Alliance sends critical letter to Boundary Committee

28.10.08

In a letter to Boundary Committee Director Mr Archie Gall, the alliance of Forest Heath District Council, St Edmundsbury Borough Council and Waveney District Council stated the following:

Thank you for your invitation to comment upon other councils’ submissions for unitary government in Suffolk.

This letter focuses primarily upon the submission from Suffolk County Council and Mid-Suffolk District Council for a ‘One Suffolk’ single unitary council. We then give you further information about the current work of the three district councils on our alternative proposal for three unitary councils in Suffolk.

1. Overview of ‘One Suffolk’

We have grave concerns that the One Suffolk proposal does not take sufficiently into consideration the very real and different economic and social realities of the county. We believe a One Suffolk option would be too great a risk to services that need to be tailored to the needs of divergent communities.

It is our view that a single unitary authority would be too big for Suffolk, running the significant risk that it will be seen as remote from the communities it serves and unable to deliver meaningful neighbourhood empowerment. The options put forward for community empowerment in the One Suffolk proposal fail to take into consideration the differences between East and West Suffolk and North Haven in terms of economy, socio-economic make up, geography and history and would therefore undermine local government in Suffolk.

The Secretary of State has said that: “The more an authority’s area matches that economic reality, the more likely that it will be effective in providing the strategic leadership necessary to create prosperity.” For the reasons highlighted in our earlier submission and in this letter, we believe that strategic leadership in Suffolk is best suited to the economic and social realities of East and West Suffolk and North Haven rather than the One Suffolk and rural proposals.

The following examination of the One Suffolk and rural proposals shows why we believe they fail to address the concerns we have laid out above.

2. General Concerns

The One Suffolk proposal is carefully articulated but there are, in our view, six critical areas in which it fails to convince:

(1) Comparing “One Suffolk” with the ‘Rural Unitary’ option (in which we include Lowestoft). It is perhaps unfortunate that Suffolk County Council (SCC) were charged with championing both proposals. The whole weight of the County’s submission seeks to prove that the Rural Unitary is an ineffective and costly proposal, lacking strategic worth. It really cannot be the case that a rural unitary council of some 475,000 population (one of the largest rural unitaries in the UK, were it to be created) would be unable to act strategically, procure and ‘market-make’ effectively and deliver cost-effective services. Furthermore the County’s submission also argues that there will be additional costs, of nearly £10 million, in dividing up current SCC arrangements, novating contracts and establishing a Combined Fire Authority. These figures must be open to considerable scrutiny. The argument against the rural unitary just does not hold water.

(2) The submission makes great play on continuing SCC’s service and management arrangements, as tried and tested. It does not promise significant change in these arrangements, and that is a profound weakness since the County is clearly viewing itself as a continuing authority and is not intending to grasp the creation of a totally new council.

(3) Thus, all the change that is promised is made in inherited district council services but here the County is not clear on just how it will seek synergies with these services – for instance, the whole section on housing in the submission stands quite separate from that on older people.

(4) Some changes are promised in the submission but most of these (better services for older people, higher levels of adult skills and economic development and attracting investment) have always been a core responsibility of the existing county council, arguably weaknesses to which they should already have given attention.

(5) The submission entirely lacks a coordinated statement on the future of Children’s Services.

(6) Finally, turning to ‘devolution’ the County Council’s submission is particularly vague. It promises a three year programme of pilots and prototypes with 375 parish and town councils, the creation of 20 community boards and it admits that it has not worked out the relationship between these two initiatives and the seven development control committees. This is a recipe for wholesale confusion. The district councils believe instead that, alongside a unique model for North Haven, two different patterns of locality governance are required for East and West Suffolk and are developing these alternative proposals in consultation with others.

3. Specific concerns

3.1 Strong and effective leadership.

• Paragraph 2. The submission claims that a unitary council for all Suffolk is likely to be more effective than the current county council in addressing weaknesses in meeting the agenda for vulnerable adults, low skills and in transforming Lowestoft. Why should this be so, since these are current responsibilities?
• No mention whatsoever is made here of the big, critical, issue of rural deprivation particularly in the east and around market towns in the west. It really seems that this challenge has not been recognised. Nor does the strategy recognise the potential development of power industries and alternative agriculture and retail but seems to pin all its hopes on high-tech development.
• Paragraph 10. Promises are made to form a Local Housing Company. The county council has not understood that, in law, this will require the consent of tenants. Nothing is said here of developing housing for vulnerable clients, calling into question the joined-up view of future services for people.
• Paragraph 19. Much is made in this paragraph of the view that a large council of 700,000 population will be more able to bid for competitive funding. This argument really is marginal. Two or three local authorities acting in concert can achieve the same. The experience of the Greater Manchester authorities (AGMA) is very telling here.

