Memorandum from the London Fire and Emergency
Planning Authority (LFEPA) (FIRE 18)
SUMMARY
1. While many of the comments in this submission
appear negative they are made in the context that we would wish
both central government departments and the fire service to learn
lessons from the FiReControl Project. We acknowledge that the
management of the project has changed during its life and that
some of lessons appear to have been taken on board by the current
management team within CLG. LFEPA continues to support the principle
of the project, subject to certain caveats around operational
effectiveness and affordability, and would wish to emphasise that
any decision to change the scope of the project or indeed to cancel
the project would have significant financial and operational risks
for this authority. This submission to the Select Committee wishes
to draw the attention of members to the following particular areas:
(a) The lack of effective user engagement in
the development of user requirements for the FiReControl project.
(b) The importance that the final decision on
the acceptability of the project delivered remains with the Chief
Fire Officer/Commissioner.
(c) The drawbacks of using separate procurement
processes for the building and IT aspects of the project.
(d) Over specification of parts of the project,
including security arrangements.
(e) A lack of consultation in the development
of the project meant an opportunity was missed to learn from London's
existing regional control room.
(f) The new burdens settlements have been fair
so far but there has been a lack of clarity on whether this will
continue for the life of the project.
(g) For this project to deliver its objectives
there needs to be a new culture of working in partnership with
the FRS.
(h) Delays to the project are utilising valuable
fire service expertise that could be being utilised on other fire
service projects.
THE LONDON
FIRE AND
EMERGENCY PLANNING
AUTHORITY (LFEPA)
2. The London Fire and Emergency Planning
Authority (LFEPA) run the London Fire Brigade (LFB) and is a functional
body of the Greater London Authority.
3. The LFB is the third largest firefighting
organisation in the world; it employs approximately 7,600 staff
and covers the 620 square miles of Greater London and is
the UK's largest fire service. The LFB operates on a regional
basis across all aspects of service provision including its control
room function.
FIRECONTROL
The development of user requirements
4. From the early stages of this project
there has been a lack of effective user engagement. This has led
to a lack of understanding within the central project team of
the technical requirements needed to procure a system that would
satisfy the operational requirements of 46 individual fire
services.
5. This lack of understanding, together
with a rush to procure a system, meant that CLG went into the
procurement process with a large number of user requirements lacking
definition. These were to be resolved post contract award. At
the time, both the Chief Fire Officers Association (CFOA) and
fire service representatives voiced concerns that this failing
would bring uncertainty and risk to the system development. It
was unclear how CLG could be confident that the successful bidder
would be able to develop a system that would meet all of these
yet undefined requirements. If the successful bidder were unable
to meet all the user requirements the whole concept of the project
would be undermined with it failing to match with FRS Integrated
Risk Management Plans (IRMP's). This was one of the main precepts
on which the project was based, and the promise that IRMP's would
not be compromised was crucial in gaining the support and co-operation
of FRSs.
6. We understand that there are still a
considerable number of these requirements that have not been addressed.
CLG need to work closely with FRS representatives to ensure that
there are suitable systems in place to facilitate the development
of the outstanding requirements with user representatives and
fund the facilitation of this engagement where required. Should
this engagement not take place and provide satisfactory outcomes
the project could lose further credibility with the service and
may not be acceptable to them. It has always been stated that
the final arbiter of whether the system is acceptable to an FRS
will be the Chief Fire Officer/Commissioner who must make a risk
based operational judgement that the system will fully meet their
requirements. This must remain the case whatever path the project
may take into the future.
7. The Authority has a duty under section
7(1) Fire and Rescue Services Act 2004 to make provision
for the purpose of extinguishing fires in its area and protecting
life and property in the event of fires in its area. Also, under
section 7 (2) (c) it must, in particular "make arrangements
for dealing with calls for help and for summoning personnel".
