Knight Review of Fire and Rescue Services

Written evidence from the Fire Service College (FRR 17)

Abstract

The Fire Service College welcomes Sir Ken Knight’s report and its approach of asking searching questions of Fire and Rescue Authorities rather than seeking to impose solutions. The use of anonymised data within the report highlights significant disparities in expenditure and points to the continued need for all leaders in the sector to challenge the status quo and consider new ways of working. There is a clear evidence base in the report that this has been successful in many services and therefore that the dissemination of good practice can benefit others. The College will offer support to Authorities and Services who wish to develop their own responses, providing additional analytical capability and helping to share best-practice amongst services who wish to participate.

The report touches on a number of areas where the College can function effectively as a national centre of expertise in FRS and interoperability training, and this response seeks to highlight opportunities and issues in those areas. In particular, the current over-capacity in UK training assets and the ongoing investment of capital budgets by FRA’s which will increase that over-capacity.

The College is currently undergoing substantial investment in new training and R&D offerings and will seek to ensure its spend in these areas will enable and support FRA’s in delivering some of the efficiencies which Sir Ken highlights as possible. We offer some specific recommendations for action which Ministers, DCLG, FRA’s and the UK services may wish to consider as they seek to formulate and implement their own plans in response to the report.

Context of the report and this response

A core element of Sir Ken’s analysis is that there is a wide variation in spend between Authorities of similar types and with similar risks and demographics, with his input data concentrating on the overall annual operating budget of the authority. We suggest that such a disparity is both predictable and wholly explicable in an environment where the principle frame of reference for annual budget setting is the previous year’s budget rather than any form of inter-authority benchmarking or authoritative "should cost" model. A considerable body of academic business literature addresses this phenomenon [1] . Other literature and much practical business experience points to the need for a more fundamental and objective approach using techniques such a zero based costings, and financial benchmarking. We at the College would want offer help to services to take that more rigorous and self-critical approach. [2]

The first chapter of Sir Ken’s report could, and we suggest should, be viewed as a call to the sector to develop a national benchmarking process. One potential area for improvement in the analysis however is in the accuracy and consistency of input data. During the purchase of the FSC and its initial transformation, we have attempted to compile similar datasets focussed particularly on the training element of authority budgets. It has become clear that almost every Authority calculates its "training" budget in a different way from its peers. Some for instance do not include the costs of full-time uniformed trainers, because they are included elsewhere in an overall "staff" budget. Similarly, at least one county authority does not include the property and facilities management costs of its training centre as these are accounted for in a generalized county "facilities" budget rather than allocated specifically to the fire service. In general, training budgets, if assessed using a fully-absorbed costing methodology [3] , appear to run at between 4% and 6% of overall FRA budgets, but these differences in accounting protocols may allow authorities with otherwise similar risk, demographic and governance arrangements to show superficially a 50% difference in training budget. It is not clear to us, what impact such accounting technicalities may have had on the overall budget numbers submitted to CIPFA and used by the report.

We would be delighted to assist groups of similar authorities, the government or indeed CFOA and the LGA to create a common financial model which would allow more accurate inter-authority benchmarking of the costs of specific service outputs [4] , comparing those benchmarks to wider public sector or commercial norms and providing the analytical support to the production of action plans.

An omission from the report – capital expenditure planning and treatment

The report focuses largely on operational expenditure, though it does discuss the use of capital investment to aid co-location and for spend-to-save programmes [1]

From the College’s perspective, the lack of discussion of assessment and approval processes for capital expenditure is an important omission from the report. We are aware of numerous Authorities currently engaging in substantial capital expenditure on new training facilities, many of which directly duplicate facilities either at the College or within neighbouring Services. Indeed two Services with a common border, each investing in new facilities, have each discussed with us the possibility of our assistance in selling the "spare" capacity which would result from investment, in each case viewing their neighbour as one potential target for such income generation.

When commercial organizations seek to invest capital in new facilities they almost always insist on some form of options analysis, coupled with non-advocate challenge to ensure that the options selection is rigorous and not simply designed to favour the preferred option of the business case originator. [2]

We recommend that those FRA’s without such a rigorous process, might consider implementing one, noting that in doing so, they would render investments more sound and targeted and would generate firmer baselines by which to assess, post-implementation, whether spend-to-save measures have actually delivered promised savings. Options considered should ideally always include the costs, benefits and risks of using existing facilities elsewhere in the UK.

