Written evidence submitted by the Metropolitan
Police Authority (LOCO 53)
INTRODUCTION TO
THE METROPOLITAN
POLICE AUTHORITY
The Metropolitan Police Authority (MPA) was established
in 2000 to provide oversight, transparency and accountability
for policing in London by holding the commissioner rigorously
to account for the delivery of an effective and efficient police
service for all London's communities. Met Forward sets out the
Authority's strategic mission, which is intended to guide
the Metropolitan Police Service in tackling the issues that matter
most to Londoners: fighting crime and reducing criminality; increasing
confidence in policing; and giving us better value for money.
The MPA is a functional body of the Greater London Authority (GLA)
and the Mayor appoints the chair.
EXECUTIVE SUMMARY
In this response, we have defined localism as:
1. The principle by which power is devolved to
individuals, communities and local bodies that operate at either
local authority or pan-London level, through opportunities to
directly influence decision-making and/or by providing local bodies
delivering public services with significant discretion in determining
the services they provide.
2. From the policing perspective it is important
to understand the landscape and context within which these services
are provided. The MPS covers an area of 620 square miles and a
population of 7.2 million. The Service employs more than 32,500
officers together with about 14,200 police staff, 230 traffic
wardens and 4,300 Police Community Support Officers (PCSOs), as
well as almost 4000 volunteer police officers in the Metropolitan
Special Constabulary.
3. The MPS is a London wide organisation with
a range of specialist and national functions, such as diplomatic
protection, counter-terrorism, serious and organised crime and
marine and air support. In addition to these London wide responsibilities,
the MPS delivers local policing services through the territorial
policing structure, which is comprised of 32 operational command
units, which are co-terminous with the boundaries of the 32 London
boroughs. We know, however, that crime does not respect those
boundaries and cross-border issues are a key concern for the MPA
and the MPS. In the London context then, "local" must
therefore be understood at two different levels; "local"
as in the London borough and "local" as in London wide.
This necessitates an oversight body with the capacity to provide
strategic direction and oversight across the entire police district
to ensure the effective delivery of policing services that are
responsive to the needs of those who visit, live and work in London.
In addition, there is a role for such a body to bring together
other criminal justice partners to meet all the challenges of
policing and community safety in a complex and diverse city. The
Authority has addressed these issues in its response to the Home
Office consultation document "Policing in the 21st Century:
Reconnecting Police and the People", which explores these
issues in greater depth (see Appendix 1).
The main points of our submission are that:
¾ the
move towards increased decentralisation is welcome. The MPA has
for some time been proactively involved in supporting local decision-making
and problem solving to tackle local policing concerns, but there
must be recognition that for London, local cannot simply mean
local authority level;
¾ a London
wide oversight body for policing is required to ensure the MPS
is delivering effective policing services to London and to also
deliver more effective partnership working with the wider criminal
justice system;
¾ localism
provides a great deal of flexibility to ensure service provision
is tailored to the needs of different communities, but this requires
effective engagement, equality impact assessment and accountability
mechanisms to be in place to ensure decisions meet the needs of
the many, not the few, and are proportionate and non-discriminatory;
¾ effective
partnership working requires effective and robust governance and
decision-making processes and this will become even more important
with increased decentralisation, which is to be accompanied by
reduced inspection and performance regimes. Leadership, accountability
and responsibility will need to be defined and communicated to
stakeholders and to local people;
¾ this
is not only a new way of working for those of us at the local
level, it will also require a different approach from central
government departments, which may not currently be appropriately
structured to deal with the process of decentralisation; and
¾ there
are significant risks arising from the pressure to make immediate
financial savings. The impending spending cuts will affect many
of the partnership arrangements currently established locally
and may encourage organisations to retreat from partnership working
to look after their own interests. This may generate a negative
impact on community confidence as well as fear of crime and our
concern is that in the community safety context, the police service
may come under increasing pressure to resolve this tension whilst
still being obliged to deliver its own services within its own
resource constraints.
RESPONSE TO
THE SPECIFIC
QUESTIONS
The extent to which decentralisation leads to
more effective public service delivery; and what the limits are,
or should be, of localism
4. Decentralisation has great potential to make
public services more effective. Where more discretion and power
is given to local people and bodies, they are able to make decisions
which target the needs of local people more effectively. Decentralisation
also allows local people to have much more influence over the
decisions made in their name, which could bring some significant
benefits for civil society as well as more engagement in local
politics.