This responsibility will not change once the network of Regional
Control Centres become operational even with the appropriate Service
Level Agreements between each FRS and the limited companies set
up to run the RCCs (except in the case of London where LFEPA will
retain responsibility).
The procurement process
8. The concept of running two separate procurement
processes, one for the buildings and one for the IT infrastructure
has led to significant cost overruns, as the buildings have or
will be completed well in advance of the procurement of the IT
infrastructure services. This results in leases, service costs
and utility payments on underutilised buildings. In hindsight
one must question if this was the correct process and if not,
what can be learned for future procurements. We understand that
IT and property procurements are very different but believe there
should have been closer management at a programme level that could
have taken early action to prevent such a divergence in delivery
timescales.
9. The buildings themselves appear to be
over specified and are clearly too large just to house a regional
control centre. The security arrangements incorporated into the
premises appear to be in excess to the threats potentially posed
to the buildings. These two things have led to significantly increased
costs that will result in a long term revenue burden to fire authorities.
Although too late to change, we would like to challenge the design
of the buildings and ask why they are so large as we are unaware
of the user input into the design process. Had users been more
fully engaged in the design process the buildings may have been
more suitable for purpose and there may have been more than one
design of building that could have catered for specific user requirements.
Such an approach may well have led to reduced overall costs.
10. We are fortunate in London that it will
be possible to maximise the use of the premises by housing not
only our Regional Control Centre, the London Local Authority Coordination
Centre, the Brigade Resource Management Centre but also the Fire
Service National Co-ordinating Centre within the premises. We
are aware that there are others who are looking to sub let some
of the excess accommodation in order to reduce the future financial
burden to those authorities.
11. In terms of the security arrangements
that are designed into the buildings we believe that they may
have been over specified considering the current threat assessment
for this type of premises. We understand that there needs to be
an element of future proofing in order that significant expenditure
is not incurred in the future, but do question why each individual
building has been built with such a high level of redundancy.
The resilience of FiReControl was to come from having a networked
solution with capacity and staffing levels that would cope with
any one of the buildings being taken out of commission. The capital
cost of this perceived over specification is of concern, as is
the long term revenues cost of maintaining it, and this will fall
to the FRS.
12. We understand that the requirements
for resilience and security were designed by consultants. Government
organisations such as the Centre for Protection of National Infrastructure
(CPNI), who could have offered objective advice, were not consulted
until the requirements were fixed. If government security advisers
like the CPNI had been consulted at a much earlier stage it is
possible that the building security specification and the subsequent
costs would not be as great as they are.
13. For some years the user community has
said that the FiReControl and Firelink Projects should be brought
together within the same project management structure. There are
many cross cutting issues between the two projects. The Firelink
radio solution is the communications bearer for FiReControl as
well as being the FRS main scheme radio system. Although CLG have
attempted to bring the two projects closer together at a programme
level, there are tensions in having two separate projects delivered
by two separate firms of consultants. We understand that these
started as two distinct and separate projects but it became clear
some years ago that they were to become mutually dependant. We
consider that it would have been much more effective in terms
of communication and the use of consultants' time if they had
been made a single project when this interdependency was first
identified.
User engagement
14. One thing that has been missing from
this project is the ability to learn from users and their previous
experiences. There is a perception that CLG are delivering a product
to the FRS rather than working in partnership with them to deliver
a successful outcome. The London Fire Brigade's existing regional
control centre could have been used as the model for other control
centres within this scheme. Had the project chosen to do so it
would have realised that it was not necessary to develop large
buildings on huge sites with complex and expensive security arrangements
to achieve a similar outcome. London's Regional Control Centre
is and will remain the busiest fire control room in Europe, handling
300,000 emergency calls and around 500,000 non emergency
calls annually. The London control room, its systems and the staff
who work there have served the capital well during all the events
of recent years.
15. One weakness of London's current system
is the inability to offload calls when the number of incoming
emergency calls exceeds the number of Control Room staff available.
