Appendix A

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18 January 2008

19 September 2003

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 Communities for Local Government Fire and Rescue Service Equality and Diversity Strategy: 2008 - 2018

Thank you for the opportunity to respond to the Equality and Diversity Strategy 2008-2018.

Overall

The Strategy fails to acknowledge progress that is currently being made by Services under the ESLG, by existing stakeholders. Caution is expressed that an implicit message is being delivered that the existing contribution is not valued/beneficial. Further, we would not want to see additional work streams and reporting separate to the ESLG, and whilst the impact assessment suggests no additional resources are required, we believe that there may be opportunity costs and the reality that delivering on any Strategy requires input costs.

Overall the business case for the Strategy emphasises compliance with legislation and the achievement of targets. Our Service is moving forward from this stance, through the ESLG to ensure that equality improves a quality of service delivered.

Our respective feedback is as follows:

Paragraph 1.2

The Strategy could demonstrate closer links with Local Area Agreements and demonstrate how Fire Services contribute to strategies that eliminate anti-social behaviour and our contribution to social cohesion.

Paragraph 1.3

The aspiration to reflect the diversity in the local community needs to be balanced against target setting. More involvement and detail is required to target setting in order to encompass the reality of the demographics balanced against local operational procedures. For example: our Retained Duty System operates out of predominantly white rural areas and restrictions to recruitment reduces the possibility of recruiting from marginalised groups. Hampshire BME population is very small and therefore set targets are not and cannot be reflective of our communities.

Paragraph 2.1

Acknowledgement that very small numbers of staff from minority ethnic backgrounds and small numbers of women operational firefighters points to an issue that is national and therefore best addressed at that level. National campaigns are needed, and would be welcomed, that lead to change in the way the role of the fire-fighter is presented. More research is required on the appeal of the role of a firefighter for women and work on identifying and eliminating the barriers - whether real or perceived, in order to attract more women to this career.

Paragraph 4.4

The commitment to equality and diversity targets should be expressed in the make up of authority membership. We consulted with our authority members and received feedback that does not accord with mainstream values and impetus to support equality and diversity. More support to attract diversity in authority membership and to further develop and educate members would be welcomed.

Paragraph 4.9

We welcome the support and encouragement to improve workforce diversity, especially the awareness raising campaigns. We consider a national response appropriate and the ability to influence at that level highly beneficial. Alongside this we consider that national research could be undertaken to better understand the barriers experienced by minority groups as well as their perceptions of the fire service as a career choice. (As stated for Paragraph 2.1)

We consider Fire Service involvement and engagement in the above, as well as advanced notification of any campaigns, crucial in order that a proactive and consistent response is enabled.

Paragraph 5.2

The issue that 14 out of 48 fire authorities form part of County Councils creates reporting difficulties and consistency. Whilst this is acknowledged within the strategy, no reference to how those difficulties will be overcome is included.

Paragraph 6.4

We consider it essential that the final strategy integrates with existing requirements to achieve ESLG in order to ensure that the strategy is practical and deliverable and does not result in additional work levels/resources.

Impact Assessment

The reality that there are no additional quantified costs for fire authorities as a consequence of good practice contained in the Strategy requires further clarity. Whilst there may be no direct link to quantifiable costs in the delivery or outcomes of the Strategy, there may be unintended opportunity costs as delivering and reporting on the strategy removes focus elsewhere. Additionally, most objectives require some tangible input and this will be translated financially.

Priority 2:

effective service delivery and community engagement (iv) outcomes will include "reduction in fire incidents, deaths and injuries across all communities with emphasis on bringing comparable success rates within vulnerable and hard to reach communities" More clarity is required on how this proposed outcome will be monitored and measured and therefore affording the fire authority the ability to report on progress of this objective. A key feature of ESLG is greater monitoring and use of evidence, and this is required across service delivery and employment practices.

Targets - Paragraph 4.6

a) Targets are more difficult to attain in an environment of a stable and long serving employee base, therefore turnover/stability rates should be factored in as a minimum requirement.

b) Additional requirements to set criteria's and targets to ensure fire authority members reflect the diversity required across all other levels.

c) Targets featured within the Strategy have been based on demographic data from 2001 Census, have the projected impacts of demographic data resulting from the 2011 census been factored in?

d) Eastern European communities are classified under the Ethnic Minority Data as "White - Other". Will this criteria be used against targets for BME in order that this groups' identity can be reported.

e) We would like to see the target for women in operational roles set at the lower base (12%) with scope to progress percentage annually in order that target setting continues to be challenging year on year.

f) We would like to see the target for minority ethnic staff to reach (option 1) the same percentage as the local working population. Additionally that reporting is split between WTS and RDS Stations in order to establish the impact of recruitment restrictions in rural/RDS stations.

g) The very low minority ethnic working age population option would work for our outlying RDS areas.

h) Parity in rates of retention and progression between minority ethnic and white employees and between men and women would be relevant if established as a percentage base.

i) Overall we prefer to see measurement on the application process as opposed to workforce establishments.

Priority 5

On what basis will performance against the National Strategy be evaluated and how will fire authorities be required to report against the Strategy that is different to the ESLG.

We hope that our response is helpful and we look forward to receiving details of the outcome of the consultation in due course.

Yours sincerely

Chairman

Hampshire Fire and Rescue Authority