Councillor Ken Thornber CBE

9 October 2008

Leader of Hampshire County Council

Policing Green Paper Consultation Responses

Police Reform Unit

6th Floor, Fry Building

2 Marsham Street



The Castle, Winchester

Hampshire SO23 8UJ

Telephone 01962 847750

Fax 01962 845969


Dear Sir or Madam,

Hampshire County Council Response to the Policing Green Paper, From the Neighbourhood to the National: policing our communities together

Hampshire County Council welcomes the opportunity to respond to the Policing Green Paper. We have grave concerns about some of the proposals in the Green Paper, particularly for the creation of a new tier of elected Members and the lack of emphasis on partnership working.

The proposals for elected Crime and Policing Representatives are inappropriate. Hampshire County Council think any Crime and Policing Representatives, if they are indeed required, should be nominated by local government from a pool of Members from district, county and unitary levels. The position of Crime and Policing Representatives would be open to abuse, attracting those with a vested interest or those standing with damaging and competing mandates. It is believed that overall there will be a negative effect on voter turnout.

We are also dissatisfied with the lack of recognition for the importance of partnership working within the Green Paper. The Green Paper lacks knowledge of the local government landscape, neglecting a narrative about Local Area Agreements or Comprehensive Area Assessments. We also regret that permanent funding for Police Community Support Officers is not assured.

Our full response to the consultation questions is appended.

Yours sincerely

Ken Thornber


Appendix 1: Hampshire County Council response to the consultation questions


How can we best ensure that neighbourhood policing teams can hear from as many people locally as possible in shaping their plans?


Hampshire Constabulary officers and Hampshire County Council's own Accredited Community Safety Officers (ACSOs) already speak to local residents on a daily basis when on foot patrol. Consultation also takes place at regular police surgeries and at resident meetings. It is essential that these services remain joined up and cross local government boundaries. For instance, strategic and operational links across parish, district and county councils will need to be considered, informed by the use of crime mapping sites such as Hampshire's Crime and Disorder Data Information Exchange (CADDIE).


What is the most effective means of encouraging customer service in the police?


This is a technical matter for the police and the Police Authority.


Given the core role of PCSOs - which is one of high visibility patrol, community engagement and problem solving - do PCSOs have the right powers to enable them to do their job?


Funding for PCSOs should be made permanent. Ring fenced funding for three years creates problems at the end of the funding period. Without permanent funding either local tax payers must pay for the PCSO service or it will be likely that PCSOs will disappear altogether.

It is disappointing that the Green Paper does not make any direct mention of ACSOs. In Hampshire, our ACSO service is seen by Hampshire Constabulary as very much part of the "police extended family", as evidenced by joint tasking arrangements and some shared communications systems. The ACSOs have effective powers to protect our residents from anti social behaviour, underage drinking, littering and fly tipping.


How can we ensure that police authorities and local authorities everywhere cooperate in tackling local people's priorities - including ensuring that the local pledge is delivered everywhere?


Policing does not occur in isolation; it is influenced by many other local factors, many of which are tackled by established local partnerships. It is disappointing that the Green Paper does not seem to share this view. Greater emphasis should be placed on Local Area Agreements (LAAs) and Comprehensive Area Assessment (CAA) processes through an enhanced narrative about the value of partnership working.

More thought is required about how decision-making and partnerships to achieve the local pledge will work in two-tier areas. The policing pledge places tough demands on police forces and local authorities including significant resource implications. It should be recognised that the response by local authorities will not necessarily be the same across all areas.


Under these proposals police authorities will have a majority of directly elected members, complemented by representation from local councils and independent members. What is the right balance between local council representation and independent members?


The creation of directly elected Crime and Policing Representatives will create a damaging parallel of democratically elected posts. They will create competing mandates where local governments will be forced to compete against and vote against one another. This will mean that taking action will be more difficult and increase the possibility of buck-passing and the sensationalist apportionment of blame. Therefore progress already made with partnership and enhanced two-tier working, particularly in relation to the delivery of Local Area Agreement targets, will be undermined.

There are no proposals for a selection process for candidates. This could allow those with a partial or single-issue mandate to be elected. Such representation could have a discriminatory effect on minority groups. A Crime and Policing Representative may stand against a political party on a platform against gypsies and travellers, for example. This would set local government, with its responsibilities under equality duties, on a direct collision course with Crime and Policing Representatives.