This is commonly known as "spike" and "spate".
Spike can be defined when a single incident simultaneously generates
an excessive number of emergency calls, eg a vehicle alight on
a motorway. Spate is where excessive numbers of emergency calls
to multiple locations are received over a prolonged period of
time, an example being electric storms associated with intense
rainfall causing wide-scale flooding to premises and property.
Under both these conditions, callers currently have to wait until
a Control Officer is available to take their call. Under FiReControl,
the network has the ability to route the call (under these circumstances)
to other Regional Control Centres. If the call is to a fire or
a life-threatening special service call, i.e non-fire related,
the call will be answered and responded to quickly. While a fully
functioning fall back facility is in place which is skeleton staffed
24/7 there is a reliance on the Metropolitan Police Service
to take calls that are queued with the BT or Cable & Wireless
operators in excess of reasonable waiting times. This arrangement
is unsustainable due to the volume of calls that are dealt with
by the MPS. Prior to the introduction of the FiReControl Project
the London Fire Brigade had been actively engaged in seeking reciprocal
arrangements with another FRS but these discussions ceased with
the advent of this project.
16. The project is being delivered by a
team within CLG that consists of civil servants, seconded fire
service staff and consultants. The team appears to be very large
for a project of this nature. Where one would have expected the
risks and the resources required to deliver the project to have
sat with the supplier, in this case, CLG seem to be bearing much
of the responsibility and resource burden of delivery. Despite
having a large number of FRS staff seconded into the project team
CLG need to ensure that they have effective user engagement arrangements
in place. While the seconded staff have technical expertise they
do not have the authority or necessarily the strategic or political
insight to speak on behalf of fire authorities.
17. The impact of this on the service in
general is that it has drawn a lot of the technical expertise
from fire services into the centre. From one perspective this
is to be welcomed, as it is only by engaging with users that a
viable product will be produced, but this has led to a significant
risk emerging which is that the fire services themselves will
no longer have the in house capability or capacity to deliver
their transition activities that are required prior to being able
to accept FiReControl into service.
Support for local Integrated Risk Management Plans
(IRMPs)
18. One of the tenets of this project has
been that it would support the IRMP within each fire service.
While it is understood that such a commitment had to be made in
order to secure even the most tentative of approval for the project
among fire authorities, this may not have been the right approach.
It means that for each type of call, there are up to 46 variations
in how they may be handled and attended. For instance, depending
on the FRS a call to a person shut in a lift could be attended
as an emergency, attended as a non-emergency or not attended at
all.
19. While some regions, noticeably the South
East, have begun to work together to identify areas of common
and best practice, there has been no central drive for this to
happen nationally. There was a missed opportunity in the early
stages of the project to encourage and support work both within
regions and nationally to identify common and best practice. This
could have greatly reduced the technical requirements of the project.
There are workstreams within the project that are there to address
the "New Ways of Working" but these are designed to
identify how the FRS will operate within the structure of the
new system rather than identifying common or best practice.
Financial impact on fire authorities
20. There is a commitment from Government
that the FiReControl Project will not be a net new cost burden
on fire authorities. To date the cost of implementation is being
met through new burdens funding. We have found that in general
the settlements for ourselves have been fair and we are pleased
to see that there are mechanisms in place for fire authorities
to bid for further funding if additional costs are identified.
21. A concern for both us and other fire
authorities is the ongoing revenue costs of the project post implementation.
The most recent business case has set out the projected annual
payments that are to be made to authorities incurring additional
costs because of the project. There are two concerns over these
payments. The first is that they need to be agreed with fire authorities.
In London we are still waiting for a response to our concern that
these proposed payments do not accurately reflect the additional
financial burden. Delays to questions such as this make it difficult
for financial officers to plan future budgets accurately. They
also give rise to fears that the money available for fire authorities
may be based more on the availability of cash to the project than
an accurate assessment of the new burden to fire authorities.
