Wednesday 3 August 2016

Consultation - West Sussex Fire & Rescue Service Community Risk Management Plan

Well I have submitted my response to the West Sussex Fire & Rescue Service consultation, which closes on Friday this week. The 'additional comments' (item 2) are reproduced below and if anyone wishes to include any of the text in their response, then please feel free to do so.

"This document does not meet the requirements of an Integrated Risk Management Plan (IRMP), and even fails to deliver as a Community Risk Management Plan. Much of the information in the document may be useful in a general information brochure, but the absence of key information on the outcomes of the last IRMP and plans for dealing with future risk makes this an inadequate IRMP.

Despite a statement that ‘Station Profile’ and ‘County Profile’ documents are produced each year and are available on the website, I have been unable to find them on the website. Even a search for them only resulted in ‘Sorry, no results were found’ being displayed.

The dubious selection of figures for fire deaths seems intended to disguise the failure to deliver on the 2010-15 IRMP’s statement that fire deaths would be reduced. The latest figures, that would show accidental dwelling fire fatalities for 2015/16, have been omitted and, oddly, figures for 2004/05 have been included. That is presumably to misrepresent the situation by starting the chart with a particularly high number of fire deaths.

According to Government figures, the actual deaths for the period of the last IRMP were 28, compared to the previous five years when there were just 13. So instead of a reduction they have more than doubled.

The 2010-15 IRMP also said that WSFRS would “look at new and creative options to maintain cover and continue to attract new retained recruits.” Not only has WSFRS failed to do this, but changes to contracts, training and management of Retained Duty System (RDS) personnel have made things worse.

Mysteriously, the retained appliance availability target of 88% in 2011/12 has been cut to 75%. Despite the serious implications, this has apparently been done without any consultation with either the public or with County Councillors. Yet even this reduced target is not being met and average availability has fallen from 87% in 2009/10 to 59% last year. Some stations have even dropped from 100% to just 30% availability during that period.

The failure to address this problem suggests that WSFRS is happy to allow the retained service to wither and die. This is evidenced by inadequate efforts to stop the decline and the repeated process of removing lower availability RDS crewed fire engines from service. Nine have been cut so far. Clues to the root causes of these failures may be shown in a recent national survey of RDS firefighters by the Retained Firefighters Union. The results showed that 69% did not feel their service was doing enough to resolve the problem, and 60% felt that they were undervalued by Principle Officers.

The only way WSFRS is going to properly tackle the RDS problem is by working with communities, County Councillors, Parish Councils, local business and community groups, partner agencies, the South Downs National Park Authority and others. Much is made of partnership working, yet on this critical problem WSFRS seems intent on avoiding the involvement of anyone that may be able to help find new and creative options.

Whilst the Crewing Optimisation Group may seem a useful interim solution to the RDS crewing difficulties, it is expensive as a long term solution and fails to cover all periods of RDS crew shortages. Operating it when there are 12 wholetime crews available, but not operating it when there are only 8 wholetime crews on duty suggests a lack of planning. Especially as there are times, during the periods that the Crewing Optimisation Group is not available, when RDS shortages are as bad as they are when the Crewing Optimisation Group is available.

There continues to be an inadequate assessment of risk and an even more inadequate provision for dealing with it. The last IRMP is claimed to have resulted in “a considerable reduction in the number of ‘Very High’ Critical Fire risk areas”, yet no evidence can be found to support this claim. It appears that this may not be an actual reduction of risk, but simply a slight drop in the number of calls received in some areas.

The risk to individual lives and property remains, and the risk of losing lives or property is actually greater in areas classed as ‘low risk’, because it takes longer to get firefighters to those areas. The risk to life is particularly high in respect of road traffic collisions, with the more serious ones tending to occur in rural areas. Not only are response times greater, but WSFRS is failing to meet target times for one in four incidents.

Neither is the provision matched to the risk or the volume of calls. Crawley continues to be the fire station area requiring the most fire & rescue service responses in the County. In addition, this document says that the population in that area is expected to increase by 25%. Yet, WSCC has cut the number of fire engines and crews in Crawley from five to two. There is a correlation between population and number of calls, yet this document has no proposals to deal with an inevitable increase in emergencies in the Crawley area. 