3.2 Adult social care

The approach of the SCC submission in respect of adult social care seems to be to list the issues for social care (many of which are national issues) and then jump to a conclusion that the only way to deal with them is at a county level. Some examples and our responses, include:

• ‘There is an ambition for a unitary Suffolk to create choice in care services’.
  This is the case for all social care services. The size of budgets and populations in three new unitaries would allow us to commission differently and further increase choice and options around localities. East Suffolk has a large elderly and very old population living in largely rural areas. This presents real challenges as well as opportunities for the use of personal budgets to create new community-driven rural networks of care. In the West a different approach, built around a West Suffolk unitary council’s new ways of working, will be created.
• ‘People with complex needs are now living longer: there are increasing numbers of older carers and a need to attract more carers, paid and unpaid’.
  This is a national issue for social care; there is no obvious reason why a single unitary would better address it. A significant number of the elderly and old population in East Suffolk are people who have moved to the area in retirement; they are less likely to have supportive family networks than those in the West. East and West unitary councils will be able to address the needs for carers and for care in ways that suit local conditions. We know that this will be a high priority.
• ‘Using contracting power to drive down overall costs and free up resources to maintain appropriate care for elderly at home’.
  The level of business within the commissioning budgets for two or three unitaries is so significant that they will have contracting power with local providers who rely on councils for much of their business. Care provision is mostly local. Single suppliers do not on the whole serve the whole county. North Haven and East Suffolk and West Suffolk will each be market makers for care in their area. Care commissioners in the East, West and North Haven unitaries will build a good understanding and close involvement with these local markets.
• ‘Care providers want to deal with one authority as it is simpler and cheaper. They also want to be able to balance urban and rural provision'.
  Providers in large metropolitan districts seem to manage perfectly well and most provision is contracted locally as noted above. North Haven and East and West Suffolk will each be able to deal with contractors to make provision across their urban centres, smaller market towns and rural areas. The new unitaries will be innovative in their approach to developing a market that meets their local needs and conditions.
• ‘Focus on preventative services is laudable but at odds with the business case: the idea that helping more people stay at home reduces demand is not true: if they live at home longer it costs more’.
  This is a complex issue and interestingly reflects the lack of a truly joined-up approach with the PCT: the costings depend on what sort of support you are putting in as a preventative measure and the use of Telecare and Telehealth can be very cost effective. Indeed, some of the proposed savings SCC are putting forward in adult social care are based on the ‘customer journey’ in terms of signposting people towards preventative services with the aim of reducing care management costs.
• Finally, on partnership. There is little evidence that, in terms of innovation, the current arrangements with the Suffolk PCT are developing as quickly as they need to. Indeed, we understand that there are ongoing issues between this PCT and SCC over the mental health budget.

3.3 Children’s Services

As noted above, the SCC submission entirely fails to address the issues of Children’s Services; they have instead provided scattered comments throughout the text related to children – surprising given the overall importance of this service area and the impact of performance in children’s services to the overall assessment of a council.

There are longstanding performance issues which the county’s services for children and young people have consistently failed to address over a number of years. These weaknesses are long term, they have occurred within a large county-based service and they demonstrate the inability of such a service to tailor strategy and service provision to the needs of markedly different communities.

In this respect, the submission admits in paragraph 4 the long history of low skill levels amongst the population in the county – “skill levels are below regional and national averages at all NVQ levels and half of Suffolk’s workforce have no qualifications at all”. Given that these problems are concentrated in areas such as Lowestoft and Ipswich it is an indication of how county-wide “one size fits all” strategies have singularly failed to focus upon the particular and different needs of high need areas such as these.

The following areas are longstanding performance issues in children’s services which are often linked to specific communities and localities, and where a broad brush whole county solution has not yielded improvements at the level of other similar local authorities:

• Progress at Key Stage 2
• unauthorised absence in secondary schools
• high proportion of NEET (not in education, employment and training ) which is higher than both national and statistical neighbour comparators
• outcomes in school sixth forms
• school attendance of looked after children
• slower progress than comparator authorities at key stage 4
• relatively high numbers of looked after children and those on the child protection register.