5. A fundamental element of decentralisation
must be a mature approach to engagement and accountability. The
concept relies on the assumption that all have equal access to
the process and are motivated by the need to be representative;
we know from our experience that this is not always the case.
Such local accountability needs to be credible, having the powers
and resources necessary to secure local influence, and legitimate,
involving local people, led by people who are selected, or elected,
by local people or groups.
6. Local authorities are well placed to provide
this accountability through their oversight and scrutiny role
(usually in partnership with other non-executive bodies in the
locality, such as the police authority). Overview and scrutiny
can also contribute to policy and service development. Recent
changes, however, mean that it is now possible for local authorities
to revert to the old committee structure, which could in our view,
lead to reduced public accountability and engagement.
7. In London there is a need to also provide
engagement and accountability at a more strategic level, which
can only be achieved through bodies such as the MPA and the GLA.
In London there are 32 boroughs within the MPS district all of
whom have separate local accountability frameworks. However, the
MPS must balance the need to police all of London against the
need to provide policing services at the borough level. This requires
effective pan-London oversight, which is currently provided through
the MPA. The Authority has a strong track record in this area,
delivering borough level engagement and accountability through
the link member role and public CPEG meetings, and pan-London
scrutiny and oversight through our committee structure and through
targeted scrutiny work focussing on specific aspects of policing,
such as gun crime, rape and civil liberties.
8. The limitations of localism include aspects
of public policy making that require strategic direction and control,
such as defence and foreign policy. There may also be circumstances
where national or regional considerations will override local
ones. This is particularly relevant in the policing context, where
crime and community safety issues may cross borough boundaries
and in the case of the MPS where its specialist and national functions
will sometimes take precedence over local matters. For example,
being responsible for the capital city, the MPS has significant
public order responsibilities and such events (eg the Olympics),
may at times require resources to be abstracted from borough policing
to ensure an appropriate police presence.
9. The key principle is to balance competing
interests within an understandable, and equitable, framework.
Decentralisation can and will lead to significant variances in
the nature of service delivery in different parts of the country.
It may therefore be appropriate for Government to identify a core
set of national minimum standards leaving others to the discretion
of local people.
10. Local people and relevant stakeholders will
need to be clear how the localism agenda fits in with the Government's
plans for the Big Society. The localism agenda is dependent on
local communities being informed and responding to actual rather
than perceived issues. Local policing has been consistently hampered
by the problems this distinction causes. For example, perceptions
and the fear of crime do not necessarily reflect the levels or
types of actual crime at a local level. So again, without robust,
inclusive and transparent decision-making decentralisation may
fail to deliver.
The lessons for decentralisation from Total Place,
and the potential to build on the work done under that initiative,
particularly through place-based budgeting
11. The evidence from Total Place pilots and
initiatives has been very encouraging. There are a number of initiatives
that the MPA/MPS have also supported such as the crime and offender
management strand of the Total Place pilot in Lewisham, and the
Diamond Initiative, which was piloted in 6 London boroughs and
aimed to tackle reoffending through a multi-agency partnership
approach. These initiatives have provided clear evidence that
single pot commissioning, ie place based budgeting not only saves
money, but can also radically enhance service delivery.
12. The Authority has long supported the co-location
of services within its estate, such as the Safer Sutton Partnership
(based at Sutton Police Station), which has brought together the
police community safety unit and the local authority safer communities
team under single line management. This has brought the benefits
of increased dialogue, better information sharing and improved
performance management and delivery, which resulted in approximately
£300k of savings in the first two years.
13. The Authority is developing this approach
at the strategic level through the establishment of the London
Crime Reduction Board, chaired by the Mayor of London and including
the Chair of the MPA and representatives of London Councils. The
Board will provide the political and strategic leadership for
a senior officer multi-agency commissioning group comprised of
the MPA, the MPS, London Councils, the GLA, London Probation and
the Chief Executive London Committee.
14. It is clear that with the right freedoms
there are opportunities to achieve considerable savings. However,
given the pan-London responsibilities of the MPS, the Authority
will still require the reassurance of ring-fenced budgets if it
is to ensure the MPS delivers all its commitments across London;
The role of local government in a decentralised
model of local public service delivery, and the extent to which
localism can and should extend to other local agents
15. The fundamental principle of localism is
for local delivery to be undertaken at a local level to meet the
needs of local residents and this will require the identification
and engagement of all the stakeholders and partners. The issue
for policing is that whilst it must work in partnership with other
agencies it is required to deliver some core services and must
remain impartial and independent. Policing and policing oversight
requires independence and impartiality if it is to provide community
confidence and reassurance.
