Supplementary memorandum submitted by
The Association of Chief Police Officers of England, Wales and
Northern Ireland
Thank you for your letter dated 14 March, with
supplementary questions for my considerations. Please find below
my response to those questions. You will note that there is an
attachment to the response to question 3—a copy of the ACPO
ANPR Strategy for the Police Service, 2005-08: [3]
1. The Roads Policing Strategy has not been
adopted by all forces—is this a matter for concern? What
have you done to encourage adoption of the strategy?
To date, only three forces have not formally
adopted the Joint Road Policing Strategy. Two of these forces
will be reviewing their current strategies in 2006, in the light
of the Joint Strategy. The third force has no plans to adopt the
Strategy but still contributes to the five key priority areas,
although not formally recognising the document in its own Strategy.
The Strategy has the status of good practice advice to forces
and I would not, therefore, criticise those who have yet to adopt
it.
I would also draw your attention to the response
of Huw Jones in the transcript of the Committee Hearing to question
65:
"What they have not done is adopt everything
in there. All of them have adopted parts of it . . ."
2. To what extent do the Police take into
account research (such as that by the Transport Research Laboratory)
which has examined the effectiveness of different types of policing
such as stationary, visible and mobile policing? How do Police
forces use this information when making decisions on how to deploy
roads police? How are the results of research disseminated to
the Police?
ACPO has a Research and Development Portfolio,
is headed by Bob Golding, an Assistant Chief Constable, and he
is also responsible for the Research and Development Portfolio
of the ACPO Road Policing Business Area. This signals ACPO's commitment
to being closely involved in R & D matters. The Road Policing
R & D Portfolio maintains a close liaison with the Road Crime
Section of the Home Office Public Order and Police Cooperation
Unit through day-to-day contact and membership of its Road Policing
Research Committee. The Portfolio also maintains close liaison
with the Home Office Scientific Development Branch. Indeed, one
of its scientists has a permanent place on the ACPO Road Policing
Operations Forum, attended by road policing professionals representing
the ACPO Regions. ACPO does conduct limited environmental scanning
of new research and was aware of the TRL report, "How methods
and levels of policing affect road casualty rates" published
in 2005, but understood that, having been commissioned by TFL,
it was London specific and did not therefore examine it in detail
or draw the attention of forces to it. ACPO does circulate the
details of relevant pieces of research to its members and road
policing professionals as and when necessary but not on a regular
basis.
3. To what extent has the focus in the Roads
Policing Strategy on "Denying Criminals the Use of the Road"
moved road policing resources away from enforcement of traffic
law, towards more general law enforcement?
The ACPO ANPR Strategy for the Police Service
2005/08, which supplements the Roads Policing Strategy is the
main means of operationalising the desire to focus roads policing
resources on more general law enforcement as well as traffic law
enforcement. However, before providing more detail, I feel it
is necessary to make two overriding points of clarification:
Firstly, the enforcement of traffic law and
more general law enforcement are not mutually exclusive activities.
Specifically, academic research has shown conclusively that those
who commit a wide range of criminal offences are also predisposed
towards traffic law offending. As such, an effective way of targeting
and disrupting mainstream offenders is to target their traffic
offending. For example, a prolific burglar who uses a motor vehicle
in the commission of his offending is also likely to be driving
an uninsured and unlicensed vehicle. Targeting uninsured and unlicensed
vehicles, particularly through the use of ANPR, is quite likely
to bring this burglar to police attention. Use of our new powers
to seize uninsured and unlicensed vehicles will then result in
this criminal losing the means to commit crime as readily, thereby
significantly disrupting their criminal activity as well as improving
road safety.
Secondly. It is wrong to see roads policing
resources only in terms of the number of officers within roads
policing units. In particular, the adopting of ANPR as a mainstream
policing tool has led to the establishment of at least one dedicated
ANPR intercept team (usually one Sgt and six PCs) in all forces
in England and Wales, with a commitment to increase this number
in the next few years. Whilst many of these units may not be termed
roads policing resources, they are in fact a very high profile
visible policing presence on the roads targeted at stopping vehicles
on an intelligence led basis for either traffic or more general
law enforcement purposes. Any consideration of the total roads
policing resources must take account of these intercept teams.
4. You confirmed (Q 51 in transcript) that
ACPO does not support the introduction of random breath testing.
What is ACPO's views on the potential for "targeted breath
testing" powers? Targeted breath testing would allow the
police to conduct breath tests in locations and at times that
they suspect drink-driving is taking place. These powers would
be more limited than random breath testing. This was a proposal
in the 1998 consultation on Combating Drink Driving—Next
Steps. The powers could be similar to the stop and search powers
conferred under the Knives Act 1997.
I would support the targeted breath testing
powers proposal but please note that this is a personal view and
not one that has been put to my colleagues nationally. I have
examined the PACTS proposal in this respect and found that it
has merit. The support of my association would, however, could
not be fully relied upon until such time as a full proposal had
been the subject of national consultation.
5. Do you accept the international research
evidence that random and targeted breath testing increases compliance
rates?