Our argument is that, given that performance failures in these areas are usually linked to particular areas of the county, for example Waveney and Ipswich, rather than being a whole county issue, then a more targeted approach via the three unitary model is more likely to achieve improved outcomes. GCSE results in Waveney reflect this concern. In 2007, 54.6% of 16 year olds achieved 5+ A*-C grades, compared with 62% nationally. And only 89.6% achieved any passes compared to 92.3% across the region. 2007 KS2 and KS3 results reflect the same continuing underperformance in this area. More detailed examination shows that young people in Lowestoft are underachieving significantly, with some schools in the area achieving 32% or fewer GCSE passes at A*-C in 2007. East Suffolk unitary council will focus on school improvement here, developing partnership approaches and innovative methods to ensure that young people in Lowestoft achieve their potential.

Teenage pregnancies (TP) provide a particularly vivid example of outcomes which diverge depending upon particular areas. Whilst this is not a particular performance issue for the County as a whole (as its TP rates are below national and regional levels) some wards within Ipswich and Lowestoft have three times the national average rates. Similarly, areas like Waveney have seen their annual rates increase by as much as 10.5% during a period when the national levels have declined by 6%. Again we argue that a strategy which may be appropriate for the County as a whole has failed to address the needs of particular communities.

Building Schools for the Future (BSF). Much play is made of this in the SCC one unitary submission in terms of the size and scale of the £600m investment and the cost effectiveness of doing this as a county. It is perfectly possible of course for three Suffolk unitaries to commission a single LEP (Local Education Partnership) in order to achieve the necessary economies of scale. Similarly with Local Safeguarding Boards which are mentioned in Paragraph 160 as needing to be duplicated. It is also perfectly possible for these kinds of structures to be shared across unitary boundaries as will be the case in Bedfordshire. In terms of BSF we also comment on the potential for lost opportunities, in areas such as Lowestoft, of applying a blanket county solution i.e. “new schools = improved performance” (for which there is no evidence), rather than looking for innovative new solutions which are more likely to emerge from a more localised unitary council e.g. the possibility of developing an all-age school campus from 3-19 along with extended family support services in order to tackle longstanding, intergenerational disadvantage in areas such as Lowestoft.

3.4 Value for money

• Paragraph 71. In the overview above we stated that service delivery in a unitary council of 700,000 people is not, ipso facto, bound to be better value than in one of 475,000 or even 250,000. We are benchmarking our work against comparators. We would be interested to know what benchmarks the Committee are using to assess value for money offered in the submissions it has received.
• Paragraph 80. The submission recognises the need for transitional investment in ICT which we acknowledge is required due to the costs and complexities of amalgamating a variety of different systems performing similar functions. We would however wish to draw attention to the fact that this cost would be less in the three unitary model which would require a lesser number of systems being combined. Whilst the transitional costs incurred by a single unitary will be higher, the opportunity for longer term savings which can be achieved as a result of removing duplication and introducing a standardised approach should apply equally to the three unitary option.
• We consider the utilisation of ICT based solutions to be fundamental to the future and believe that there are numerous ways that this can both improve customer services and reduce costs. We would therefore wish to support those identified in the single unitary submission, but consider this bid to lack sufficient ambition in this respect. For example the submission refers to the use of IT “to allow staff to operate flexibly”. It is our belief that there is a need to migrate many roles to an agile working environment. This requires a change to the culture of the organisation and an acceptance of the fact that staff who work in an agile fashion, whilst being provided with the appropriate tools to enable them to work efficiently and effectively, will not necessarily have their own desk space. This change in culture will drive out large savings in the property portfolios of the future authorities.
• We would further argue that there is an increasing opportunity for greater partnership working with the private sector in the way in which ICT is deployed and also a need to recognise the different requirements of North Haven and East and West Suffolk driven by the different levels of social deprivation in each area.

