Written evidence submitted by The Chief
Fire Officers Association (Cfoa) (LOCO 081)
EXECUTIVE SUMMARY
1. The Fire and Rescue Service (FRS) is a well
respected, valued and high performing public service, rooted in
localities and yet a fundamental part of the critical national
infrastructure of the UK. National threats to society posed by
climate change and terrorism require robust, consistent and well
equipped civil emergency capacity.
2. Since the abolition of national standards
of fire cover, the former centralist approach, FRS's have been
better able to provide more effective local solutions to match
local risks and needs. The approach to risk management has led
to very local solutions and integrated risk management plans (Imp's)
drive the allocation of resources to risk through a consultative,
evidenced based process.
3. CFOA supports greater decentralization of
public services as long as this does not lead to unnecessary duplication,
service fragmentation or protectionism. Government must however
ensure that services that are required to operate across boundaries
in the national interest are not fettered in doing so by restrictive
budgeting arrangements. The limit of decentralization must be
where the national interest overrides local considerations. The
FRS has a dual role to protect local communities through its IRMP
but a national role to protect the state during widespread adverse
events or threats to the security of UK plc. The FRS responds
to the impacts of climate change and terrorism threat—there
must therefore be clear direction from Government to put in place,
and pay for, the arrangements necessary to address this national
requirement.
4. If local integration and redesign of public
services is to be achieved (the tenet of Total Place) then there
must be the appropriate freedoms and flexibilities for each individual
service to do things very differently. FRS's have long campaigned
for the same powers as other local authorities, including now
the Power of General Competence, to enable them to freely take
on additional responsibilities or commission out to others as
the local circumstances warrant.
5. True localism has to start with a true appetite
in Whitehall. There is little point in trying to resolve issues
of responsibility and duplication locally if the structures above
will not allow the flexibility. Joined up central Government departments
is a fundamental prerequisite of joined up local services to ensure
there is a corresponding holistic view of public services at the
local and national levels.
THE CHIEF
FIRE OFFICERS
ASSOCIATION
6. The Chief Fire Officers Association (CFOA)
is a professional membership association and a registered charity.
CFOA members are drawn from all UK Fire & Rescue Services
representing the senior executives and managers of the Service.
Through the work of its members the Association supports the Fire
and Rescue Services of the UK in its aspiration to protect the
communities they serve and to continue to improve the overall
performance of the fire sector. CFOA provides professional and
technical advice to inform national fire policy.
THE SUBMITTER
7. Susan Johnson OBE was elected to the CFOA
Board in 2009 with responsibilities for strategy, policy and guidance
relating to performance improvement, resources, governance and
statutory responsibilities as they affect the fire sector. Susan
is Chief Executive of County Durham and Darlington Fire &
Rescue Service, appointed in 2005, prior to which she spent a
number of years working at strategic levels in the private and
public sectors.
DETAILED RESPONSE
The extent to which decentralisation leads to
more effective public service delivery; and what the limits are,
or should be, of localism
8. The Fire and Rescue Service (FRS) is a very
local community based service with facilities in virtually every
locality in the UK, including rural communities, whilst providing
a national civil resilience capability. This places the FRS in
a unique position as a public agency able to deploy, in a co-ordinate
way, into local areas whilst being able to deploy specialists
and other resources across boundaries should the emergency require
it.
9. Since the abolition of national standards
of fire cover, the former centralist approach, FRS's have been
better able to provide more effective local solutions to match
local risks and needs. The approach to risk management has led
to very local solutions and integrated risk management plans (Imp's)
drive the allocation of resources to risk through a consultative,
evidenced based process.
10. IRMP's have also led to improved community
outcomes and stronger partnership working. There is evidence that
by focusing on local communities and providing encouragement—through
grant and reward funding such as Local Area Agreements—there
is improved partnership working with tangible examples of innovative
joined up working directed at local priorities. However, there
are limitations on the extent to which decentralization delivers
benefits to citizens:
(a) There is a risk of widespread re-inventing
of wheels, with local accountability transcending the common sense
approach to sharing across boundaries. There is an optimum size
for efficiency which is not the same as operating every service
as a local fiefdom.
