Memorandum submitted by Police Federation
of England and Wales
1. INTRODUCTION
1.1 The Police Federation of England and
Wales is the staff association for over 95% of police officers.
Established by statute, we are responsible for the welfare of
officers and the provision of an efficient police service.
1.2 We welcome the opportunity to give written
evidence and would be happy to provide oral evidence to the Committee
at a later date.
1.3 The demise of traffic policing has been
a controversial policing issue for many years. The Police Federation
is not alone in raising concerns. RoSPA, RoadPeace and HMIC have
all expressed similar concerns over the fall in traffic police
numbers.
1.4 In 2005 the Police Federation formed
a traffic policing sub-committee. In November 2005 we held the
inaugural Police Federation Roads Policing seminar attended by
Derek Twigg MP (Parliamentary Under Secretary of State, Department
for Transport), Chief Constable Meredydd Hughes (ACPO lead on
roads policing) and representatives from the Highways Agency and
RoSPA.
2. OVERVIEW
2.1 We believe there is growing confusion
as to the precise definition and role of roads police officers.
Consequently, national figures on officers actually deployed on
traffic duties are not as clear as they should, and indeed could,
be.
2.2 Technology is an important tool in influencing
driver behaviour, especially in respect of speeding. It should
be recognised, however, that its use is very limited and is no
substitute for the observant, experienced and highly trained traffic
police officer.
2.3 The upward trend in drink, and especially
drug, driving offences, deaths and injuries, is a great cause
for concern. We do not believe this problem will be addressed
until the broader problems with roads policing strategies, priorities
and funding are addressed.
3. ARE TRAFFIC
OFFICERS ADEQUATELY
RESOURCED, TRAINED
AND SUPPORTED?
3.1 We have serious concerns that resources,
training and support will be adversely affected by the new Highways
Agency Traffic Officers (HATOs). As their profile and technical
ability increase we anticipate further extension of their powers—a
powers creep that could lead to the eventual disappearance of
police officers from the enforcement of road traffic legislation
in favour of other key policing priorities. Moreover, we believe
it to be dysfunctional and unsustainable for two separate government
departments to oversee roads police officers and HATOs. Conflicts
and confusion are inevitable where remits overlap and we would
advise strong caution against any new powers being conferred to
HATOs. Indeed, we note the Transport Committee's comment in relation
to the Traffic Management Bill that:
"We expect the House will be keenly interested
in Clause 8 which gives national authorities the power to give
"further special powers" to traffic officers [HATOs]."
[5]
In reply the Government's reassurance was heavily
qualified:
"We have no existing plans to confer
further special powers on traffic officers . . . as operational
experience develops, further powers may be identified that could
make the service more effective." [6]
3.2 Whilst we believe roads policing teams
receive a fairly consistent level of equipment, we would like
to see the service keep pace with the private sector. The contrast
in on-board vehicle technology available to roads police officers
and roads rescue services such as the AA and RAC is of particular
interest. In many cases roads rescue services enjoy the sort of
technology that would be of great use to police officers.
3.3 We believe the level of training and
general competencies for traffic police officers to enforce the
myriad of road traffic legislation is in decline. Many officers,
for example, no longer have competences in the enforcement of
driving hours legislation, construction and use regulations (skills
in vehicle technology) or the transportation of hazardous chemicals.
3.4 We are unconvinced that roads policing
is considered a priority beyond meeting the key performance figures
in respect of casualty targets—this despite the significant
impact such patrolling officers have on the spontaneous detection
of crime. There is a clear parallel with community policing which
fell into decline in the 1980s and 1990s precisely because only
a snapshot of the broad spectrum of tasks undertaken by officers
was recognised and valued. It is noteworthy that had the service
concentrated solely on quantifiable aspects of roads policing
over the past 20 years many terrorist suspects and criminals stopped
by roads police officers for acting suspiciously would have slipped
under the police radar.
4. WHAT IMPACT
HAS THE
JOINT ROADS
POLICING STRATEGY
HAD ON
THE WORK
OF TRAFFIC
OFFICERS?
4.1 In reality we have seen no higher priority
or investment given to the work of traffic officers following
the introduction of the Joint Roads Policing Strategy. The performance
of individual forces is measured against specific performance
indicators dictated by HMI/Home Office. The Roads Policing Strategy
does not feature prominently in these performance indicators.
The only direct link is the 2010 casualty reduction target set
by the Department for Transport. As with any target regime, it
is simply a case of "only what gets measured gets done".
At the present time Roads Policing is consequently seen as low
priority.
