Knight Review of the Fire and Rescue authorities in England

Written evidence from the Chief Fire Officers Association (FRR 09)

Chief Fire Officers Association (CFOA)

1. 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 their 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.

Executive Summary

2. CFOA recognises the significant challenges facing Fire and Rescue Services (FRSs) as they strive to sustain their exceptional performance in delivering their prevention, protection and emergency response services through an extended period of austerity. Any comprehensive and evidence based review can only help to stimulate innovation in service delivery at a time when FRSs are entering the third year of significant funding reductions. Sir Ken Knight’s report on FRS efficiency is therefore timely.

3. CFOA welcomes the overall conclusion of Sir Ken’s report that FRSs have been almost uniquely successful amongst public services in delivering improved outcomes year on year. Halving deaths and injuries from fires over a decade is a record for FRSs to be proud of and for others to envy. It is against this backdrop of achievement that any business case and required investment to deliver fundamental structural change should be considered.

4. CFOA recognises that the analysis in the Report is by necessity superficial given the limited resources available to carry out the review and the timescales for its completion. There are some positive themes and ideas that demand further examination by the professional and political leaders of the FRS. However, there are areas where more substantive analysis would inform FRS transformation programmes and there are omissions and errors which CFOA would wish to highlight to the Committee. It is difficult not to be drawn into the debate on how the data and analysis has been presented in the Report as they are used as the basis to conclude whether FRSs are efficient or not.

5. Whilst the financial savings suggested in the report made for good media soundbites, CFOA believes that these savings should not in any way be used as a basis for further cuts in FRS grant funding. CFOA estimates that the overall reduction in funding to FRSs over the SR2010 is £211m, with the majority of that reduction yet to be reflected in the centrally reported data due to the lag in producing national statistics.

Key Issues

6. It is surprising that the Report suggests there is ‘little relationship between expenditure and outcomes’ when there has been no analysis presented in the report on the full range of outcomes that FRSs deliver. It is also surprising given the author’s extensive experience in the fire and rescue service that he equates reducing incidents with reducing risk and also that he has not acknowledged the required increase in training and competency development as risks change and the frequency of one incident type declines. It would have been helpful for the Report to examine the impact of a substantial reduction in prevention and protection work - taking away the use of ‘latent operational capacity’ - on risk and emergency incidents. It seems somewhat incongruous that the Report should be suggesting that this work can be removed, or does not represent value for money, at a time when other public services are being heavily criticised for their lack of focus on prevention.

7. The Report takes a narrow view of efficiency, using only expenditure per head of population to assess how efficient one FRS is relative to another. This approach fails to acknowledge the value to society and the reduced pressure on other public services due to the wide range of outcomes that FRSs deliver, particularly in our prevention and protection work. The use of traditional metrics that focus on outputs is somewhat outdated. Perhaps a more rounded view of Value for Money, which looks at a wider range of factors around economy, efficiency and effectiveness would have been a better starting point as this would have avoided the very narrow metric approach that has been used - which is at best erroneous and at worst used to inform incorrect conclusions based on a single measure. CFOA is working with sector leaders to develop a much more meaningful suite of indicators to measure our overall efficiency and to support the type of benchmarking that sparks innovation. CFOA is also leading the way in developing a social impact model that quantifies the leverage from every pound spent on the FRS, with initial work suggesting a £6bn return from the £2bn that FRSs spend.

8. The case studies presented in the Report serve to illustrate the breadth of innovation already taking place in many FRSs as they reconfigure their reducing resources to manage the risks in their communities. Whilst the Report has stimulated debate there is limited fresh thinking and it has not drawn upon relevant parallels from other sectors.

9. Sir Ken acknowledges that the possible future operating models set out in section 5 of the report would involve ‘upheaval’ in fire and rescue authorities and whilst he suggests that the ‘gains could be considerable’ CFOA would have welcomed a much deeper analysis of the costs, benefits, community impact assessment, risk assessment and deliverability of the various options put forward.

10. The financial analysis in the report does not take into account the efficiencies and savings that have been delivered since 2011/12. The greatest reduction in central grant funding has occurred over the 2011/14 period with a consequent reduction in firefighter numbers. The data underpinning the headline financial assessment of possible savings (£196m) is based upon figures which have been adjusted to reflect international accounting standards. They are not the same figures which the Treasury uses to determine the ‘cash’ funding for fire. No savings estimate for the public finances could be based on this form of calculation and it is not a true representation of the funding invested in local fire and rescue service delivery.

