cel/Secretarial/WP/Corporate/HFRA/HFRA 13 02 08 New National Framework 2008-11Error! Bookmark not defined.

11 January 2007

Appendix A

MC/cel/CO/W/C/National Framework - HFRA Response

Error! Bookmark not defined.January 2007

Talia Watson (National Framework)

Fire & Resilience Policy Division

Communities & Local Government

Zone J/10 Eland House

London

SW1E 5DU

Dear Ms Watson

Hampshire Fire and Rescue Authority's Response to the Fire and Rescue Service National Framework 2008/11

Can I open by thanking you for the opportunity to respond to the draft National Framework. Hampshire, as an ambitious and forward thinking Fire and Rescue Authority, is keen to work with government to develop a set of clear expectations for the fire and rescue service which provides both clarity, direction and inspiration.

Whilst acknowledging your set of questions, we prefer to respond by setting out a number of general observations and then responding to detailed points in each chapter.

Firstly, the Authority welcomes the fact that the National Framework will cover 2008/11 with a review being undertaken in year two. We believe that with the increasing trend for three year IRMPs and underpinning three year financial plans, the National Framework should align with these. We also note that the document takes a more strategic approach and is less prescriptive. We believe this to be a welcome change.

The Authority is also pleased to note that the draft Framework seeks to reflect the general principles of the CLG, CFOA, LGA shared 10 Year Vision for the Service. The commitment to a Service provided locally, that meets and reflects the needs of its community, is something which we would wholeheartedly support.

We do believe, however, that the Framework should be driving that vision rather than just being reflective of it. The draft document at present fails to achieve that ambition and in many ways says very little new about the Service of the future.

It is surprising and somewhat disappointing that the draft Framework is silent on fire and rescue authorities' current and potential role in environmental and sustainability issues. Apart from just a few references to 'protecting the environment' (essentially from the fire risk and heritage protection perspectives), there is little acknowledgement or encouragement of the contribution and positive actions that authorities could and should take to: (a) promote prevention and protection measures from a wider environmental perspective; and (b) reduce their own carbon footprints as responsible, high-profile, public sector organisations.

We would also urge government to be clear about its future intentions for Regional Management Boards. We are unsure if their role is as set out in previous Framework documents. At present it would appear they are expected to take on a fire resilience co-ordinating role even though they have no responsibility under the Civil Contingencies Act.

Chapter 1: Prevention, Protection and Response

1.4 The Authority is concerned that in moving towards a Regional Control Centre (RCC) and a resource deployment model that is regionally based, the obligations that fall to the Fire and Rescue Authority and the Chief Fire Officer, under the Fire and Rescue Services Act, are not compromised. For instance, 1.4 refers to the nearest resource mobilisation. This will have an impact on where fire stations are located, meaning that they can better serve communities in other fire and rescue authorities which may, or may not, be in the same region. Unless there are Section 16 arrangements in place, the default would be for the providing Service to use their resources by quirk of geography, rather than by conscious consent.

This situation could be amplified in relation to much more sparse specialist resources which could potentially service whole swathes of another fire and rescue authority's area without the owning authority's consent.

Bullet point 5 in 2.9 further compounds this as it effectively takes away any local control over the use of resources that are provided and funded by fire and rescue authorities. We consider this a significant erosion of sovereignty and would prevent CFOs meeting their obligations under the Fire and Rescue Services Act.

1.5 This Authority's experience is that our effectiveness is at its optimum when prevention, protection and response activities are integrated rather than just interacting. We believe that government should be advocating a more integrated approach and providing examples of such best practise.

1.6 Whilst we accept the value of the Fire Service Emergency Cover toolkit (FSEC) in identifying risk and deployment of resources, we would not see this as the only valid tool available. Were RCC mobilising to be based purely on FSEC data and mobilising, this would remove the flexibility and sophistication currently operating within IRMPs. As government intends to continue to support the local development of IRMPs, we would want some assurance that this would not be negated by a single model of mobilisation within RCCs.

1.7 We believe government's support in relation to the Home Fire Safety Checks initiative is to be applauded. This Authority, with many others, has capitalised on this support and in many cases has been able to lever more funding through local partnerships. The funding has made a significant positive impact on home safety across Hampshire. We believe that lessons can be learnt from this experience and would advocate government undertaking a similar funding initiative around reducing deaths and serious injuries caused by road traffic collisions.

1.13 Whilst it is recognised that sprinklers are only one element in achieving a reduction in risk, it is a significant factor. We believe government's approach to sprinklers needs to be more consistent with the recent guidance for protection of schools. This sets a clearer and more positive position on the use of sprinklers as a means of building protection.