5. HAVE POLICE
FORCES ACROSS
THE UK GOT
THE BALANCE
RIGHT BETWEEN
TECHNOLOGY-LED
ENFORCEMENT AND
OFFICERS CARRYING
OUT ROAD
POLICING DUTIES?
5.1 We believe technology is an important
asset in delivering the road safety message. However, it seems
the greater focus on road safety in recent years has been to concentrate
on speeding through enforcement cameras. This has been the emphasis
for far too long, such that we believe there is an over reliance
now on enforcement cameras, which have fallen under the control
of camera partnerships. Static enforcement cameras are only effective
where they are sited and have little effect beyond the immediate
vicinity of the camera.
5.2 We are supportive of greater use of
Automatic Number Plate Recognition system (ANPR) technology, but
have concerns that this is developing into a robotic enforcement
process, particularly where police officers place too great a
reliance on technology rather than their judgment, experience
and discretion. It seems the priority for ANPR is in favour of
criminal activity, and supports the concept of denying the criminal
the use of the road, not on road safety. We therefore foresee
a further decline of roads policing skills in the future and this
is supported by anecdotal evidence from officers up and down the
country.
5.3 We also have concerns that the "hit
rate" of ANPR will present the service with a significant
challenge. At the Dartford Tunnel and connecting road network
it is suggested that ANPR can achieve one million "hits"
per day. A successful identification rate of only 2% equates to
some 20,000 hits per day. Even allowing for some prioritising,
this huge volume would require a veritable army of road police
officers to cope with such a high demand.
5.4 Technology is only as good as the information
entered onto a database. As such, at a most basic level, it can
never take account of those drivers who use mobile phones, fail
to wear seat belts, drive in an anti-social manner, fail to comply
with other rules of the road, and nor does it detect drink/drug
driving offences. It is also important to note the limits of the
benefits of ANPR. As it is restricted to tracking the identity
of vehicles, criminals can evade detection by simply travelling
in a vehicle not registered in their name or in a vehicle not
identified as of interest to the police.
5.5 The importance of a visible police presence
is perhaps best illustrated by the problem of drink/drug driving,
as it can be no surprise that drink drive deaths have increased
as the number drink drive tests have fallen (by around 30,000
per annum since 1999). As with any form of crime, individuals
make a calculated decision based upon their perception of the
risk of being caught and the likely punishment that will entail.
We believe the decline in roads policing has been an important
contributory factor to the increase in this crime.
6. HOW EFFECTIVE
AND HOW
EFFICIENT IS
ROADS POLICING
IN REDUCING
THE NUMBER
OF ROAD
CASUALTIES?
6.1 Although this is an inherently difficult
issue to assess as there are many different imponderables (education,
road signing and traffic calming, road engineering and improvement
in vehicle safety features), we strongly believe enforcement and
education delivered by experienced Traffic Police officers plays
a vital role in impacting upon driver behaviour. Even the mere
sight of a roads police officer influences driver behaviour, as
does the belief that traffic officers are, or could be, operating
nearby.
7. TO WHAT
EXTENT DO
APPROACHES TO
TRAFFIC ENFORCEMENT
AND CASUALTY
REDUCTION DIFFER
BETWEEN FORCES
ACROSS THE
COUNTRY?
7.1 In the existing 43 police forces in
England and Wales there are effectively 43 different approaches
to roads policing, ranging from significant resources and commitment
to almost no interest (other than perhaps speed enforcement).
7.2 The methodology adopted by different
forces in respect of casualty reduction and enforcement also varies
widely. Whilst some forces still have dedicated Road Policing
Units with highly trained staff deployed in accordance with casualty
data and crime information, others have disbanded these units
completely in favour of devolving staff to Basic Command Unit
(BCU) level. In such circumstances officers find themselves busy
with general police work and the time and energy spent upon roads
policing is significantly diminished.
7.3 We are also concerned that due to the
number of deaths and injuries on our roads and the need to comply
with the Road Death Investigation Manual, too much officer time
is spent on investigating these incidents rather than on enforcement
or prevention.
8. HOW HAVE
TECHNOLOGICAL DEVELOPMENTS
AFFECTED BOTH
THE DETECTION
AND ENFORCEMENT
OF DRIVERS
IMPAIRED THROUGH
ALCOHOL, DRUGS
AND FATIGUE?
8.1 In relation to detection, technological
developments have had only a minor impact upon drivers impaired
through alcohol or drugs. The reason for this minimal assistance
is that it still requires a constable to stop and deal with the
driver—technology alone will not improve this.
8.2 One area where technology has improved
detection is in relation to the use of ANPR. Details of regular
drink and drug drivers are added to the ANPR database system which
helps officers to identify the vehicles of offenders.