Furthermore, accounting practices around capital expenditure are routinely different to those dealing with operational expenditure. We would suggest that capital investment in training infrastructure is a cost of training delivery and therefore depreciation and amortisation of capital expenditure should be recognized in any analysis of delivery costs. This is particularly pertinent when such facilities are used by ‘trading companies’ set up within an Authority. Such trading companies will wish to demonstrate that they account appropriately on a full cost recovery basis for both their operational and capital assets, in order to avoid downstream legal challenge from third parties.

The role of the College in enabling efficiencies

The College believes that it can play a number of roles in enabling Authorities to generate efficiency improvements. In addition to the analytical and benchmarking capability discussed above we believe the following actions may prove helpful to the fire sector.

Promoting intra-operability, sharing systems and structure

Sir Ken notes [1] some good practices of interoperability and sharing but also that in many obvious cases, it does not happen. We are particularly heartened by his reference to the College as an enabler of interoperability and agree wholeheartedly with his observations about "off-watch" training [2] . The report also features numerous instances of good practice in the sharing of back office systems which are both improving services and delivering savings.

We believe that the "back-office" approach can be extended to the training function, where there is considerable duplication today in development, administration and delivery. Joint-working has the potential both to eliminate waste and to promote common and consistent standards across service borders particularly for cross-border mobilisation and incident command.

We suggest that the development of a model of shared training (development, administration, delivery, accreditation and assurance) can deliver significant savings, improve training standards and increase resilience. It can improve the usage of existing assets (both regional and national), largely negate the need for further capital investment and transform the utilisation of trainers, allowing them to be freed for use in the front-line.

We suggest that joint training in leadership, incident command and specialist skills may not only offer immediate financial efficiencies, by reducing the need to retain expensive local training centres, but will also increase the efficiency of the service as a whole by building mutual understanding between the leadership of individual Authorities and Services and thus facilitating joint-working and best practice sharing.

The College is currently working with a number of Services on a model which both facilitates local joint working, and enables national-joint working for specialized and leadership skills, and would welcome the opportunity to discuss this more widely.

Joint experimentation, test, evaluation

Sir Ken’s report [1] highlights the duplication which occurs between Authorities in the design, specification and procurement of new equipment. We have particularly noted this with regard to new capabilities which may offer transformation in crewing and operational models. For instance, in discussion with two large metropolitan authorities regarding COBRA ColdCut ™ systems, one Service has indicated that they believe it offers a significant benefit to public safety whilst generating efficiencies by allowing smaller, faster response vehicles with smaller crews as part of an overall system of new equipment. The other has indicated they believe it to be hazardous and have no interest in adoption. The two authorities are of similar size, demography and risk profile.

Whilst the College would in no way seek to determine the "correct" view of any such equipment, we believe it can offer an impartial and objective space for joint evaluation by multiple services. We could help to agree joint, criteria for pass or fail between services prior to the start of evaluation and thus avoid duplication of assessment, and facilitate the sharing of best-practice.

We suggest that Authorities should always encourage their professional services to share evaluation with other, similar, potential users and where sensible to seek the assistance of a neutral assessment body to facilitate the process.

Facilitating joint response to public enquiries

Numerous Services have briefed the College that following a public enquiry or similar report with recommendations for the sector as a whole, each will often develop its own individual response in terms of operational guidance, procedures or procurement. We believe there is a role for the College in providing an independent centre to allow joint evaluation of multiple different options under safe, experimental, conditions. In doing so, we would aim to support both CFOA and individual Services in developing response options but also the Fire Protection Association, Building Research Establishment and other bodies in assessing implications for fire safety and engineering.

Retained-duty-system (on-call) training

Sir Ken recognizes the value of on-call firefighters [1] and the savings that might be generated from greater use. Some feedback to the report however [2] questions Services’ ability to recruit and retain on-call staff and there is a perception that 2-3 hours training a week for on-call staff will result in less well trained firefighters than for those on full-time contracts.

We believe that new models of training for on-call firefighters will have a significant effect on not just their skill levels but, critically, on their morale and therefore recruitment and retention. The College is therefore developing an approach which will involve: (a) e-learning, allowing RDS staff to access learning at a time and place that best suits their work patterns, (b) local realistic training, but supplemented by (c) an intense, immersive, crew-based weekend course involving several "incidents" in various stretching scenarios. We believe that such a model will give the on-call firefighter a greater sense of the challenges of the role, particularly in areas where "live" incidents are extremely rare. By focussing the training over a weekend, and ideally combining the training between several services to allow larger simulated incidents, we believe it will be possible to build an esprit-de-corps which will positively influence attitudes to the role.