The document states, “We use analytical resources, such as computer modelling software, to help us predict risk and assess the likely impact of changes”. Unfortunately, history shows that the results of that modelling are ignored when it does not suit the Council’s political agenda. Modelling of proposed changes in 2010 was reported, as it showed no increase in deaths or property damage. Yet when modelling of the cuts in 2015 showed an increase in deaths and property damage, efforts were made to disguise and later discredit the modelling.

It is reassuring that WSFRS recognises the reduction in firefighter experience of real fires. However, extra training at the Fire Service College is not enough. The cut in wholetime firefighter numbers and the shortage of retained firefighters have made it difficult to maintain skills with continuation training, and at the same time maintain adequate fire cover. In house training facilities need to be improved and more firefighters must be employed to enable training facilities to be used without undermining fire cover.

The document includes the Sussex Control Centre (SCC) in the list of specialist teams in WSFRS, when in fact the SCC is operated by East Sussex Fire & Rescue Service (ESFRS). The Control function is effectively contracted out. No mention is made of the worrying fact that the combined mobilising system, that was fundamental to the improvement of the control function, is now three years overdue. ESFRS has refused to state how many times the combined mobilising system has failed acceptance tests and they have given no indication of when this problem will be resolved.

Other problems with the SCC are not mentioned, including the excessive amount of overtime required to maintain minimum staffing levels. In 2015/16, overtime was required on 425 shifts. Of particular concern is that, unlike the previous WSFRS Fire Control, the SCC does not record mobilising errors. If they are not recorded, then problems are not being identified and remedial action cannot be taken.

The document states that around half the incidents attended by WSFRS were false alarms. It is concerning that this number has been artificially increased by classifying attendance at some road traffic collisions as false alarms, simply because no action was required when the service arrived. To describe an actual road traffic collision that the service attended as a false alarm is misrepresenting the facts and the work of the service. Will attendance at actual fires that are out on arrival be the next to be misrepresented as false? 

The document states, “our change in operating model has not altered the emergency response standards we agreed with you in 2009”. Yet it fails to inform the public that those standards are not all being met and that the degree of failure has increased. In particular for both fire engines arriving at critical fires and for the first fire engine arriving at critical special services.

The addition of the High Volume Pumping Unit is to be welcomed, but it does not offset the loss of 11 fire engines. Storms and flooding primarily require a large number of standard fire engines to respond to the high volume of emergency calls received in a short space of time. WSFRS is now less well prepared to respond to the predicted increase in severe weather events and no improvements are planned.

The claim that this is a ‘Community Risk Management Plan’ is dubious. Despite fine claims about integration, this document has little or no mention of the smaller units now controlled by the Chief Fire Officer, the legislation covering their work, or any plans for their future work. These smaller departments seem to be completely overshadowed by the fire & rescue service and their effectiveness seems to have suffered as a result.

A recent example being the Council’s latest IT Strategy report. The Civil Contingencies Act and resilience are not mentioned, yet resilience of such a core facility, which is essential to all WSCC services, should be a key strategic objective. If the Council cannot meet their legal obligations on such a fundamental report, there is little hope of them setting an example to others.

Finally, the inadequacy of the consultation. There are just two sections on the ‘Plan’, one of which contains four questions designed to get a favourable response, and the other is simply blank for additional comments. Yet there are seven sections about the person submitting the response!

There are no questions about the public’s views on deteriorating fire engine availability, or on increasing failures to meet response times. Both are of significant concern to the public and they are entitled to be properly informed and invited to comment. They should also be asked if they consider £33.68 per person per year is sufficient to spend on their protection. I consider it inadequate and I am sure many others would agree.

Firefighters continue to do a superb job, but the decreasing support they receive from the County Council is a disgrace. The public also deserve a much more open, transparent and accountable fire & rescue service. This Community Risk Management Plan does little to meet those objectives. Sadly, it’s inadequacies will simply strengthen the Police & Crime Commissioner’s case to take control of the fire & rescue service."


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