Select Committee on Office of the Deputy Prime Minister: Housing, Planning, Local Government and the Regions Written Evidence

Memorandum by the Association of Chief Police Officers (ACPO) (RG 75)


  1.1  The Association of Chief Police Officers (ACPO) was set up to undertake work on behalf of the Service as whole, rather than in each force separately. ACPO co-ordinates consultation with the 48 Home Office forces of England, Wales and Northern Ireland to provide a service response to national issues and can offer the authoritative service "voice" on all aspects of policing. ACPO provides professional advice to government, police authorities and other agencies and individuals.

  ACPO develops policies, manuals of guidance and memoranda of understanding for the forces to use public resources to best effect.

  ACPO is not a staff association; this function is performed by the Chief Police Officers Staff Association CPOSA.

  1.2  In producing this memorandum all forces were invited to respond on the terms of reference; a total of 15 responses were received (34%) and their views are summarised under each of the six key issues set out in the ODPM consultation.

  1.3  It is appropriate that the service is given the opportunity to contribute to the debate in view of the potential impact of regional Government on current and proposed policing structures.


  2.1  The devolution of decision making and accountability to a more local level is welcomed. Connection with and accountability to communities and locally based partners is fundamentally important to the delivery of policing at all levels and to the achievement of policing outcomes in terms of reassurance, prevention, detection and bringing offenders to justice. Policing is delivered at neighbourhood (parish/ward), basic command unit (district) and strategic (force/county) level.

  2.2  There is an inherent conflict between the current system of centrally driven priorities and the need to reflect local issues when determining organisational priorities. Decision making and accountability at the regional level has the potential to increase this strain further as there are significant concerns that regional level does not have the necessary democratic structures to support it. Clearly there are benefits for all Whitehall departments to apply a "joined up" approach to developing new structures and a shared vision. The community safety plan incorporating the national policing plan is an example of this emerging approach.

  2.3  The relationship between the regional and sub-regional structures is critical in terms of accountability, resource allocation and the ability to set local targets and priorities at a local level. In order for arrangements at a regional and sub-regional level to be effective it is imperative that flexibilities and freedoms are granted by central government to allow local priorities and needs to be met and delivered by existing partnership working arrangements with the Crime and Disorder Reduction Partnerships (CDRP), Local Strategic Partnerships (LSP) and in turn, their relationship with the Local Area Agreements (LAA) that are currently being piloted.

  2.4  A further consideration for the police service is the outcome and final decisions made around HMIC review of protective services "Closing the Gap" and Force restructuring. Policing issues transcend boundaries and tiers; it is a fundamental principal for chief officers that resources can be deployed at their discretion in support of national, local and neighbourhood level priorities as determined by intelligence assessments.

  2.5  There is a real tension between the desire to provide an increasingly personalised service directed towards genuine local priorities set against the need for each agency to deliver against Governmental priorities expressed within the Public Service Agreements and the mass of related targets and expectations that flow from them.

  2.6  For example, the ODPM's 2005 consultation document "Securing better outcomes: developing a new performance framework" emphasises the collaborative delivery of local public services in a way that is helpfully consonant with neighbourhood policing. However, this highlights LAA (sitting at County/Unitary level) as the relevant vehicle for the production and monitoring of shared targets and outcomes. It is not yet clear how, or how well, priorities identified at the neighbourhood level of granularity will survive or be influential when aggregated to the level of LAA.

  2.7  There is a need to move beyond status quo for public services as articulated by the ODPM consultation document's description of the current performance framework for councils, which: "fosters compliance rather than innovation, with a greater focus on accountability to central government rather than to local people . . . is increasingly rigid, complex, process heavy and resource hungry . . . [and] focuses on extremes of performance."


  3.1  There is some attraction in the devolution of powers from a regional level to a county level. In particular powers to direct resources and funding could increase the focus on local issues, and potentially facilitate faster decision-making and implementation of change. However, it could potentially increase competition for finite available funding, creating conflict in terms of local priorities and aims which would not be conducive to partnership working. The issue of devolution of powers from regional to a local level opens up a debate whether local, regional, or even central priorities take precedence.

  3.2  The level and degree of the potential devolution will depend upon the nature and type of powers that are devolved. In principle, such an approach supports the emphasis on local public service delivery and localism. It serves to reinforce the opportunities for timely and efficient delivery on local issues, enhance and strengthen partnership working and delivery on community safety issues. It further provides tangible support to the concept of empowering communities and enabling them to influence levers of power to hold people to account. It effectively places the citizen at centre stage.