8.3 In respect of enforcement, new state
of the art roadside screening equipment for alcohol is beneficial
provided that officers have the time and commitment to use it.
The service is in desperate need of an effective drug screening
device but this still appears to be some way off. Part of the
reason for this is the difficulty and costs associated with Home
Office type approval. We believe this process must be subject
to a serious review, and a new system established which encourages
innovation by manufacturers.
9. IS THE
BEST USE
BEING MADE
OF THESE
TECHNOLOGIES?
9.1 Yes. Police officers are making best
use of what is currently available—but there is still significant
room for improvement. At present, officers have to complete a
paper form for each and every negative breath test they conduct.
This is unnecessarily bureaucratic. The roadside screening device
could automatically store the key data (to be downloaded by the
officer on a weekly or monthly basis—involving no paperwork).
Obstacles to such improvements relate primarily to the "type
approval" process. This is very expensive and manufacturers
are reluctant to meet these costs in order to upgrade equipment
and meet Force demands. Costs for type approval for one device
can be as much as £60,000. This has the effect of stifling
innovation and new developments.
10. WHAT LEGISLATIVE,
STRATEGIC AND
OPERATIONAL CHANGES
WOULD IMPROVE
THE EFFECTIVENESS
OF THESE
TECHNOLOGIES?
10.1 A number of changes to the legislative
framework would assist the police services' operational effectiveness.
Firstly, the drink drive limit should be reduced from its current
level of 80 milligrams of alcohol in 100 millilitres of blood
to 50milligrams. The UK is now one of only two countries in the
EU that continues to tolerate such high alcohol levels in car
drivers. Secondly, the law currently requires a blood or urine
option to be offered to those who are between 40 and 50 micrograms
of alcohol in 100 millilitres of breath (the limit in breath being
35 micrograms). We believe that the accuracy of modern testing
equipment is such that this option should be withdrawn, thereby
releasing officers from unnecessary bureaucracy. Offenders are
already protected by the cautioning policy which disposes of those
between 35 and 39 micrograms (inclusive) without prosecution.
We believe this would free up approximately two hours of officer
time per officer.
11. HOW WILL
THE NEW
FUNDING ARRANGEMENT
ANNOUNCED BY
THE SECRETARY
OF STATE
AFFECT THE
WORK OF
THE ROAD
SAFETY CAMERA
PARTNERSHIPS?
11.1 The sweeping changes made to funding
arrangements are likely to have a significant impact on the way
road safety partnerships function. Local authorities will be able
to receive 70% of the funding without any "strings attached".
Some may choose to take the money and abandon the safety cameras—possibly
handing them back to the police. The remaining 30% of funds will
be linked to casualty reduction. If local authorities decide to
use funds for projects other than safety cameras then revenue
will fall and this will have clear implications for the way safety
cameras are managed.
12. WHAT LESSONS
CAN BE
LEARNED FROM
THE EXPERIENCE
OF SPEED
LIMIT ENFORCEMENT
USING CAMERA
TECHNOLOGY?
12.1 We believe enforcement cameras only
impact on driver behaviour or awareness where they are statically
situated. It would be far better in the interests of driver compliance
to consider wider use of speed/distance devices. We acknowledge
the expense involved, but we are concerned that better, more efficient
technology is not being developed quickly enough. The impact of
speed/distance devices over motorway maintenance areas is very
encouraging.
12.2 Most drivers are unsure about the speed
limits on roads and we would advocate greater use of "speed
repeater boards" and interactive signs.
12.3 We are also concerned of varying levels
of enforcement outcomes across the country. This growing postcode
lottery can only have an adverse affect upon public confidence.
13. HOW EFFECTIVE
ARE MULTI-AGENCY
APPROACHES TO
SAFETY ISSUES?
WHAT STEPS
ARE REQUIRED
TO IMPROVE
PARTNERSHIP WORK
BETWEEN THE
POLICE, DEPARTMENT
FOR TRANSPORT,
LOCAL AUTHORITIES
AND OTHER
AGENCIES?
13.1 Generally, we believe partnership work
is the correct way to achieve results. However, we take the view
that the present arrangements between the Home Office and the
Department for Transport are not as effective as they might be.
Casualty reduction targets are dictated by the Department for
Transport as opposed to the Home Office. Regrettably, there is
little incentive for Chief Constables to focus resources on this
issue as it is not seen as a Home Office priority.
14 February 2006
(http://www.publications.parliament.uk/pa/cm200304/cmselect/cmtran/144/14404.htm)
5 Transport Select Committee: Traffic Management Bill
(First Report) Back
6
The Government's response to the Transport Committee's report
on the Traffic Management Bill. Back
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