11. The report suggests that the variance in expenditure across FRSs is ‘inexplicable’. For many years, the FRS funding formula, which the Report describes as ‘fair’, is based upon a complex algorithm which takes account of a multitude of factors that impact on community risk. It is based on a basic amount per head of population topped up by an allowance for local risk that takes account of deprivation and major risk sites. It is therefore entirely explicable why expenditure varies across FRSs - it reflects successive governments’ own assessment of the need for different investment based on risk. CFOA echoes Sir Ken’s concern that ‘some authorities would not be able to meet the challenge should substantial further reductions be applied equally across the board’ since the risk pattern does not reduce as the funding does. The same conundrum applies across local government. To suggest that sector leaders need to come up with the solution abdicates Government’s responsibility to ensure a postcode lottery does not determine the quality and level of service people should expect. Any future operating model of the FRS would need to address this.

12. The Report has some notable omissions and CFOA would ask the Select Committee to examine these in more detail during the inquiry. These include:

a. No recognition of the resources required to maintain and sustain FRSs contributions to the national resilience capability. CFOA has included a detailed assessment of the funding required to maintain this capability in its submission to the Spending Review 2015/16, a copy of which can be found at http://www.cfoa.org.uk/15321. In summary, the assessment is based on the national planning assumptions and the resources needed to respond to four simultaneous Critical National Infrastructure incidents. CFOA estimates that the staff costs required to ensure FRSs are able to deliver a national resilience response, whilst continuing to provide local operational response and other statutory duties, is £2.155bn compared to the £1.674bn that is currently spent on staff costs in English FRSs.

b. A more considered examination of national resilience requirements could have led Sir Ken to draw conclusions on the Government’s risk appetite as we approach the 2015/16 Spending Review. If there are further substantial reductions in firefighter capacity the national response to major prolonged or widespread incidents will undoubtedly be adversely affected.

c. Detailed analysis over many years has identified that those most at risk of death or injury in a fire are usually at risk in other ways - the elderly, those with physical or mental disability, those with substance abuse problems, troubled families. CFOA has called for a thorough review of efficiency in these upstream prevention activities. Whilst Sir Ken’s report criticises ‘siloism’ this review of FRS efficiency has taken place in a silo and has failed to consider public safety as an holistic system. The overall context - compounding impacts of the extensive changes in public services, local priorities reflected in integrated risk management plans, public and national Government expectations on the Service - could have provided a richer picture of the efficiency challenge that FRSs face.

d. In light of recent inquests and legal trials linked to firefighter fatalities there is little reference to maintaining firefighter safety, particularly through a safe and effective incident command structure. Scale, frequency, hazard variables and spread of incidents determines the necessary safe incident command arrangements - these cannot be determined by striving for the leanest management to staff ratios. Lean does not equal safe.

e. The Report states that ‘little has changed in firefighting technology and techniques over a number of years’ yet Sir Ken does not support the need for a centrally funded research programme. The fire and rescue service has not benefitted from the step changes in technology seen in other public services. For example crime detection rates by police have improved dramatically as a result of national investment in DNA techniques and forensic science.

13. One of the major proposals in the Report is that FRSs should increase the numbers of Retained Duty System personnel by 10%. CFOA’s discussions with analysts at DCLG have clarified that the £123m derived from this change is from the consequent reduction in wholetime firefighters. The 10% RDS substitution assumes that there would be a corresponding ‘one for one’ result in outcomes. This is not the case. In most FRSs wholetime operational staff deliver a significant workload outside their response function, thereby helping to drive down incidents and mitigate risk. RDS staff typically give a few hours a week for required training and competency development and then provide only response cover on an ‘on call’ basis. The majority of their productive time is spent delivering outcomes for their primary employer. Appliance availability differs markedly between RDS and wholetime which means FRSs need to be very sophisticated in their resource management to assure their emergency response provision. A simplistic ‘one for one’ swap therefore does little to advance the debate on alternative staffing models. The churn of RDS staff, with the average length of service estimated at four years, gives rise to significant additional recruitment and training costs.

14. The Review could have explored the true net savings from moving to a greater number of RDS staff by examining the cost of replacing the work that wholetime firefighters do when they are not responding. Integrated Risk Management plans aim to put in place the right balance of prevention, protection and response arrangements to mitigate risks and threats. FRSs now use very sophisticated modelling techniques to determine resource deployment to meet the priorities in the IRMP. Sir George Bain was emphatic in his support of the use of IRMPs to save and protect life. Whilst the Review would have gained greater credibility if more time had been spent to refine these arguments, there is however great value in exploring the benefits, risks and efficiencies of different staffing models from beyond the fire and rescue sector. CFOA will be working with FRSs to consider their potential use of these models in our sector, for example drawing upon the MOD’s Total Support Workforce model.

