Commissioner of Police Submission, 1998

Commissioner of Police Submission

Executive summary

1. This submission is made in response to the Preliminary Draft Report on the Review of Police Administration and Management Structures. In formulating this response, the Commissioner has taken into account the views of staff and his overall responsibilities as Commissioner for the effective and efficient delivery of policing services and overall management of Police.

2. The Commissioner supports the objectives of the Review to streamline management and support services in order to free up resources to improve frontline service delivery and recognises the opportunities presented in the report to achieve this. In particular he accepts the potential for more decentralised and accountable management, the centralisation of support services, a stronger but smaller strategic capability at the centre and the principle of outsourcing some functions (subject to specific exceptions).

3. The Commissioner is concerned, however, at the extent of the proposed changes to existing structures, at both the administrative and management levels, the outsourcing of some of the services proposed and the early timeframes for achieving the recommended savings. He believes that further work is required to either confirm or modify the extent of the recommendations in the report, the savings quantified and the proposed timeframes for their achievement.

4. The Commissioner is also conscious of the tension created between the need for swift implementation of reforms (staff have supported this to reduce uncertainty) and the obligations he has to ensure that the impact of change has minimum effect on standards of service to the public, that staff are treated fairly and that the ethical standards and integrity of the Police are maintained.

5. The Commissioner is seeking confirmation from Government that the savings proposed from the Review are part of the requirement to restructure and produce savings following the completion of INCIS and not in addition to that requirement.

6. The Commissioner notes with appreciation that, subject to this requirement, Government has agreed to reinvest savings from the Review back to policing. Structure

7. The Commissioner supports the concept of a streamlined and strategic Commissioner's Office. Specialist advisers in key performance areas (such as policing policy and development, crime, road safety and crime prevention) in the Commissioner's Office will be accountable for the quality of advice provided by Police to the Minister and Districts. It is District, Area and Station managers who will be accountable for results achieved through service delivery. He believes, however, that proposed cuts to staff are too severe to ensure effective support to Districts, especially in crime, road safety and strategic capability. Further work and consultation is required to establish optimum capability and staff levels in the Commissioner's Office.

8. The Commissioner supports the concept of Service Centres. Whether these services are centralised or decentralised will depend on the nature of the service. Some services may be best decentralised because they need to be close to the external customer; others may be best centralised and consolidated because it is more cost effective to run them out of a centre designed to support multiple points of delivery.

9. The Commissioner supports the principle of disestablishing Regions and reducing the number of Districts but believes there are issues relating to Northland and the greater Auckland area that need to be further considered and worked through as part of the implementation process. Although the Commissioner has noted submissions from the Districts proposed by the Review to be merged, that local identity and the quality of support services are at risk, he observes that operational leadership will still be provided locally in merged districts. It is administrative support that will be centralised. This step is in effect extending the approach already implemented in many other Districts and will free up resources for frontline policing.

10. The Commissioner is also conscious of the need to ensure that support provided by service centres is no less than that provided to Districts today and that restructuring does not result in further administrative burdens on frontline staff.

11. The Commissioner supports the concept that Areas are to be the key service delivery units and will be built around communities of interest. In order that Areas do not become unmanageable in terms of staff numbers and/or geographical size, he believes that the number of Areas is likely to exceed the suggested 48. Overall savings at Inspector rank will also require further analysis so as to take account of specialist expertise, such as investigative skills.

12. The Commissioner supports the principle of a five-level management structure as a means of achieving closer oversight by the Commissioner of service delivery. He recognises, however, that there is likely to be a need for some limited exceptions to this principle, based on ensuring manageable spans of control and adequate supervision of staff. A continuing role for the senior sergeant rank is recognised but the nature and extent within the overall structure may change.

13. The Commissioner supports the need for further consideration of overall resources proposed for Districts and service centres to ensure that cuts to the numbers of administrative support staff in districts do not affect the frontline, and hence overall delivery of policing services.

14. In respect of restructuring, the Commissioner believes that additional flexibility within Police is required in terms of the mix of sworn and nonsworn staff and that potential staff savings should be expressed as a total number of staff rather than attempting a hard and fast sworn and non sworn number. Also that potential savings should be expressed as a range to be targeted rather than a specific number.

15. The Commissioner agrees with the proposal for a National Operations Committee consisting of District Managers and other senior managers. In addition to the role proposed in the draft report, he considers that this group should be a key contributor to national strategy as well as the leadership group to drive strategy through Police. However, he is also in favour of a second management group; one that not only has a strategic focus but also an audit and performance role and with external expertise to assist Police in specialist areas. Further design work is required before the final shape of the Police Executive is established. Outsourcing

16. In principle, the Commissioner supports the outsourcing of support functions currently delivered in-house where such functions meet the recommended criteria, provide a quality service for lower cost, and where appropriate risk management strategies can be put in place.

17. The Commissioner believes, however, that aspects of forensic photography and Search and Rescue are core police functions and should not be outsourced. He also recommends further consideration be given to aspects of the Commercial Vehicle Investigation function which should be retained.