3.5 Community engagement and devolution

• Paragraph 47. Whilst we welcome SCC’s conversion to locality engagement and ownership we reiterate that proposals for prototypes for 375 parish and town councils, 20 Community Boards and 7 Development Control committees, plus special arrangements in Ipswich and Lowestoft are really a recipe for muddle. The Boundary Committee is entitled to have received a more convincing case. In our own work we have come strongly to the view that different locality governance arrangements for east and west Suffolk are likely to work better, recognising for instance, the place of market towns in this equation.
• But more than this, the Suffolk County Council submission has not tackled the issue of democratic deficit - the loss of over 250 elected members, and much higher councillor to elector ratios that those proposed in our submission. Again, the district councils believe this to be a significant argument in favour of their bid to see created three unitary councils for Suffolk.

3.6 Broad cross-section of support.

• Paragraph 132. It is clear that massive effort has been undertaken by the County Council to convince others of its case for ‘One Suffolk’. In this paragraph we learn of many business breakfasts. At no time has the case for the rural unitary received such promotion. Nor has the Boundary Committee embraced, and sought consultation on a three unitary solution.
• This massive promotional effort has cost the County a considerable sum. We question the basis on which SCC has been able to spend such sums on promoting its preferred case, sums which have not been made available to promote the rural unitary or any other option.
• It is most evident that the ‘broad cross-section of support’ is substantially the result of this promotional effort. It cannot be claimed to be, in any sense, representative.

4. Anomalies in the financial case

4.1 Part of the submission required all of Suffolk’s S151 officers to sign off the financial element of the submission. Apart from the County Council itself, no S151 officer has completely signed off the proposals. They each state that the only element they can agree unanimously is the inclusion of their own original 2007/08 base submission. Therefore they do not accept on the evidence provided that the county’s proposals are either reasonable or affordable.

4.2 Some of the reasons given for not signing off the submission are set out below:

Methodology

• SCC produced workbooks for both the unitary county and the rural proposal. Very little work was put into the rural unitary submission and SCC consistently discredited the rural proposal and promoted their single unitary option. This we consider casts significant doubts upon the efficacy and even handedness shown by SCC in producing the rural submission.
• Securing the Future is the largest single area of future savings and accounts for over£45m of ‘identified efficiency savings’. SCC would not provide complete details of how Securing the Future savings could be achieved and therefore these could not be signed off as reasonable or achievable. No indication was given as to actual effects of savings on services
• SCC could not prove that there was no double-counting in their savings proposals between what they had included in the 2007/08 budget, the 2008/09 budget, Securing the Future and the proposals for a single unitary council. This is a major concern of the S151 officers.

Senior Management and Redundancy costs

• SCC used differing cost bases to meet their own agenda – this was very evident when considering senior management and redundancy costs. For example, using Chief Executive budgeted costs for 2008 in respect of Waveney and Suffolk Coastal districts but 2007/08 figures for the County Council – reducing the figure taken into account by some £42,000 against more recent figures.
• Redundancy costs assume no redundancy of SCC directors. The impression is that the new unitary will, in effect, be the existing county making the decisions on employment and treating district staff as the main source of savings, with very little from the county.
• Recruitment costs are we believe also understated. They assume, for example, only 5 directors being interviewed for the 6 posts in their proposed establishment, and make no provision for Assistant Director recruitment.

Waste Services

• The SCC proposal is based on two reports produced for the County, but discredited by all of the district councils as being inaccurate and unachievable by the methods stated.
• Costs are based on 2005/06 budgets inflated to 2007/08 and therefore do not comply with the requirements of the return.
• SCC assumed that although they currently run the waste disposal element of the waste service they can make a further 20% saving. This has not been proved and, if this is the case, the question raised is why it is not currently being achieved.

Corporate Services

• Based on their own calculations and use of average salaries, SCC have assumed in their workbook that a rural authority would require the equivalent of 26 extra staff to support its monitoring officer and head of internal audit, compared to a county unitary. This has not been agreed by the districts and is not considered acceptable.
• Similar comments and assumptions have been made throughout the submission which puts in doubt the integrity and accuracy of both the unitary Suffolk case and the low level of savings attributed by SCC to a Rural/North Haven option.

Property

• No account was taken of the economic effect of closing offices in areas of deprivation, of the impact on community involvement, nor of recruitment problems in some services.
• Properties had not been suitably valued or account taken of the downturn in the property market.
• Property issues were contested by district officers and little change was made until the very last moment just days before final submission by SCC. Consequently district officers have not been able to either agree or disagree with SCC revised proposals and financial implications

Other anomalies

• Although there are many areas of discrepancy within the submission just one more is pointed out here to give an example. In dealing with savings and costs, staff on-cost has been assumed in all cases as 30% (as agreed with the districts), which is not consistent with the proposal for recurring costs and locality working where a 40% uplift is used.