15. One of the future operating models proposed in the Report is to remove stand alone fire authorities and to ensure that funding for fire and rescue is contested locally alongside other local priorities. Many Chief Officers running fire and rescue services from within County Councils (County Brigades) have commented that they will struggle to assure the operational viability of their Service as the demands placed on adult and social care budgets continue to outstrip the funding available. Councillors are faced with impossible choices and there are no winners, just losers. A Chief Fire Officer’s primary function is to assure a safe and effective emergency response - something which regular questionnaires on business continuity sent from the Chief Fire and Rescue Adviser recognises. An emergency service should not be something that is locally contested when funding is being substantially cut. There is a danger that the decision on whether to maintain investment in an emergency response service becomes one based on the probability of incidents occurring rather than one of the risk to communities.

16. The Report acknowledges the extensive support provided to FRSs through CFOA and the mechanisms we use to facilitate the sharing, and adoption, of good practice and sector led improvement such as Operational Assessment and peer challenge. This is hugely valued by our members and will increase in the future as we strive for continuous improvement so that we are better able to manage risk in our communities. It would have been helpful for Sir Ken to expand on the barriers for FRSs in adopting the learning, particularly as they relate to adapting to local circumstances.

Suggested questions to Sir Ken Knight

17. What were the constraints he experienced in introducing different staffing models, particularly more Retained Duty System staff, whilst he was Chief Fire Officer in West Midlands and the Fire Commissioner in London?

18. To what extent does he feel that the FRS focus on safe systems of work for firefighters constrain their appetite to reduce operational management posts?

19. How could FRSs be more efficient in meeting their national resilience capability responsibilities whilst sustaining local resources aligned to local risk.

20. Given the continuing economic and financial challenges the country is facing which future operating model for the FRS does Sir Ken feel would deliver the most efficiency savings whilst maintaining the high level of public trust and confidence in the FRS?

21. What barriers does central Government need to remove to allow greater FRS efficiency?

22. What measures do you think are necessary, both centrally and locally, to increase ‘on call’ or RDS staff given the many reviews of the retained duty systems that have highlighted the challenges of recruitment, retention and willingness of employers to release staff?

Key areas for consideration by Government

23. CFOA provided a comprehensive submission into the Efficiency Review and is pleased that some of the recommendations have been included in Sir Ken’s report. The following are areas which CFOA would ask Government to consider in its response to the Report.

a) CFOA is calling on the Minister and officials within DCLG to work with CFOA as we draw together a new vision and core purpose for the FRS, ensuring congruence with funding, resourcing and public and government expectation. Structural reorganisation should not come before this important definition of purpose.

b) To maximise the value of the Review any mechanism or governance arrangements established to support FRSs to take forward the Review’s recommendations should augment the support already provided through CFOA.

c) Ministers need to conduct their own risk assessments and be aware of their appetite for risk as resources and resilience are reduced as a result of the seismic changes in UK public policy and the risks that these present for FRSs and their communities.

d) Any future structural changes should take account of the wider outcomes that FRSs deliver and the impact that FRS prevention, protection and response work has on society.

e) CFOA would suggest that an efficiency review is needed in upstream activity particularly in reducing smoking, drug rehabilitation, road safety, the use of sprinklers in the built environment and care in the home

f) CFOA suggests that a thorough, independent, evidenced research project to investigate the optimum size of an FRS would inform the ongoing debate on FRS efficiency.

g) CFOA suggests that the time is right for a robust independent research project to examine the opportunities, risks, barriers and efficiency gains or otherwise of closer integration between the emergency services

h) CFOA would suggest an open, wide ranging and evidenced debate with all stakeholders on which governance model presents the optimum opportunity to deliver sustainable efficiency improvements in the future

i) Our collective efficiency as a group of FRSs and our contribution to national resilience should be considered to assess the value for money that is achieved for the nation as a whole when the circumstances require it.

j) CFOA suggests that Government urgently reviews the financial barriers to FRA combinations and provide financial assistance to those Authorities that wish to combine.

k) Government should do more to require other public agencies to share data with FRSs to enable Services to improve the targeting of prevention activities.

l) We suggest that Government should do more to remove interdepartmental barriers to FRS efficiency.

m) CFOA suggests that further research is required to determine the extent to which response times are a factor in minimising the risk of death or serious injury.

n) CFOA calls upon Government to address the lack of a nationally driven research programme that is well funded, to underpin the development of new technologies.

o) CFOA believes that the national machinery for both pay bargaining and dispute resolution is cumbersome, time consuming and outdated.

June 2013