I do accept that international evidence shows
that in the countries that it is adopted random and targeted breath
testing has had a positive increase on compliance rates. However,
it is not always clear what influence increased enforcement activity
may have had on the outcome. The adoption of random and targeted
enforcement might not necessarily have the same results in the
UK.
6. The UK has one of the lowest rates of
breath testing in Europe. Why are there not more breath tests
carried out in the UK?
The level of resources applied to drink driving
enforcement is a matter for individual chief constables. Police
Officers in the UK conduct breath tests when they suspect alcohol
or where a collision has occurred. The decision to breath test,
in the absence of random testing, is a matter of discretion for
the individual officer. There have been suggestions that more
tests are conducted than reported but it is a matter for individual
chief constables to tighten up their reporting procedures, not
ACPO.
The real question is how much of an impact are
police in the UK having upon drink related road death. In 2003,
drink-driving fatalities in the UK were 0.98 per 100,000 population—one
of the five lowest of the 14 EU countries that provided the data.
The data gathered in the UK is very accurate, this cannot necessarily
be said for some of those countries shown to have a better record
than the UK—Slovakia, Czech Republic and Italy for example.
In short, it is not the number of tests that are carried that
is important but testing the right people and detecting the drink
drive offenders. The ACPO recommendation that all drivers in collisions
dealt with by police should be breath tested is an important factor
in this.
7. How successful has Field Impairment Testing
of drug driving been? How does the number of successful prosecutions
using Field Impairment Tests compare to that for drug-driving
before Field Impairment Tests were introduced?
Over the last five years, laboratory drug sample
testing has increased from approximately 350 to 3,700 per year.
The only change to the investigative process has been the introduction
of FIT in a few forces as a voluntary measure in 2000 and in most
forces as a legally enforceable requirement in 2005 with a corresponding
increase in instructor training. Drug impairment and Drink Impairment
figures are a combined statistic at the Home Office and cannot
be divided. It is also hard to see the full extent of Drug Impaired
driving because it is much easier to prosecute for excess alcohol
than it is for drugs. Consequently, a driver who may have a combination
of both in their body will generally be prosecuted for the alcohol
offence since this is easier to prosecute and the penalty is the
same, even though the person may have performed badly in a FIT
test and even though drugs may be present. These factors prevent
police from acquiring a clear picture of the extent of the problem.
8. How many forces have not yet adopted Field
Impairment Testing? Why have not all forces adopted Field Impairment
Testing?
ACPO has not required forces to report on their
up take of FIT. We do know the number of instructors but not the
number of trained officers.
9. You told us (Q76) that roads policing
should have a higher priority. You also told us that there was
no need for an extension of the number of speed cameras (Q33)
and no need for random breath testing powers (Q51). What aspect
of traffic law enforcement should be increased, and how should
this be achieved?
Whilst speed cameras play an important role
in reducing those killed and seriously injured on the roads, there
is no doubt that other types of offending also need to be addressed
if the downward trend in KSIs is to continue. This includes enforcement
of seatbelt legislation, enforcement in regard to the roadworthiness
of vehicles and targeting those drivers most likely to be involved
in collisions (eg disqualified drivers, drink/drug drivers, uninsured
drivers, unlicensed drivers and those driving stolen motor vehicles
or driving aggressively or antisocially).
ANPR is the best method of targeting many of
these offences. As such, ACPO advocates that when funding for
the Safety Camera Partnerships changes in 2007-08 to funding for
more general road safety activity, there should be an anticipation
that some of this funding will be spent on enabling police enforcement
campaigns—for example, through purchasing additional ANPR
equipment.
10. Should the police now reduce the threshold
speed that triggers enforcement? How accurate is the speed detection
technology—does it need such a large margin for error?
The current stance is that the threshold should
not be reduced at present. However, as new holder of the work
stream dealing with speed enforcement and portfolio holder for
Safety Cameras, ACC Adam Briggs is to commence a review of the
current position to include current detection technology, in-car
technology and the relevant thresholds. This review will include
the involvement of, amongst others, Chief Supt Jerry Moore at
the Department for Transport and the ACPO Roads Policing Operations
Forum to ensure that all relevant stakeholders are consulted.
11. Do you have any concerns over the use
of Automatic Number Plate Recognition technology? Does it encourage
the "de-skilling" of traffic officers as the Police
Federation has suggested?
ACPO has no concerns over the use of ANPR technology
and does not accept the view that the use of ANPR "de-skills"
traffic officers. ANPR assists officers to identify vehicles that
are more likely than not to be worth stopping. From that point
onwards, it is entirely down to the skills of the officer as to
whether this targeted stop produces results, whether in terms
of traffic law enforcement or more general law enforcement.
It would be ACPO's view that by effectively
targeting officers, there is a vast increase in their productive
time - that is time spent with drivers who are likely to be offending.
In turn, this means the officers deal with a far greater range
of offenders and offending vehicles. This increases their experience
much more quickly than traditional methods of policing and leads
to them having higher skills than officers who are not targeted
in this way through ANPR. In particular, ANPR equipped officers
rapidly learn how to establish the true identity of drivers, leading
to fewer unservable summons or offenders failing to appear at
court etc.
Please accept this response as being on behalf
of the Police Service.
30 March 2006
3 Not printed. Back
| 
