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
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
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
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
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
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
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
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
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
(Home Office) Police Standards Unit monitoring and/or
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
Meeting floor requirements for ring-fenced funding
Local Public Service Agreements.
Outputs from Local Strategic Partnerships eg Community
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
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
and the Tyne & Wear and Tees Valley
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. IMPACT WHICH
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
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 economicfor 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
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