(b) The overhead cost, particularly logistics,
administration and management, in the FRS is disproportionate
to the size of the service. Smaller Services are still faced with
disproportionate corporate costs because they need to comply with
the mass of legislation and regulation—health and safety,
employment legislation, data protection, human rights—which
all come with an administrative layer. No one parliamentary term
can dismantle or rationalize this body of legislation to ease
the burden on smaller services.
(c) Disaggregating service delivery to a multitude
of local areas runs the risk of service fragmentation, duplication,
protectionism and unnecessary customization. However, there is
an opportunity to make better use of land and buildings owned
by public services which was evidenced through the Total Place
pilots.
(d) The limit of decentralization must be where
the national interest overrides local considerations. The FRS
has a dual role to protect local communities through its IRMP
but a national role to protect the state during widespread adverse
events or threats to the security of UK plc. The FRS responds
to the impacts of climate change and terrorism threat—there
must therefore be clear direction from Government to put in place,
and pay for, the arrangements necessary to address this national
requirement.
(e) It is doubtful whether citizens in local
areas either consider the threats to the nation when they are
thinking about their local services or expect their locally elected
politicians to have regard to this.
(f) There is critical need to ensure interoperability
between FRS's, often geographically distant from each other, to
enable an appropriate weight of response to a widespread or protracted
incident (eg Buncefield, Cumbria floods). Localism suggests that
each FRS is accountable to their communities only for those assets
that fit with local need.
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. Place based budgeting can deliver tangible
outcomes for citizens by encouraging partnership working. However,
if local integration and redesign of public services is to be
achieved (the tenet of Total Place) then there must be the appropriate
freedoms and flexibilities for each individual service to do things
very differently. FRS's have long campaigned for the same powers
as other local authorities, including now the Power of General
Competence, to enable them to freely take on responsibilities
or commission out to others as the local circumstances warrant.
12. Many FRS's cover more than one local authority
area but is responsible for ensuring that they have regard to
the life risk across the entire area they cover. Any mechanism
for place budgeting needs to have regard to this.
13. In comparison to other public service, particularly
health, social care and children's services the FRS has to allocate
its resources according to risk, not demand. There is currently
no clarity on how place based budgeting will ensure adequate financial
resources to underpin integrated risk management planning.
14. Place based budgets also need to ensure the
national resilience responsibilities of the FRS are appropriately
resourced. This may be difficult to achieve when partners in a
local area are held to account for the funds spent on their local
areas, not on national civil protection.
15. "Allocation" of any place based
budgets would need to recognize the economic costs of fire and
the monies saved through an effective response service. The prevention
and protection outcomes of the FRS are often difficult to quantify
and yet they have a direct effect on the safety and wellbeing
of local people. One of the key lessons of the Total Place pilot
in the South of Tyne was that collectively investing in prevention
is much more efficient and effective than focusing on response.
FRS's have evidenced this through the previous national indicators
system, reducing deaths and injuries in fires substantially over
many years by investing in prevention activities. Other local
services could learn much from the FRS on how to manage risk through
the right balance of prevention, protection and response.
16. Another learning point from the Total Place
pilots was that the refocusing to prevention does not happen quickly.
The FRS transition to fire prevention did not happen overnight.
Any area based budgeting approach will need to be sustained over
a very long period, and protected from changing political or policy
agendas, in order to realize sustainable community benefits.
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
17. FRS's are governed by Fire Authorities made
up of elected local politicians. Chief Fire Officers/Chief Executives
are already accountable through their Authorities for the effective
and efficient delivery of an emergency service. Integrated Risk
Management Plans provide the accountability of the Authority/Service
to its local areas. This is a strong model of localism and could
offer much to other public services.
18. If Fire Authorities were afforded the same
powers as those given to local authorities (eg Power of General
Competence) this would further extend our reach in partnership
with other local service providers and assist in calling others
to account. It would also facilitate greater innovation, with
FRA's taking a lead, and developing more radical solutions to
service integration.
19. The FRS is a specialist delivery agency
which can and does use its capacity and public image to add value
to wider preventative agendas such youth diversionary activities
and other initiatives aimed at changing behaviours eg road safety.
In carrying out this delivery role we can operate at a number
of spatial levels from the national to the neighbourhood level.