1.20 Reference is made to the Fire Research Academy but we are unaware of any intention here in relation to implementation, funding and governance. It is important that this paragraph clearly states what government's intention is for the establishment and operation of this body.

1.21 We would strongly urge that the Incident Reporting System (IRS) includes collection of diversity monitoring data beyond fire incidents (as is currently proposed). Achievement of Local Government Equality Standard Level 3 requires authorities to have installed comprehensive monitoring systems. It is extremely disappointing that the current IRS proposal does not meet this requirement.

We also consider that as priority 2 objective IV of the draft National Equality and Diversity Strategy calls for comparable success rates in terms of risk reduction for vulnerable and hard to reach groups, it is important that we have a nationally consistent monitoring system. We believe the IRS would provide that mechanism for providing comparable, nationally validated data which would assist fire and rescue service to achieve this requirement.

Chapter 2: Resilience

2.7 We consider that this would be extremely difficult to quantify across all fire and rescue authorities, which would be in different stages of replacement and renewal, with much of the cost being revenue contribution to capital across 25 years.

2.9 In terms of the requirements falling to the Authority (bullet point 7), Hampshire can only complete its defined tasks where project partners meet their obligations. In relation to bullet point 5, clearly this Authority would wish to be party to a national agreement so long as this does not constrain its own legal obligations under the Fire and Rescue Services Act.

2.10 The Firelink project unlike FireControl has been hampered by a lack of clear dialogue between the main parties. That has caused confusion and misinformation in terms of cost, timescales and outcomes. As such, there needs to be a commitment to improving this within the section.

2.14 Whilst welcoming the government's financial commitment to the New Dimensions programme, we are keen that funding for such specific assets remains transparent and as such, do not believe it should be subsumed with the Revenue Support Grant.

2.17 Having played a part in the recent national responses in South Yorkshire, Gloucestershire and Warwickshire, we would strongly advocate that the Framework makes reference to the need for national incident command procedures. We believe this is an essential element of ensuring we maintain long term sustainability and ensure those resources can be used to best effect.

2.19 We believe that the role of the Emergency Information Support Group (EISG) and its relationship to the Fire and Rescue Service National Co-ordination Centre (FRSNCC) needs to be clearly articulated.

Chapter 3: Diversity and Workforce

A significant proportion of the this chapter is dedicated to Equality and Diversity. Whilst this is important and a key policy area, there is a separate National Strategy currently out for consultation on this area. As the responses on that aspect of the document will cover the same ground, the Authority will address those issues in response to that document. What it does appear to then result in, is that the remaining parts of the HR agenda are constrained to a more limited discussion and both the scope and ambition within it seems limited. Therefore, it is on those elements (from paragraph 3.12 Workforce Planning onwards) that this response will concentrate. To do otherwise, would pre-empt or undermine the current full and open consultation on the draft National Framework for Equality and Diversity.

3.12 It would have been helpful to indicate some form of vision as to what that might look like, how it might be facilitated, the support that would be provided centrally and clarity of the role of RMBs. Other areas of the public sector have embraced this as a key tool to support the change agenda, modernisation and continuous improvement.

3.14 The concept of having a nationally accredited standard selection test is well accepted. However, the detail of the requirements and the elements that make it up do need further refinement. Additionally, as the EIA process has not been completed there remain risks that what is being done at present may have an adverse and unintended detrimental effect on our ability to attract talent from across all areas of the community. Has the process been fully exploited to ensure that this is the case?

3.15 The ADC process majors on the development aspect. This is perhaps an opportunity lost, as to use this more robustly as an assessment tool to identify people across all fire and rescue services, against the same standards, would be potentially a tool to enable ease of movement across organisational boundaries. This would be particularly so if they were operated at a regional level in all areas of the country.

3.16 `...RDS recruitment can also help to deliver efficiencies and improve representation of women in operational roles'.

This is probably accurate for women. Implied within this statement would appear to be an acceptance, by it's omission, that recruitment campaigns centred on the RDS are unlikely to have the same comparative impact on the recruitment of staff from BME backgrounds. If this is the case, the performance measures discussed in the earlier parts of this document and the draft National Framework for Equality and Diversity, should reflect that. Local communities that surround these retained fire stations are microcosms and do not conform to the statistical averages for the county. It is therefore suggested that the targets for RDS staff in respect of E&D performance, are devised and measured separately to those of whole time firefighters.