22. The second concern is the long term
future of these payments. CLG have only been able to give an undertaking
to review these payments after three years. While it is accepted
that a review is required once steady state has been reached to
ensure that payments remain accurate there is a fear that the
review could lead to these payments being reduced or discontinued.
This would lead to an increased burden for local tax payers. In
order to ensure that fire authorities are willing to commit to
this project, a clear commitment is required that the principal
of new burdens funding will apply for the full term of the project
and not just the first three years. We would ask the committee
to demand an assurance from the government that that the project
is fully funded in both the short and long term and that these
assurances are provided explicitly to fire authorities.
Project timetable
23. The numerous delays in the delivery
of this project have led to a lack of confidence in the ability
of CLG to deliver a complex project of this nature. The problem
stems again from the lack of user engagement at early stages of
the project. From the beginning CLG seemed to have failed to grasp
the complex nature of this project. If this project is to deliver
its objectives there needs to be a new culture of working in partnership
with the FRS, more realistic goals and timescales need to be set.
This has not always been the case to date.
24. The impact of delays to the project
on the FRS is not insignificant. Dedicated project teams have
to be kept in place with a lot of expertise either being seconded
onto the national project team or committed to the project internally.
This takes away valuable expertise from delivering other projects
and programmes that are also essential to delivering and maintaining
service to the public. CLG and suppliers need to commit to the
current timetable and if further delays become apparent these
need to be shared at the earliest opportunity with the user community.
CONCLUSIONS
25. The conclusions that we would like to
see included in any report from the committee include:
(a) The final arbiter of whether the FiReControl
system is acceptable to any individual FRS must remain with the
respective Chief Fire Officer or Commissioner.
(b) There needs to be effective user engagement
from the earliest stages of a project to ensure that all user
requirements are captured and defined. There would be benefit
in fostering a greater partnership approach with the FRS.
(c) There should be a clear audit trail of decision
making that is transparent for all to see; this together with
greater user engagement at all stages of development may have
enabled the design of the buildings to be challenged at an early
stage and more practical solutions delivered at less cost.
(d) There should have been a greater strategic
understanding of the change programme from the outset, this may
have resulted in the FiReControl and Firelink projects being consolidated
with significant savings in consultants fees.
(e) Less reliance should be placed on the use
of consultants for specification purposes when there are reliable
sources of advice readily available within other government departments
and of course within the FRS itself.
(f) More regular external project reviews should
be undertaken and there should be a greater willingness to accept
change within the project as circumstances change.
(g) There may need to be a clearer definition
of responsibilities between the CLG and the supplier as it appears
that there is a large central team having to support the supplier
and so taking on a greater burden of the risks involved. There
should be a recommendation to have a comprehensive review of the
entire procurement process.
(h) The impact to the FRS should have been more
closely examined at the outset. As CLG became aware that this
was not just another IT project to be delivered the draw on fire
service resources to support the project delivery has increased
significantly.
(i) The difficult challenges in the project such
as defining all of the user requirements should have been addressed
at an early stage; this may have led to much more clarity during
the delivery phase. Again we would emphasise that early user engagement
would have helped in this area but it is not only the engagement
process but also listening to what the users have to say that
is important. There needs to be a greater emphasis on partnership
working between CLG and the FRS rather than the customer/client
relationship which appears to exist at present.
(j) The financial settlement to cover the net
new burden to the FRS needs to be a transparent process that is
based on the real impact to authorities and not on the cash available
to the project.
(k) There needs to be a very clear assurance
from the government to fire authorities that new burden payments
will continue for the life of the project and not just the first
three years.
(l) If the government should decide to change
any aspects of its delivery strategy the service itself should
be offered the opportunity to manage the implementation itself,
either by refreshing existing systems or by collaboration with
partners. The government should provide full funding for this
to be implemented. However it must be emphasised that any decision
to change the scope of the project would have significant financial
and operational risks for this authority.
January 2010
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