16. The practical application of decentralisation
will therefore require police authorities to ensure increased
negotiation, liaison and mutual understanding of needs and priorities.
Leadership will be more complex because of the shared responsibility
for service delivery in an area. In this environment effective
governance, openness, transparency and accountability will need
to be carefully planned, designed and delivered because it will
require joint working between a variety of local partners, including
the local community. Keeping the community engaged, confident
and informed throughout this process will require considerable
effort and commitment and the MPA and MPS have considerable experience
in this area.
17. The Authority's engagement structure consist
of 32 community-led borough Community and Police Engagement Groups
(CPEGs), which sit above and bring together the MPS' Safer Neighbourhood
Panels (SNPs) that work with the MPS' ward-based policing teams
to develop and hold the local team to account for ward priorities.
Borough commanders and community safety partners are then accountable
to the wider community through the public meetings of the CPEGs.
These structures have enabled the Authority and the MPS to maintain
an ongoing dialogue with communities, which supports the development
of a more confident and informed community that is able to challenge
and hold service providers to account. In addition, the MPA conducts
an annual policing plan consultation exercise, which also supports
the identification of public priorities and concerns for consideration
through the strategic planning process.
The action which will be necessary on the part
of Whitehall departments to achieve effective decentralised public
service delivery
18. At the present time there appears to be little
clarity regarding how central government will support the decentralisation
process across all departments and the process will take considerable
time to become embedded. Inspections and standards of practice
have provided frameworks and protocols for local partnership performance
and delivery and the removal of these processes will avoid an
over prescriptive regime, but it may leave some local partners
facing disproportionate expectations from local communities with
regards to local delivery. For example, effective policing and
the delivery of community safety requires partnership working
amongst a range of stakeholders, including local authorities,
probation and the health service. One of the key issues for the
MPA is that should any one partner fail to provide an appropriate
and responsive service for whatever reason, the police service
should neither be held accountable for that nor be expected to
fill the gap. It is therefore essential that central government
departments develop a shared view of localism and of the desired
outcomes so that all service providers are working towards the
same goals. This could include priorities being developed on a
cross-Government basis and/or the development of joint delivery
units.
19. We have made the point about the need for
effective engagement and accountability structures elsewhere in
this response, but it is worth reiterating. Whilst efforts are
being made to ensure the localism agenda provides greater local
accountability, there must be some recognition of the need in
London for strategic level oversight and engagement that brings
together those local borough accountability mechanisms into one
pan-London structure and our response to the Home Office consultation
(see Appendix 1) expands on how we think this could work under
the new Police and Crime Commissioner.
The impact of decentralisation on the achievement
of savings in the cost of local public services and the effective
targeting of cuts to those services
20. As mentioned above the potential of the Total
Place approach to help deliver significant savings is clear. However,
policing is obliged to deliver public reassurance, which requires
taking a value-based approach to service delivery rather than
focusing on cutting costs. A decentralised approach also requires
all government departments and local agencies to share the same
priorities, which is not necessarily the case at present. In the
current period of spending reviews and cost cutting requirements
the potential for individual bodies to retreat into organisational
silos to find ways to make savings within their own budgets has
increased considerably and this could lead to significant tension
between different agencies.
21. Decentralisation will lead to the abolition
of a number of strategic bodies, including the MPA. The rationale
may be clear in the context of decentralising power and achieving
savings, but in some cases there may be a valid argument for preserving
such arrangements. Apart from the governance and accountability
issues raised elsewhere in this response, the Authority has actively
contributed to the development of responsive services, such as
the Havens (rape crisis centres) and the Dangerous Dogs Unit,
and to the delivery of significant savings within policing that
could not have been delivered without pan-London oversight.
22. Effective decentralisation will help to deliver
savings in the long term (as we have discussed). However, meaningful
decentralisation will (like devolution) require time as it is
a process, not an event. It has to be recognised that this time
delay may impact on the availability of tangible evidence of benefits
received, particularly to the public purse. The issue of sustainable
benefits also needs to be taken into consideration and this will
require careful planning, so that short term savings plans do
not so significantly reduce capacity in local areas to the point
that agencies are unable to manage and deliver on the additional
responsibilities that decentralisation will bring.