5. A different proposal

The district councils are continuing to work on the detail of their proposal for a three unitary solution i.e. East and West Suffolk unitary authorities alongside your own proposal for a North Haven unitary. As we explained in September, retaining Lowestoft in Suffolk remains central to this proposal, which we see very much as an improvement to your own preferred option.

We have not been given the opportunity to have our option properly assessed by the Boundary Committee. Thus we are independently now undertaking work on the detail of how community empowerment, strategic leadership, service delivery and affordability might work for East Suffolk and West Suffolk unitary options. Some emerging observations are:

• Community empowerment. We are responding to the Secretary of State’s call to put greater emphasis on empowering people, “to help them ‘own’ what’s going on, to feel they’re involved rather than being powerless in the face of events… to maintain trust in civic institutions at a time when it’s needed.. and to get the public involved to help deliver better services at better value”.
  
  Different arrangements will be required for East and West. We are looking to create strong mechanisms for delegating management and devolving decision making. At the same time we are aware that different geographies and community arrangements as well as different population needs and service challenges must be reflected in our approach. The three unitary model including East and West Suffolk will provide opportunities to put in place models that reflect differentiated long-term ambitions across the county.
  
  We also see the opportunities to build new ways to deliver services, working to develop social enterprise and building new local and wider providers to meet our needs.
• Providing the strategic leadership that each area needs to deliver progress and prosperity for its citizens is at the heart of our thinking. This involves working with partners to determine local priorities and working together to deliver them, in a way that reflects local conditions. With the implementation of the sub-regional economic development and regeneration review through current legislation, and in the present economic situation where attention to the local economy is vital, economic development is our key strategic leadership focus.
  
  Our submission to the Committee showed that we see East and West Suffolk as having different economic development and regeneration needs. SCC’s submission, which is confused on the issues of economic growth and housing growth, clearly illustrates less than a full understanding of the situation. Their failure to grasp and adequately promote infrastructure and labour force needs has left Suffolk with a low value, low skills economy with areas of real deprivation and high unemployment. As districts we have led successful economic development programmes across the County. A three unitary councils model is best placed to take the lead in promoting economic development and regeneration in Suffolk.
  
  We have also been exploring the governance and management models that are most appropriate to deliver customer focused services in different parts of the county. We have looked at the opportunities offered by the deployment of emerging technologies and the available customer access points to ensure that we provide a comprehensive network of support to meet the needs of the different communities within Suffolk
• Value for money: We have been looking at service delivery in comparator 4* rural unitary councils and benchmarking future service delivery in East and West unitaries against the costs and performance they achieve. We have considered the challenges facing key services, including adult social care and children’s services over the coming years to identify new and cost-effective ways of working. We will show how better use of IT, new customer service access, service commissioning and partnership working will ensure that the services developed offer both value for money and quality, effective outcomes for local people.
• Affordability. Our initial submission demonstrated the affordability of the three Suffolk unitary model. In this letter we have shown that we have concerns about the financial cases presented to the Boundary Committee by SCC. Our approach is to provide new and improved, locally tailored services. As we work up more detailed models we are able to firm up our projections on affordability. We remain convinced that, over a five year period the East/West Suffolk proposal will deliver savings, net of costs, of no less than £33m.
  
  The model we are proposing, and the decision we are seeking, has precedent in the Secretary of State’s decision on two Cheshire unitary authorities. The decisive factors in that case were that a single unitary would not reflect economic reality and that there were risks that the authority would be seen as remote by local people. The same arguments apply in Suffolk.

6. Conclusion

We believe that we have produced an option for future unitary local government in Suffolk that meets the needs of local communities and builds on opportunities for change to meet difficult times. We ask, even at this late stage, for the facility to have our model fully and equally assessed alongside the other models you are considering.

Yours sincerely

This website puts forward the views of Forest Heath, St Edmundsbury and Waveney councils but to help you make up your mind you should also take a look at the proposals put forward for a unitary covering all of Suffolk (minus Lowestoft) on www.suffolk.gov.uk and, for a unitary covering Ipswich and Felixstowe, www.unitarynews.com

You can read the Boundary Committee's full proposal on www.boundarycommittee.org.uk