3.17 This is an area of continuous challenge for fire and rescue services. Local campaigns are usually effective to some degree. It is unclear how a joint regional approach would benefit this when the catchment area for staff is within 4 minutes of these fire stations and are quite often, by their nature, remote and in sparsely populated rural areas. However, it would be beneficial for central government to take a lead in a national strategy (noting that the Retained Review Report had a significant number of recommendations for CLG). This might include incentives paid directly to employers who release their employees to attend emergency calls as Retained firefighters, a central co-ordination effort and supporting publicity. The MoD have successfully used this kind of approach with regards to their Reserve Forces, and clearly whilst not on the same scale, this approach could have a significant impact and benefits.

3.18 The retention level for professional firefighters is indeed high. CLG should be aware that the recent changes in tax regulations allowing firefighters to take the lump sum from their pensions benefit and then return to work, does have the potential to improve this further. Furthermore, the increasing awareness of the benefits of extended working lives tied to the Age Discrimination legislation, will also add to that stability in the workforce. Whilst this must be seen as a benefit, it will also have an immediate and longer term affect on the ability of fire and rescue services to improve the proportion of under represented groups within the workforce.

3.20 The IPDS is a good framework. However, its ability to deliver consistency on a national basis should not be over estimated. This is a very general standard. Whilst that is appropriate and provides the framework under which all fire and rescue services can work, it remains generic enough for fire and rescue services to adapt to their local and regional needs. It is the principles that need to be adhered to when implementing, rather than prescriptive procedures.

"Fire and Rescue Authorities must:

· apply IPDS principles to the recruitment, development and progression of all staff;

· use IPDS and the national processes based on it (National Firefighter Selection Tests, subject to final validation, and Assessment and Development Centres) for all Grey and Gold Book staff."

These directives are inevitably going to cost fire and rescue services money in excess of the systems that were in place previously. Both National Firefighter Selection Tests (NFST) and Assessment and Development Centres (ADCs) are considerably more resource intensive than pre-existing methodologies and therefore add to the cost pressures experienced by fire and rescue services. If these are mandatory requirements from CLG, then central government should consider how they can provide funding streams to account for them and thereby reduce the risk that operational service delivery levels will have to be compromised to fund them locally.

Similarly, if these are truly `National', the means to ensure their validity, to maintain standards, to provide accreditation and ongoing development, a national body needs to be in place. Whilst this is also subject to consultation via the proposals for a National Centre of Excellence (CoE), it needs to be stressed that this function should be set at a national level and as such, funded centrally with suitable governance arrangements.

3.24 The Continuous Professional Development for the Retained Duty System has been, and remains, a key challenge for fire and rescue services. The issues of attracting and retaining high quality and dedicated firefighters to work in this way will need continued effort. Support from CLG (as described above) would be valuable in helping local fire and rescue services to achieve this.

3.26 In relation to the second bullet point, it is accepted that this is in part a training and development issue, it also links very closely to the operational areas within the service delivery arms of fire and rescue services. There is also a clear link to the role of the National Advisor within CLG who should be considering these issues on a national basis.

Chapter 4: Governance and Improvement

4.3 We note that whilst Regional Management Boards will have less involvement from now on in the regional control project, but seemingly a greater role in "putting in place effective resilience plans for large scale emergencies", we are unclear how this would be managed given the current requirements under the Civil Contingencies Act with regards to Local and Regional Resilience fora.

We feel it is unnecessary to articulate the need for RMBs to undertake further reviews to achieve efficiencies, we would consider this as part of the normal business planning process.

4.5 Regional Management Boards

Given the Authority's own experiences, we would suggest that the government is most reluctant to enforce a contributor even when the financial and operational advantages are undeniable.

In terms of the performance and assessment regime, we are concerned by the complexity of the intended CAA arrangements and given its focus on examination of both individual authority operation, and multi authority partnerships, we believe it will be vital that the burden of inspection does not become even more onerous.

With regards to the contribution and benefits fire and rescue authorities can bring to such partnerships, we believe central government should do more at a national and departmental level to promote the work and added value of the fire and rescue service.

4.14 Community engagement and involvement

Fire and rescue authorities are well used to consulting stakeholders on their plans. It is a fact, however, that when consulting on any proposals that seek to deliver greater cost-effectiveness - particularly concerning the deployment of response resources - those stakeholders that do become actively engaged are usually unanimous in their opposition to proposals. This is not to suggest that fire and rescue authorities shouldn't do more to engage with their communities. The point is made to emphasise that considerable pressure is frequently put on local elected members by the communities they represent not to change emergency cover - no matter how strong the operational and business cases might be.