Significant financial and bureaucratic burdens will be placed on Police Authorities to organise and hold new elections and to administer the Community Safety Funds.

The right balance for accountability will be when local government elected Member representatives have a majority, a clear mandate and decide the budget. Under the current proposals these powers will be lost. It is essential that public trust and confidence in the police and Police Authorities is maintained.

Crime and Policing representatives are not the only option for the perceived need to improve Police Authority accountability. Other options have been suggested, for example, Conservative Party views of Directly Elected Police Commissioners.


To what extent might police authorities be able to allocate part of their budgets by participatory budgeting?


Hampshire County Council thinks that unless the County Council has complete autonomy over its budgets participatory budgeting will be meaningless. Without this autonomy, participatory budgeting is tokenistic and involves very small sums of money siphoned from other budgets.

Government needs to tie participatory budgeting closer to local authorities if it is to be introduced. It is the role of local government to address the needs of the area and therefore should not be compromised by strong community, often issue-based, action. Connections between communities and local government should be utilised, not bypassed.


What other community safety budgets do you think might be suitable to be allocated in this way?


In accordance with the above views, Hampshire County Council does not think any other budgets should be allocated according to participatory budgeting.


Do you consider the creation of the Communities Safety Fund to be the best way to use the money that currently makes up the BCU fund?


Like the Local Government Association, Hampshire County Council is concerned that given the self-selective nature of Crime and Policing Representatives the greater number of resources allocated for them to spend could run counter to agreed local priorities, result in preferential, one off-schemes or projects and risk public credibility.

It is also unclear how the government intend the Community Safety Fund to be complementary to the Area Based Grant.


How might the Councillor Calls for Action be best used to complement the broader changes to local accountability arrangements for policing?


A right to Councillor Calls for Action is accepted but it must be recognised that this right comes with responsibilities. If the Councillor Calls for Action system is to be manageable then it needs to be apolitical, directed to the appropriate accountable body (this is crucial for two-tier authorities), proportionate and non-vexatious. Guides will be required to ensure that not only are referrals to scrutiny committees properly evidenced and embedded within the community but also provide local government with criteria for managing planned and unplanned work.

At present, the government's thinking on the operation and parameters of the Councillor Calls for Action is unclear. In relation to Crime and Policing Representatives it will quickly become evident that they are not invested with enough authority to be representative across broader issues for which local government is responsible, even if they are able to make Councillor Calls for Action. A number of questions require answers: how will the robustness of the governance be tested? How will an appropriate balance be secured between local government bodies and Crime and Policing Representatives? The role and functions of Crime and Policing Representatives must be clear before connections to Councillor Calls for Action are designed.


How can we best involve frontline officers and staff in designing more effective and less bureaucratic processes?


Local government has many examples of good practice in the involvement of frontline officers in the service design and improvement which may be of interest to police and Police Authorities. For example, Hampshire County Council's ACSOs have adopted a communication facility, Airwaves, which could be of interest to police forces. Similarly, Hampshire Constabulary are considering adopting electronic incident recording systems which are used by ACSO's. These examples illustrate the value of partnerships for innovative and effective joint working.


How can we ensure that new forms of bureaucracy do not replace those that we are committed to reducing?


It is not clear from the proposals how a reduction of national targets will be achieved or how it will assist the reduction in bureaucracy to gain more police out on the streets.


How best, together, can we tackle the risk aversion that Sir Ronnie Flanagan identified?


This is a technical matter for the police and the Police Authority.


How can we best change the operation of Senior Appointments Panel to make it more proactive in succession planning and appointments, with greater strategic input into leadership development?


This is a technical matter for the police and the Police Authority.


How should a scrutiny gateway for the renewal of fixed term appointments work?


This is a technical matter for the police and the Police Authority.


What is needed to recognise that it can be right for chief officers to leave a force before the expiration of their contract because that is best way forward for the individual or for the organisation?


This is a technical matter for the police and the Police Authority.


How can we establish better succession mechanisms, including in poor performing forces?


This is a technical matter for the police and the Police Authority.


The government would also appreciate views on the proposed approach to Regulation 11's provisions on serving in another force as Chief Officer before becoming a Chief Constable.


This is a technical matter for the police and the Police Authority.


The Government would be grateful for initial views on its outline three-year equality, diversity and human rights strategy for the police service.


