
respect, the current statutory limitation on police authorities
to decide their own staffing levels is unhelpful and should be
removed. The APA will be working to support authorities in taking
this forward as part of our wider Improvement Programme.
26. Police authorities are, however, relatively
new bodies and we believe that much progress has been made over
a short period both in engaging with local communities and in
holding forces to account on their behalf. This is now being accelerated
by the APA's Police Authority Improvement Programme which has
the support and commitment of all authorities.
27. Police authorities see effective performance
monitoring and management as key to effectively holding the force
to account on behalf of local people. The Police Standards Unit
has given a welcome stimulus to the focus on performance management
which authorities were already trying to instil at local level.
Good progress is now being made and we welcome the additional
benefits which new tools such as i-Quanta, activity based costing
and the developing PPAF are bringing on stream. 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 police authority members
and staff "Can You Manage It?". Training has been delivered
both nationally and locally with over 400 members attending one
or more of the 40 training days held during 2003.
28. Accordingly, we believe that police
authorities have the knowledge, skills and systems in place to
undertake effective performance scrutiny and drive forward continuous
improvements. In effect, police authorities are the local equivalent
of the Police Standards Unit, accounting on the one hand to the
Home Office and on the other to local communities for police performance.
29. Indeed, we would suggest, that police
authorities are more advanced in performance monitoring and scrutiny
than many other local bodies and agencies. Uniquely, the work
of police authorities extends across both community safety and
criminal justice and through our links with CDRPs and Local Criminal
Justice Boards, we believe that police authorities can be instrumental
locally in securing effective joined up performance management
across the piece.
30. Accordingly, rather than creating a
new oversight body or Board, we believe that the answer lies instead
in strengthening the role of police authorities by articulating
more clearly within legislation their powers and duties for holding
chief officers to account on behalf of communities for police
performance. This ties in with our proposals for authorities to
have a remit to co-ordinate consultation on community safety issues.
The Northern Ireland legislation and experience provides a good
example on which we can draw.
31. In line with this, we agree with the
Government that the concept of "operational independence"
is now outmoded and that a move to "operational responsibility"
is appropriate and would accord with the practical reality which
exists in many areas.
We propose that: in line with the proposed shift
to "operational responsibility"", police authorities
should be given an explicit statutory remit to hold chief officers
to account on behalf of their communities and the role and responsibilities
of police authorities should be more clearly set out in legislation.
32. We agree that given the increasing emphasis
on BCUs as the core local policing delivery unit, it is important
that visible and appropriate arrangements are in place for oversight
and scrutiny at that level. However, it is disappointing that
the Green Paper fails to recognise that many authorities already
have, or are developing, structures for this purpose including,
for example, local policing/partnership boards.
33. We consider that BCU Commanders should
continue to be accountable to the chief constable but see merit
in exploring the scope for a range of different options to suit
local needs for more direct scrutiny of planning, performance
and community engagement at BCU level. We believe that this would
fit with our earlier proposals for a statutory remit on authorities
to secure effective community consultation and engagement at all
levels.
34. We also agree that there is a case for
strengthening oversight and accountability of local CDRPs, whose
performance, effectiveness, and indeed visibility to communities
is extremely variable. There is also a need to streamline the
range of local partnerships including YOTs and DATs/DAATs, and
to join up more effectively the work of CDRPs and Local Strategic
Partnerships. Increased transparency and accountability can be
achieved through a variety of means including tighter lines of
accountability to parent organisations; local multi-agency scrutiny
arrangements; and implementation of the co-ordinated community
engagement strategy we have proposed.
35. Similarly, we see scope for neighbourhood
panels to have a role in influencing policing at a very local
level where that works and meets local communities' needs. However,
we are aware that there are already many different bodies and
panels operating at neighbourhood level that could possibly play
a role and this view also comes across in authorities' local consultations
with communities. The Green Paper's recognition that there is
no single solution here is welcome, given the very different configurations
of communities and localities, both in terms of geography and
local government structures. The National Reassurance Project
could potentially point the way forward, engaging as it does with
local communities at ward level and an evaluation of the lessons
from the pilot areas should be used to help inform future developments.
36. We strongly believe that the answer,
whether at BCU, CDRP or more local level is to develop locally
based solutions. In our view, the imposition of a rigid statutory
framework for accountability mechanisms below the strategic level
is likely to prove counter-productive and simply add to bureaucracy.
OPERATIONAL EFFECTIVENESS
37. The APA agrees that it is sensible to
review regularly whether current force structures are fit for
the purpose of delivering efficient and effective policing services
which meet modern demands.
38. We recognise that there is a gap in
tackling serious, organised (level two) crime which has resulted
from the creation of the National Crime Squad (NCS) and the demise
of the Regional Crime Squads. But we are clear that recreating
Regional Squads is not the answer. Indeed, the Green Paper has
stimulated action by authorities who are already moving to explore
the possibilities for more effective, innovative approaches to
tackling cross-border crime. And indeed, there are already many
examples of longstanding good practice in place, such as the Midlands
Central Patrol Group, on which we can draw for solutions.
39. In our view, structures should be driven
both by operational needs and community identities. Alterations
to force boundaries do not solve the problem of cross-border crime,
since these issues will need to be addressed however the boundaries
are drawn. Instead the answer is to develop clear, effective strategies
for tackling the different types of serious, organised crime,
for example, human trafficking or credit card fraud.
40. The APA has no difficulties with the
concept of strategic forces as described in the Green Paper. However,
we have yet to see the evidence that the benefits to be gained
from any reconfiguration of the current pattern of police forces
would outweigh the very considerable disruption and costs, both
financial and in relation to communities' confidence and partnership
working, which would result from major restructuring at this time.