  3.3  There is a need to challenge the presumption of competence in delivery at the local level, as evidenced by variance in the consistency and effectiveness of CDRP; one should questions an assumption that local government is perfectly able to take on devolved powers and the challenges associated with such powers.

  Simplification of existing arrangements should be balanced against the commensurate management investment to secure consistency, corporacy and curbing unilateral action.

  3.4  At the sub-regional level, future local government reform will have a considerable part to play. The introduction of Local Area Agreements (LAA) in every local authority area provides a mechanism through which appropriate levels of accountability for local decision making, allocation and use of funding and performance attainment against agreed standards and priorities can be assessed. To support this, focus needs to be given to the development and delivery of an LLA performance management framework. Such a framework is still required in some regions that are currently piloting this concept.

  3.5  It is clear that the implementation of devolved decision-making is a goal shared by the Government's public service reform programme and the public services alike.

  3.6  Truly citizen focussed policing is intrinsically linked to active citizen engagement and devolution of powers from the regional to more local level has potential benefits. However the economic and service benefits of co-ordinating and managing the delivery of some policing services at a regional and wider than regional level should not be lost and underpin the government's current plans for the restructuring of policing.

  3.7  The principle of subsidiarity should apply, with relevant powers devolved to the lowest appropriate level, together with trust in operational leadership. Any resulting governance arrangement should be recognisable to the public, to maintain their engagement and confidence. According to recent MORI research in one county force (Cumbria), "neighbourhood" and "county" have the strongest resonance with members of the public. Another MORI survey within West Mercia showed a lack of public support for "regional" government, albeit in a policing context.


  4.1  The co-terminosity of local policing units with those of partners, particularly local authorities, supports effective partnership working and should be prioritised. The current two tier system of local Government complicates issues. This complexity is likely to intensify with the increasing influence of Local Strategic Partnerships (LSP) which develop and manage local sustainable community strategies. There is no mechanism for managing poor performance by CDRP/LSP.

  4.2  A move to regional government accompanied by unitary authorities at the local level should streamline the process for management of CDRP partnerships and thereby improve performance. Regional government would also offer greater scope for co-ordination of activities between partnerships and unitary authorities.

  4.3  Whilst we are enthusiastic about LAA and the benefits they bring, we are anxious about the governance and local accountability of these structures. The outcome of evaluation of the LAA process is needed to provide an informed response to this question.

  4.4  The clearest route through the thicket of delivering national priorities while also localising public services is for LAA to consist of a very slim set of PSA-derived outcomes with accountability for their attainment residing at the regional level. This approach would provide the scope for more "granular" governance structures to have regard to these outcomes, but also to pursue authentically local priorities.

  4.5  There may need to be a very clear delineation between a slim set of central expectations monitored at the regional level or above, set against a rationalised regime of local performance monitoring and management rebalanced towards local priorities.

  4.6  It seems that monitoring, management and target-setting regimes have evolved in a relatively uncoordinated way that militates against effective service delivery in pursuit of clear national targets and well-defined local priorities.

  4.7  The police service is subject to a high degree of thematic or geographic oversight. For example, Basic Command Unit (BCU) commanders are required to operate within a preponderance of accountabilities and potentially conflicting priorities established by the following:

    —  GO targets for CDRP contributions to Public Service Agreement targets.
    —  (Home Office) Police Partnership Support Unit monitoring and/or intervention.
    —  (Home Office) Police Standards Unit monitoring and/or intervention.
    —  Maintaining performance against a wide range of PPAF Statutory Performance Indicators.
    —  OCJR Performance assessment and intervention.
    —  LCJB targets and processes.
    —  Local Policing Plan targets.
    —  Force and BCU priorities as identified by NIM and performance analysis.
    —  Efficiency targets.
    —  Meeting floor requirements for ring-fenced funding streams.
    —  Local Public Service Agreements.
    —  Outputs from Local Strategic Partnerships eg Community Strategies.
    —  Crime and Disorder Reduction Strategy and Implementation plans with associated targets and three-year longevity.
    —  Local Probation Plans.
    —  Drug and Alcohol Action Team plans.
    —  Local Youth Justice Plans.
    —  Local Youth Service Plans.
    —  Together Action Plans.
    —  Respect Action Plans.
    —  Local Area Agreements.

  4.8  The above is far from an exhaustive list, but it is reasonable to suggest that, to a large extent, effective management of local services will occur despite, rather than because of, the mass of performance-related architecture that has grown around the local delivery agencies.

  4.9  If change is to occur at the regional level, then the driver of this development must be the alignment and rationalization of existing demands and rebalancing the relative weight of target-setting from the national to the local.