This is a technical matter for the police and the Police Authority.


The Government would be grateful for views on what impact (positive, negative or none) will the Green Paper proposals have on communities, police officers and staff from diverse backgrounds. This will inform further development of the Equality Impact Assessment for the Green Paper.


Our concerns in relation to the impact of the Green Paper proposals on equality and diversity are:

1) A tightening of powers for police at borders and on the ground has the potential to encourage a return to pre-Stephen Lawrence Enquiry behaviours. This could negatively impact on anyone who was perceived as `different'. It will be important that the lessons of institutional discrimination are learnt and solutions carried forward.

2) Training of officers in equality and diversity issues is essential. This includes knowledge about cultures and faiths and communication in other languages. As well as this, mental health awareness training would help to ensure that officers have an understanding of different types of behaviours.

3) With proposed changes to elected representation a system of checks and balances and recall should be embedded to safeguard against discrimination.

4) The wider use of `Stop and Account' forms could unfairly mitigate against those from Black and Minority Ethnic Communities.

5) Proposals for the quick career progression of those with academic qualifications might impact upon those who come from deprived communities.


Are our proposals for strengthening the National Policing Board and encouraging collective action on the small number of issues that demand national attention right?


This is a technical matter for the police and the Police Authority.


Using the principles we have outlined, what issues should be decided at the national, regional and local level, and who should have responsibility for taking those decisions?


Please refer to our response to Question 26.


In what areas of policing should we give greater freedoms to frontline practitioners to enable them to deliver on local priorities and on seriousness in the most effective and efficient way?


The County Council agrees with the Local Government Association's view that if the government can extend these freedoms and responsibilities to the police, they should look to meet their commitments on devolution of greater freedoms to local governments in a similar fashion.


What more can be done to build upon present policing arrangements to improve the security of our borders?


This is a technical matter for the police and the Police Authority.


If a border policing agency were created, how far should links with local forces and local accountability be preserved?


Links to strategic authorities such as county councils should be created and maintained, as well as with district councils, due to the significance of airports and seaports in large shire areas. The emphasis should be on sharing information. As a matter of good practice, Hampshire County Council has already met with the Border Agency and has agreed to share information.

Established structures and networks such as Drug and Alcohol Action Teams (DAATs) and the Reference Groups (DARGs) that they organise could be important in terms of intelligence gathering.

There will be significant issues regarding the duty to cooperate and sharing information where this relates to matters of national security.

At this hypothetical stage, there are a number of questions which require answers:

    _ A separate force would require a separate accountability structure. Would it be connected to or under the jurisdiction of the Police Authority?

    _ If so, how will this affect the number and type of locally elected representatives?

    _ How is local government to be involved in this new police force?


What are the operational benefits and risks of creating a national police border force as proposed by ACPO?


    Please refer to the above response.


Are there any variations to ACPO's national policing model that could offer greater operational benefits than those currently being delivered under the present arrangements?


The County Council welcomes the proposals regarding criminal justice and Probation as full members of Crime and Disorder Reduction Partnerships.

It is very disappointing that the Green Paper does not place as much emphasis on partnership working within the new national policing model as national government places on local government working in partnership with the police and Police Authorities. Partnership working is not only well-established but it is essential to tackle actual crimes, particularly low level and environmental.

There will also be implications for police and all tiers of local government working in partnership to ensure that the right balance is struck between service satisfaction, reducing the fear of crime and public confidence levels against actual crimes. A more holistic approach to improving public confidence is required.

The proposals for the policing pledge and where partnerships are considered seem to be based on a unitary or urban model which does not take into account county and district structures. More thinking is required about how the proposals will work in two-tier, rural or large shire areas, particularly in relation to impacts on democratic involvement and the alignment of civic and police boundaries.

Greater operational benefit could be achieved by ensuring consistency across inspection regimes which support the area assessment approach. The Audit Commission's consultation on the CAA suggests that area assessments are supposed to be the only trigger for inspections. Connections to the CAA and the other inspections and audits that all partnerships are subjected to are noticeably absent.


What would be the main costs?


Greater partnership working and collaboration on commissioning, for example, could save money. A variation to the proposals for the National Police Improvement Agency could be to allow the body to be responsible for knowledge transfer and data-sharing as well as Information Technology. Joint commissioning with local government could offer greater value for money in these areas.


Will structural reform be required?


We have no comments on this.