The action which will be necessary on the part
of Whitehall departments to achieve effective decentralised public
service delivery
20. The Chief Fire Officers Association has indicated
through its recent submission into Communities and Local Government,
the freedoms and flexibilities it seeks, on behalf of English
FRS's. Whitehall departments need to:
(a) Join up at the centre in the same way they
expect local services to join up
(b) Policy development and budget setting needs
to move away from siloed priorities, historical precedents and
outdated grant formulas to a much more holistic, cross departmental,
integrated approach. Funding allocations need to encourage and
reward better outcomes for local citizens.
(c) The removal of the inspection and regulation
regime and the consequent data burden, whilst welcome, has not
gone far enough to ensure flexibility and freedom to act at a
local level. National prescription for locally elected police
commissioners is an example.
(d) The current dialogue with CLG officials in relation to
the fire sector taking responsibility for what must remain as
national functions is welcome. The CFOA/LG Group partnership is
confident that they can deliver what the sector requires only
if there is the funding to underpin it. Whitehall moves
to decentralize cannot come with an expectation that what needs
to be done at a national level (to ensure consistency, interoperability,
resilience, etc) is to be funded from the local taxpayer.
(e) Clarity is needed on what stays within the
responsibility and accountability of Ministers during and after
the transition to localism. Ministers will require assurance that
national interests are protected—eg adequate measures to
counter terrorism, adequate protection of critical national infrastructure.
What the parameters of that assurance are needs to be clearly
articulated.
(f) There is an opportunity for Government to
examine the advantages and disadvantages of greater integration
between emergency services, particularly fire and ambulance, via
a review and to determine the optimum way to manage these at a
local level.
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
21. One of the tenets of the Big Society and
localism is that public services can be delivered by communities
themselves, thereby achieving greater ownership but also reducing
the cost of these services. Through the Retained Duty System
(RDS), FRS's already achieve these efficiencies, drawing over
one third of its workforce from RDS which crew over half of the
fire stations and fire appliances in the country, typically providing
120 hours of on call cover. RDS staff are fundamentally a part
of the community they serve.
22. However, sustaining the RDS does not come
without investment, particularly in ensuring the health and safety
of operational staff who work in hazardous environments.
23. Decentralisation should not assume that one
spatial configuration of service delivery (eg local authority
area) is more efficient than another (eg regional). Policy prescription
which dictates the right spatial configuration is contradictory
to the policy of efficiency. If government is not prepared to
support the combination of some services through pump priming
or buffering of council tax equalization requirements then it
is unlikely that FRS's will achieve the most efficient "corporate"
size relative to their service delivery. Government needs to encourage
and incentivize local agencies to come together where appropriate
to provide a critical mass so that costs can be driven down.
This does not necessarily mean that those aspects of the service
that citizens really care about in their local area cannot be
determined, delivered and held to account locally.
24. In the race to cut funding to local services
Government needs to remember its need for national civil protection
and resilience. Longer term planning issues cannot be sacrificed
in the haste to devolve everything to the local level. The recent
example of grit shortages during the severe winter weather provide
a salutary lesson in planning and budget decisions which ignored
the impact of infrequent events on critical local services.
What, if any, arrangements for the oversight of
local authority performance will be necessary to ensure effective
local public service delivery
25. CFOA has been working for many months on
a sector led improvement framework that seeks to put in place
a sector owned suite of performance indicators, range of toolkits
to assist performance assessments, and brokerage of sector support
to assist any FRS looking for good practice, ideas or hands on
assistance to drive continuous improvement. Previous performance
regimes have assumed that one size fits all, have been burdensome
and have resulted in the law of diminishing returns. The sector
must be trusted to develop mechanisms which are fit for purpose,
which respond to the public need to have visibility on how its
service is performing and which takes account of local context.
CFOA welcomes the recent consultation launched by the LG Group
on Self Regulation and Improvement
and will be making a strong contribution to the debate.
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
26. This raises the question of the funding mechanisms
for local public services which are unnecessarily complex and
do not help to explain what is delivered in terms of resilience,
how much it costs and how important it is.
27. The "whole of government accounting"
and the published final accounts produced by public services are
totally unreadable by the layperson—and are increasingly
too complex even for finance professionals. Whilst it is incumbent
on local authorities and other public agencies to present these
in a way which is meaningful to the citizen, the recent national
prescription on how agencies do this, ie publishing every item
of expenditure over £500, could lead to "scrutiny of
the weeds rather than the forest".
October 2010
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