  4.10  While acknowledging that there are clear advantages to be had from managing specialist and back office services on a wider than the current County Force basis the majority of policing business is managed at the BCU and sub BCU level working with partners, organisations and communities from the ground level.

  4.11  Our experience of working alongside two tier Authorities in large rural areas, such as GOSW, challenges the accepted definitions of regional and sub regional. The diverse nature and spread of the communities across large geographic areas and confused accountability mechanisms do not support a regional model for service delivery.


  5.1  Whilst city regions are perceived to be catalysts in driving regional and national economic performance it must be recognised that this development is still in its relative infancy and it is not clear how the city region is defined. Key benefits appear to be the focus on collaboration to promote economic success, delivery of sustainable neighbourhoods and communities and the focus that is given to enhancing key city and conurbation infrastructures.

  5.2  There is a lack of clarity on how such an arrangement will engage socially excluded communities to improve their quality of life. Moreover, the question of how the envisaged wealth and prosperity will be equally spread across communities still appears unanswered. There is also the potential obstacle that may be encountered with the differing local governance mechanisms and political allegiances that exist between the areas that fall within the city region. This may prove difficult to reconcile and thereby impede the collaborative stance required.

  5.3  Within the North East region there are two proposed city regions; the Tyne and Wear City Region[103] and the Tyne & Wear and Tees Valley[104] City Region. It is worth bearing in mind that these are economic not social concepts and consequently are not aligned to existing structures. Any new arrangements, such as the establishment of these city regions, must therefore be cognisant of the revised local authority structures that underpin them.

  5.4  The concept of city regions appears to undermine the argument for regions and raises the concern that cities would attract greater funding to the disadvantage of the remaining region, with increased bureaucracy and additional costs. Bearing in mind the fragility of regional structures these could be a further, unhelpful, complication.


  6.1  The development of a city region may enhance the migration of resident core city population to the peripheral towns and cities, thereby creating an economic stimulus through demand for local housing, education and health. Further spin offs may include improved accessibility to transport infrastructure, skills, health services, educational facilities and cultural activities within core cities and city regions.

  However, the city region could actually affect the peripheral town and cities' ability to survive economically. An occupational divide could develop alongside a local economic downturn which may exacerbate deprivation levels and lead to the development of pools of economically inactive people and poverty.

  6.2  In reality, it is difficult to envisage circumstances in which the establishment of city regions would benefit "peripheral towns and cities" rather than disadvantage them. It is important to recognise the potential risk that greater emphasis could be placed on city regions, to the detriment of other areas, such as rural communities. The importance of people's perceptions should not be under-estimated. Policing of these areas should be effectively managed through sound BCU and local partnership arrangements.

  6.3  The establishment of city regions could adversely affect funding to and economic growth in peripheral towns and rural areas.

  6.4  There is clearly an optimum size of infrastructure beyond which public services cannot be delivered in an effective and comprehensive manner to the customer. Regional structures become detached and unnecessary bureaucratic obstacles, when they are applied to areas beyond that optimum size.


  7.1  Policing is not a business bound by lines on a map and inter-regional co operation will remain a feature of the way policing operates whatever boundaries apply. Economic disparity does impact upon crime and therefore in principle co operation at any level that assists in the management of this could be viewed as welcome.

  7.2  Regional co-operation might be seen as the movement of resources between regional Government offices. This could impact upon the police ability to sustain its efforts in crime reduction if funding streams currently administered by GOSE were redistributed to other parts of the country and regions.

  7.3  The benefits of such cooperation are not only economic—for example the inter-regional work on the Milton Keynes and South Midlands Regional Strategy is an effective model to deliver sustainable communities.

  7.4  Inter regional co-operation becomes difficult in a geographic region such as the South West, where city based regions such as Bristol have no beneficial impact on the socio-economic profile of the peninsula counties. The reverse is also true, the hinterland of that same city (Somerset) is relied upon for substantial economic and political support yet arguably receives inequitable allocation of service delivery.

  7.5  Rural disadvantage and poverty would be detrimentally affected by dependence upon a regional government structure upon which the most powerful persuasion for resource allocation will be from urban centres.

103   Including the unitary authority areas of Newcastle, Gateshead, South Tyneside, North Tyneside, Sunderland and adjacent parts of Durham County and Northumberland County. Back

104   Including the unitary authority areas of Darlington, Hartlepool, Middlesbrough, Redcar and Cleveland and Stockton on Tees, and the District of Sedgefield in County Durham. Back

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