A full cost-benefit analysis of the implications of any restructuring
must be a pre-requisite for any further consideration. In particular,
the APA would strongly resist any structural change which weakened
local accountability for policing.
41. We do, however believe that there are
significant gains to be made through the development of specialist/lead
forces and greater strategic collaboration, and there are already
good examples of this happening in practice. We see no reason
why this need be confined to regional or geographic areas, but
would encourage strategic collaboration between any authorities
and forces where this best meets the needs of the organisations
and their communities.
42. Police authorities and forces need clear
strategies in place to tackle serious and organised crime. We
see benefits in the concept of a National Policing Agency to tackle
level three crime but would wish to ensure that there is appropriate
recognition at that level of the so-called "golden thread"
and the ripple effect of level three and two crime within local
communities. We consider that there should be a specific statutory
duty on police authorities and forces to collaborate to tackle
serious crime and to ensure that this is subject to appropriate
governance and oversight.
We propose that:
— police authorities be given a statutory
duty to establish effective collaborative arrangements with appropriate
governance structures to tackle serious, organised crime; and
— police authorities be given capacity
to develop collaborative approaches to workforce planning, recruitment,
training and development based on strategic assessments in support
of this approach.
Central Resources
43. The APA welcomes the proposed review
of the plethora of central bodies engaged in the business of setting
standards, monitoring, inspecting and auditing policing. We believe
that there is scope to streamline and reduce the considerable
burden which the various regimes place on authorities and forces.
In our view, the role of the centre should be one of enabling
and supporting rather than directing. We would also suggest that
there is scope to rationalise the different performance regimes
which apply across the different partnership arrangements.
MODERNISING THE
POLICE SERVICE
Earned Autonomy
44. The APA considers the concept of "earned
autonomy" inapplicable within a tripartite relationship where
the relative powers and responsibilities of each partner are properly
balanced. In practice, both recent legislative changes and central
control have undermined the proper balance of that relationship
and we have called for that to be reversed.
45. The APA considers that within the tripartite
relationship, police authorities have a degree of autonomy and
that autonomy should only be questioned where performance is less
than satisfactory. Nevertheless, we welcome the recognition that
performance would be enhanced if authorities had the sorts of
"freedoms and flexibilities" outlined in the consultation
paper. In our view, these should be available to all authorities,
unless there is evidence of poor performance. We do not support
the application of such an approach at BCU level, in line with
our view that direct funding of BCUs does not make sound organisational
or business sense. Moreover, we could not support any system whereby
poor performance resulted in penalisation of communities whose
needs were already, by definition, not being met.
Workforce Modernisation
46. The APA considers that this is one of
the most important aspects of the Green Paper, since it is only
through our people that we can deliver successful reform.
47. We welcome the moves which have already
been made towards a more modernised service but see scope for
more rapid and radical progress to be made, including through
a fully integrated workforce and a unified employment structure.
We believe that there should be common minimum standards and terms
and conditions of employment for all staff whether warranted or
non-warranted. We believe that this will also support the efforts,
to which we are wholeheartedly committed, of achieving a police
service which is fully representative of the communities it serves.
48. The APA has led the way in developing
the "People Matters" framework for effective HR planning
and development within police forces. We believe that there is
scope for a much more common and consistent approach to training
and career development for the wider police family, including
wardens and accredited staff. Police authorities would welcome
the opportunity to be given a lead role in developing this approach.
49. Authorities would also wish to have
greater freedom to appoint both overseas police officers and suitably
qualified non-police officers to senior positions within forces.
The current anomaly in the legislation, which means that authorities
have no statutory role in the appointment of senior police staff
to ACPO equivalent ranks, should be addressed.
50. Here, as elsewhere in our response,
we believe that the answers lie in giving authorities greater
scope to develop a "mixed economy" workforce which meets
local needs. We strongly believe that there is now a need to move
away from the current fixation on police officer numbers and that
collectively we must all proactively seek to encourage the public
to understand that policing is delivered by the whole police workforce.
We propose that: police authorities have lead
responsibility for ensuring the development of common standards
of training and career development for the wider police family.
CONSULTATION AND
ENGAGEMENT OUTCOMES
51. In launching the Green Paper at the
APA Annual Conference, the Home Secretary urged police authorities
and others to engage in widespread debate with local people and
partners on the proposals. Police authorities have risen to that
challenge. Despite the limited and inauspicious consultation period,
authorities have engaged widely with a range of local people,
community and voluntary groups and organisations, CDRPs, LCJBs,
other partner agencies and stakeholders including local councils
at all levels, local businesses and a whole host of minority and
other interest groups, as well as their own workforces, using
an extensive array of methods and approaches. As you would expect,
this has elicited a wide mix and range of views on most of the
issues raised in the Green Paper. However, the consultations have
informed and helped shape views of police authorities.
52. Section 4 of this submission provides
an objective and impartial summary of the consultation undertaken
by police authorities locally and the wide range of views and
opinions expressed. Many authorities have produced full reports
detailing the outcomes of local consultations and these are appended,
as listed at Section 5.
CONCLUSION
53. The APA welcomes the fact that, as Ministers
have repeatedly stated, the Green Paper represents very much the
start of an ongoing dialogue which will continue as proposals
are developed and refined and that there will be further consultation
in due course. In the interim, the APA and police authorities
intend to continue engaging with our communities and partners
to consider options for change, as well as contributing to the
ongoing debate.
February 2004
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