18. The Commissioner considers the time frames identified in the draft report for outsourcing to be too tight in respect of some outsourcing proposals and suggests further consideration of which services fall within the following amended time frames:
    - Phase 1 - up to 30 June 1999
    - Phase 2 - up to 30 June 2000
    - Phase 3 - up to 30 June 2001

19. The Commissioner agrees that an attempt should be made to develop principles that would serve to better define the core responsibilities of the Minister and Commissioner, including changes to the Police Act. Police has noted the proposal for an Advisory Board to the Minister, but believes there are issues to be worked through before such a Board could be implemented. Ministerial direction

20. The Commissioner notes that this proposal is not intended to impinge on the operational independence of Police but to provide a process for resolution in situations where a Minister and Commissioner cannot agree whether a set of facts fall within or outside the Commissioner's independent jurisdiction.

21. On this basis, the Commissioner has no objection in principle to the creation of a formal power of ministerial direction, provided the areas which are not subject to direction and those that may be included in a written direction are clearly specified, and there is a prescribed process to be followed. Police Housing

22. The Commissioner supports the need for police housing in areas where there is no suitable accommodation for staff transferring to either rent or buy and highlights a concern that the targeted houses for sale will not leave sufficient for this purpose. There is justification for a comprehensive review on the number, need and reason for retention of police houses and their role in addressing recruitment and retention problems.

23. In summary, therefore, the Commissioner is committed to achieving the objectives of the Review but is conscious that further work and analysis is required before the exact parameters of review recommendations (staff and savings) can be established and implementation can begin. In the interim projected savings and staff downsizing ought to be expressed as a range of savings rather than a specific target.

24. Overall the Commissioner believes that significant savings can be made from the proposals in the draft report and wants to accept responsibility for the further work required, consultation with staff and implementation of approved proposals. He believes that if these stages are properly managed, Police will emerge stronger and more capable in its core role of reducing crime, the road toll and disorder and improving public safety.

RECOMMENDATIONS

• That an appropriate definition of 'frontline capability' that is more accurate than simply counting sworn staff be developed, and that mechanisms be set in place to monitor and evaluate that capability.

• That there be flexibility for Police to alter the mix of sworn and nonsworn staff in Police to improve operational capability even though this may mean a reduction in overall sworn numbers.

• That further work be carried out to define the extent of staff and dollar savings.

• That Police Regions be disestablished and that the proposed district mergers, with the exception of Northland, proceed. However, the number of Districts should be left flexible between ten and twelve until questions surrounding the wider Auckland area are resolved.

• That there be flexibility in applying the district management template so as to ensure that Districts retain the necessary specialist capabilities but that a dedicated traffic safety report be mandatory in each new district.

• That the total number of Areas be left flexible until further analysis of District and community needs has been carried out.

• That three operational Superintendents be based in Auckland, Wellington and Christchurch who would each have an inter-district role in coordination of operational matters, contribute to the management of integrity and operational risks, and increase Police capability in relation to operational command for major events.

• That there is a need for some additional resource within the Commissioner's Office, principally to address crime, road safety and strategic development coordination, advice and specific service delivery.

• That a five-level management structure be introduced subject to specific approved exceptions.

• That the senior sergeant rank be retained although some changes to job structure and role may occur.

• That the Review recognises a Police core role in forensic photography and Search and Rescue, which is not open to outsourcing, and that further work needs to be done in respect of CVIU to establish which functions may be core to road safety and should be retained.

• That there should be greater clarity and definition of the respective roles and responsibilities of the Commissioner and Minister including the potential for Ministerial direction provided such direction does not impinge on the Commissioner's constitutional role. The Police, State Services Commission, Department of Prime Minister and Cabinet, and Crown Law should work through both the detail and means by which such clarification ought to proceed.

• That the Police Executive comprise two groups, both of which will contribute to strategy development; one with a performance, audit and advisory focus and the second with an operational and strategy implementation focus. The Commissioner will chair both.

• That Police property be restructured under a national property manager and a national property management system be established.

• That a review be carried out of the number and location of police houses required to ensure reasonable policing needs are met while not retaining properties where a clear case for retention cannot be made.

• That the Police purchasing strategy be streamlined through the implementation of a tendering process for the top 100 purchase items.

• That priority is given to establishing the proposed rate of overall change and to ensuring the management structural proposals are fully implemented prior to June 1999 to enable a full three months of clear attention leading up to APEC in September 1999.

• That the Review specifies a range of staff and dollars savings rather than a precise figure in order to ensure that proposed cuts to administrative and other structures do not affect overall delivery of policing services.

Table of contents

INTRODUCTION AND OVERVIEW
DEFINITION OF 'FRONT-LINE'
    Flexibility in sworn/nonsworn staff mix
THE ORGANISATIONAL STRUCTURE OF POLICE
COMMISSIONER'S OFFICE
    Roles and staffing numbers
    Separation of functions
    Reporting relationships
    Executive management structure
SERVICE CENTRES
POLICE REGIONS
POLICE DISTRICTS
    Number of districts
    District template
    Areas
    Levels of management
    Operational risk management
    District management support team
    Administrative support
OUTSOURCING
    Proposed areas of outsourcing
    Time frames for outsourcing
GOVERNANCE AND ACCOUNTABILITY
    Policy/Operations Distinction
    Statutory definition of Police role
    Ministerial Direction
    Police Act
    Management Advisory Board
PROPERTY MANAGEMENT
    Police housing
PURCHASING
TRAINING
IMPLEMENTATION TIME FRAMES
CONCLUSION