4.20 Performance Assessment

We welcome the reduction in national performance indicators, but anticipate that many of the existing Best Value Performance Indicators (BVPIs) will continue to be used as `local' indicators in benchmarking exercises. This assumption appears to be borne out by the reference to the inclusion of: "... an assessment against national and local performance indicators ..." in the section outlining the future CAA process.

Until more details are available on the way CAA will impact on fire and rescue authorities, it would be premature to comment; but, the intention to continue with the Use of Resources and Direction of Travel Assessments as part of CAA provides at least some elements of continuity and consistency against which improvement (or otherwise) can be measured. Great care will need to be taken that the burden of inspection does not become disproportionate.

4.24 Improvement

We welcome the CLG's commitment to continue to support improvement in performance by fire and rescue authorities. However, in proposing to streamline the existing regional improvement partnership arrangements under a single Regional Improvement and Efficiency Partnership (RIEP), we are concerned that the particular needs of fire and rescue authorities might be overshadowed by demands from other areas of local government. We therefore urge the CLG to ensure that during the consultation arrangements with RIEPs, that the improvement and capacity needs of fire and rescue authorities have been fully and properly taken into account.

4.28 Centre of Excellence

We welcome the separate consultation exercise taking place to assess the scope and potential benefits of developing a Centre of Excellence (CoE) and fully support the principle that to work effectively, the CoE must have the full support of all fire and rescue authorities and other stakeholders. As part of the exercise, it will be important to examine the possible overlap in expectations and functions between RMBs (regional collaboration) and a CoE - particularly in respect on shared services, training provision, and procurement. As an Authority we will also want to be convinced that the funding mechanism is fair, equitable and proportionate.

4.31 Chief Fire and Rescue Advisers' Unit

We are somewhat concerned that the function and jurisdiction of the new Chief Fire and Rescue Advisers' Unit is not explained more fully. We would also welcome further explanation as to how this unit will co-ordinate with other bodies such as the Centre of Excellence and the Practitioners' Forum.

4.33 Fire and Rescue Authority Finance

Fire and rescue authorities have responded well to the modernisation agenda, particularly through reinvesting efficiency gains towards prevention and protection activities. The scale of change and improvement has been remarkable over the last three years; but fire and rescue authorities have been reliant on support received through specific grants. The loss of specific grants for prevention and protection activities will put an extra pressure on budgets and, even with the cashable savings that some fire and rescue authorities have managed to achieve, this will make it extremely difficult to contain council tax increases. Hampshire has been successful in delivering its medium-term financial strategy over the last three years which included the aim to keep the average percentage increase in council tax at, or below, the average percentage increase in state pensions. There is little realistic prospect of achieving this over the next three years and the pace of improvement and

modernisation is likely to suffer. It would be helpful to know the details of settlements much earlier so that draft budgets can be prepared with greater confidence prior to our consultation with stakeholders.

4.37 Efficiency

Fire and rescue authorities have demonstrated that they can produce efficiency gains. It must be acknowledged that the potential to deliver significant cashable efficiencies (especially where fire station closures and the redeployment of `response' resources are concerned) can take some time to achieve. Our experience from consultation with the public (on our IRMP proposals) shows that our plans to deliver better value for money through the rationalisation of emergency cover is universally perceived as a cut in services - no matter how convincing and strong the operational and business case might be. To better illustrate and understand the problems we face, and so that the CLG can be in a position to offer help and support to fire and rescue authorities, there would be merit in having representatives from CLG observe public consultation meetings where changes to emergency cover are being proposed.

4.38 Pay

The lack of a national pay formula for firefighters does make it very difficult to forecast with sufficient confidence budget implications for pay inflation. Experience shows that fire and rescue authorities which stick rigidly to government expectations for pay increases (and set budgets on that basis) have subsequently faced severe problems in balancing their budgets when national agreements exceed those expectations.

4.40 Asset Management

We would welcome advice and examples of good practice as soon as possible and whether this will be consistent with Audit Commission expectations.

4.42 National Procurement Strategy for the Fire and Rescue Service and Firebuy

Firebuy is currently struggling to win the confidence of fire and rescue authorities on its ability to deliver substantial savings. We intend to carry out post-implementation reviews of our Firebuy contracts to ensure that predicted savings have actually materialised. These will provide the evidence necessary for any future business case to use contracts outside the national framework agreements. We sincerely hope this will not be the case.

We hope our contribution is helpful and we look forward to a National Framework which we can be proud of.

Yours sincerely

Chairman

Hampshire Fire and Rescue Authority