23. For decentralisation to occur the process
requires the pre-establishment of local awareness and local commitment
by the community so that they are able to engage and participate
in local decision-making effectively. This can be a time consuming
and sometimes costly process. However, if accountability is approached
intelligently, it can provide a powerful method for identifying
savings and efficiencies in local services, based on independent
research and the views of local people. The scrutiny process,
for example, can provide an excellent opportunity for local agencies
to engage in discussions with local people about plans for efficiency
savings.
What, if any, arrangements for the oversight of
local authority performance will be necessary to ensure effective
local public service delivery
24. There is logic to the principles set out
and agreed between the Local Government Group and CLG around local
self-regulation. Sector-owned improvement activity must be the
means for enhancing performance. This is a continuous process
that tends to be focused on peer review and it provides an effective
way to share and promote good practice and positive working. It
is predominantly a controlled exercise that is officer-led and
does not normally directly involve local people. We would argue
that this would be the weakness in this approach, which the Authority
has addressed through its open committee structure and scrutiny
and accountability processes, which enable continued public engagement
and continuous learning and dissemination of good practice.
25. Government proposals, which may result in
many authorities dispensing with their scrutiny functions in favour
of a return to the committee system of governance, may not, in
our view, support the decentralisation process. Even if structures
and processes change the values of transparency, accountability
and scrutiny must be paramount. The removal of the formal scrutiny
function in some local authorities will lead to a significant
mismatch between executive and backbench power. Strong, independent
local accountability, led by elected members, is central to transparent
decision-making and will only become more important as partnership
working increases and central government inspection and oversight
decreases.
26. The decentralisation of inspection and accountability
may have some unintended consequences. The proposed structural
changes in policing and health, for example, may fragment accountability,
governance and improvement in local areas when it should be further
joined up. One way to counter this effect would be through the
provision of a sector or region based outcome-focussed management
information regime. This would ensure that a minimum set of consistent,
accessible and comparable datasets were collated at a certain
level for the benefit of all the relevant stakeholders.
How effective and appropriate accountability can
be achieved for expenditure on the delivery of local services,
especially for that voted by Parliament rather than raised locally
27. As an organisation with responsibility for
a budget of £3.7 billion, we fully recognise the importance
and value of financial transparency in ensuring public accountability
for expenditure. The Government has also recognised this by requiring
local authorities to publish items of expenditure over £500.
We note, however, that not all local partners would be under the
same obligations and would hope that this disparity would be considered
within the Localism Bill. It should also be noted that such information
will be open to different interpretations at the local level and
that its success in delivering greater public accountability is
based on the assumption that local people have the necessary skills,
the time and the inclination to consider detailed expenditure
figures. Furthermore, the provision of expenditure data will not
in itself enable the kind of analysis that might provide confirmation
that service delivery does not prejudice or disproportionately
impact on particular communities and it may be less than useful
without commensurate action to ensure that local people are aware
of the processes through which to seek redress. Central inspection
or accountability performance measures may help address this gap
by assessing the quality of expenditure processes. Decentralising
or relying on local measures will not provide this accountability
process.
28. There is a need to be aware that in some
respects the MPS is quite different to other service providers
since it is obliged to provide policing services across the capital
(ie across borough boundaries) and beyond, as well as delivering
local neighbourhood policing services. In this context, local
accountability may not always be possible or appropriate in some
cases, such as counter terrorism and national security. While
we appreciate the need for a culture of openness in the public
sector as a crucial element of decentralisation, we believe it
would be inappropriate for the police service to be directly accountable
on some important matters. The Authority, therefore, provides
this accountability and transparency through its oversight and
scrutiny functions, some of which, such as the Counter-Terrorism
and Protective Services Sub-Committee, is quite rightly conducted
behind closed doors. As such, the new requirements to publish
expenditure in excess of £500 does not fully take into account
the fact that policing is already much more accountable than many
of its partner service providers.
29. A further issue for consideration is that
the nature of policing is such that it can require large amounts
of expenditure in the short term to address long term issues.
Considerable effort will therefore be needed to ensure such information
is appropriately contextualised at the local level to ensure this
is fully appreciated by local communities. In addition, the complexity
of policing is such that it receives funding from central government
and through the local precept and is expected to deliver services
which uphold the law, support rehabilitation and also prevent
offending. Many of these activities will only impact directly
on small numbers within the local community, and yet, the MPS
may be held accountable to all residents who may have different
expectations of local service provision.
October 2010
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