Whilst such occasional periods of immersive training may be notionally somewhat more expensive than short, weekly, station-based sessions we believe and hope to prove over coming months, that the result will be a more capable on-call workforce, improving safety and saving lives but also that the impacts on recruitment and retention will more than offset the cost, hence driving overall financial efficiency.

Shared or centralised recruit training

Sir Ken notes [1] that recent recruitment freezes may have led to unbalanced Services and that as recruitment restarts, there are economies of scale to be had from joint training. For Services which have done no recent recruiting, such economies may involve the avoidance of significant costs arising from re-creation of a recruit training team and potential associated capital investments.

The College will work with authorities and services to establish if centralized recruit training is viable and further to look at "self-funded" models, whereby potential firefighters fund their own training, independent of an Authority, prior to application for firefighter jobs.

The College recommends that Authorities rigorously assess any plans put to them by their Services to restart local recruit training, asking the questions: (a) could this be done more economically with other Services, (b) could it be done more economically and effectively centrally, with the benefit of national facilities and accreditation and (c) what would it take to implement a "self-funded" model.

Supporting blue light inter-operability

In addition to supporting intra-operability between individual FRS’ the College sees a significant role for itself in supporting improvements in inter-operability between all Cat 1 and Cat 2 responders, and we are encouraged that Sir Ken recognizes us in this role [1] . We aim to substantially develop this service over coming months, particularly in support of JESIP, and plan to make use of some of the redundant building stock at the College to enable major joint training exercises prior to its demolition. We are encouraged that another recent report by Tobias Ellwood also endorses the need for such a capability.

We encourage fire authorities, particularly working with their Local Resilience Forums to understand and build on the findings of JESIP and will be pleased to contribute to any local inter-operability initiatives, sharing broader national perspectives and best-practice as well as provide a location for and facilitate large-scale exercising.

Supporting setting, maintenance and evidencing of standards

The report notes the benefit of common standards to the Service as a whole, in particular in facilitating collaboration [1] and that shared training and exercising can help in building those standards.

We believe that the College should not seek to be a standard setting body, but are keen to support CFOA, other national bodies and where appropriate local groupings of FRS’ in developing, challenging, testing and exercising those standards. In particular, we note that there is no settled model for the hosting and maintenance of National Guidance after 2015 on behalf of CFOA as its custodians. We are keen to offer the College as a host, enabling the close linkage of guidance with training and accreditation and will try to work closely with CFOA, LFB and regional groupings to develop a viable model.

We believe that the College has an important role to play, as it has in previous times, in helping to assure quality, by validating that both local trainers and those seconded to the College, are training against national standards and that assessment approaches converge across Services. In this way, we believe we can provide Authorities and CFO’s with the assurance that their firefighters, those who train their firefighters and those who train the trainers are all operating within the framework set by national bodies, providing an unbroken evidential chain between national standards and local delivery.

Conclusion and recommendations

The Fire Service College warmly welcomes Sir Ken’s report. We support the questions it raises of the sector  and in some areas, particularly relating to training, have detailed evidence to support the disparity he observes between services. We believe the report’s focus on operational efficiencies could be usefully augmented by a focus on efficiency in capital investment.

We are making substantial investments into the offering and infrastructure of the College, and will ensure that investment supports the drive to collaboration, interoperability, national standards and efficiency that Sir Ken envisages.

We believe that the College has an enabling role in the sharing of, and learning from, best practice which Sir Ken endorses. We will be glad to support any Authority or Service seeking to review operational efficiency or investment plans, by providing benchmarks, alternative models and independent analysis.

We recommend that authorities wishing to respond to the report:

· Seek to harmonize their accounting protocols so that like for like comparison of expenditure in particular areas can be made.

· Ensure that major decisions affecting operational or capital spending are accompanied by a thorough review of costed alternative options and by non-advocate challenge. Options considered should always include at least one of collaboration with other Services.

· Consider engaging with the College should they wish explore options for sharing services, either regionally or nationally.

· Recognize that for experimentation, evaluation, training and accreditation, the College is a national asset, supported by private sector investment, and that it will become more valuable, the more it is used.

We thank Sir Ken for his report and stand ready to assist national and local Authorities as they seek to seize the opportunities it represents.

July 2013