This is a wide-ranging review covering a range of issues linked to the UK’s role and standing in the modern world. While the LGA is only responding to the review questions that directly link to the work of councils, in an interconnected and globalised world, these wider issues are also highly relevant to councils and their residents, too.
1. About the Local Government Association (LGA)
1.1. The Local Government Association (LGA) is the national voice of local government, and our members include councils and fire and rescue authorities. We work with our members to support, promote and improve local government.
1.2. We are a politically-led, cross party organisation which works on behalf of councils to ensure local government has a strong, credible voice with national government. We aim to influence and set the political agenda on the issues that matter to councils, so they are able to deliver local solutions to national problems.
2. Key messages
2.1. This is a wide-ranging review covering a range of issues linked to the UK’s role and standing in the modern world. While the LGA is only responding to the review questions that directly link to the work of councils, in an interconnected and globalised world, these wider issues are also highly relevant to councils and their residents, too.
2.2. The Novichok poisoning in Salisbury, flooding and wild fire incidents, and sadly terrorism attacks all show that geopolitical tensions, climate change and other global challenges all manifest themselves at the most local level, with councils and local partners on the front line in responding. High levels of mobility and more diverse populations mean that issues in faraway places can play out as tensions in local communities in the UK, or through patterns of migration. In considering this review it is important to recognise the extent to which local is global, and that councils are key and equal partners in responding to these challenges. That does not always seem to be recognised in the national response to these issues playing out at the local level, with challenges over the sharing of critical information, and therefore of trust, prevalent in recent emergency responses, undermining the ability of local partners to plan and respond most effectively, and therefore our overall resilience.
2.3. Councils want to work with local and national partners and residents to build the resilience to withstand the challenges of the twenty first century: but it is important to be clear about what is meant by resilience. In a narrow sense, this may refer to emergency preparedness and response, but genuine resilience must be much broader than this, in terms of wider organisational and community resilience; an ability to withstand shocks and respond to emergencies as well as the ongoing challenges that communities face. Resilience is not an issue that has been the subject of public national debate or awareness in recent years, but with the COVID-19 pandemic remaining an ongoing challenge, this is a good opportunity for a reset on what resilience should mean at the individual, organisational and community level.
2.4. At national government level, there is a need for a cross government approach to resilience. For specific incidents, this means better join up between departments nationally and agreement on shared priorities – particularly where there are competing objectives as can be seen in the health/economic considerations of COVID-19. Outside of response periods, it requires both strategic oversight of resilience and greater consideration of long-term resilience issues across all policy issues and departments. An obvious example of this is the need for consideration of the risks of extreme weather and flooding, and how to mitigate them, in relation to housebuilding. Another example to consider for the future will be how we can ensure resilience in supply chains for items where global demand can increase very quickly, such as PPE or testing products.
2.5. Councils have led from the front in responding to the COVID-19 pandemic. The pandemic has highlighted the importance of wider organisational resilience alongside emergency planning expertise in responding to shocks and emergencies; but it has also exposed the extent to which capacity and resilience in key services (for example regulatory services) has been reduced by austerity, threatening to undermine our ability to tackle the pandemic and raising question marks about the risks of concurrent events in the coming months. Maintaining organisational resilience requires appropriate levels of funding, and the Government should use the forthcoming spending review to ensure that sustainable funding (or mechanisms to generate this) are made available to relevant local services.
2.6. There is a need to look at the role of Local Resilience Fora (LRFs) as the Government’s preferred delivery vehicle for dealing with shocks and emergencies: there is a mismatch between the statutory role of LRFs as set out in the Civil Contingencies Act and the recent demands placed on them in relation to no-deal Brexit planning/EU transition and COVID-19. The Act and the supporting guidance should be reviewed and amended to ensure that they are fit for purpose, with LRFs, or their component organisations, appropriately resourced for what they are expected to deliver.
2.7. The review should also examine existing national structures (including the current split between the Cabinet Office’s Civil Contingencies Secretariat and MHCLG’s Resilience and Emergencies Division) and the way central departments support local organisations, to consider the scope for strengthening the current framework.
2.8. More broadly, alongside a substantive analysis of our civil contingencies machinery, there is a need for a review that examines the wider government response to COVID-19, looking at both local and national activities and the interface between the two. Too often in the COVID-19 response, we have seen issues with an over-centralised approach to planning, information sharing, decision making and service planning, when trust and co-design with local partners delivering on the ground would have enhanced our response. Adjusting this approach going forward will deepen our resilience.
2.9. Finally, following recent emergency responses at the local level, in recent years the LGA has scaled up its activity to support councils on the resilience agenda, through training, guidance and the development of a bespoke resilience peer approach in London. There is scope to extend this work more widely to look at a peer review framework for LRFs, to help provide the consistency and assurance the Government has sought through the development of the national resilience standards.
3. Detailed response
What are the key opportunities, challenges, threats and vulnerabilities facing the UK now? (Submissions focusing on rapidly evolving areas such as science, technology, data, cyber, and space are particularly welcome.)
3.1. As we set out in our key messages, the opportunities, challenges, threats and vulnerabilities facing the UK play out at the local level. One specific example of this relates to the regulated and sustained cyber-attacks which councils, in common with other bodies, are now subject to.
3.2. There is a need for continued support as councils and others adjust to this shift. Dealing with threats rather than hazards changes the dynamic of risk assessment processes, and subverts some of our typical resilience processes; a cyber attack does not need to trigger a multi-agency response to be extremely disruptive.
3.3. The LGA’s cyber resilience programme is supporting councils as they work to deepen organisational resilience to cyber-attacks, but there is a need for continued resource to support this agenda and support the development of peer networks and sector led assurance tools. At the national level, there is the need also to develop a whole system approach to assurance of public sector information systems, as is the case in Scotland.
3.4. Finally, greater work is needed in identifying and communicating the sector wide threat and attack pictures, without which councils are not able to take appropriate counter measure, assess vulnerabilities, enhance resilience, asses risk, or measure the impact of cyber security initiatives and projects. What are the key steps the UK should take to maximise its resilience to natural hazards and malicious threats? How can we build a whole of society approach to tackle these challenges?
3.5. We support the idea of a whole of society approach to building resilience to the challenges of natural hazards and malicious threats - as well as other stresses such as economic shocks.
3.6. For organisations such as councils, understanding and managing the risk of future shocks and stresses must extend beyond the emergency planning officer and Civil Contingencies Act into business as usual, but austerity has impacted councils’ capacity both in emergency planning and other services. In particular, the COVID-19 pandemic has highlighted reduced capacity in services that have a key role to play in response to the current emergency such as environmental health; however, this reflects a broader hollowing out of council capacity in recent years. While there will always be steps that can be taken to improve organisational resilience through better training, sharing good practice and national support, it also needs to be recognised that organisational resilience requires investment in capacity.
3.7. At community level, there are also concerns about the extent to which community resilience has been impacted by reductions in some local services as a result in cuts to funding: many community services, whether council, health, or third sector have been lost, increasing vulnerability within communities. There is a need to invest in local support networks, including through the voluntary and community sector. However, there is an opportunity to build on the local structures that have developed in response to COVID-19 to help deepen community resilience. The LGA will work with councils and other partners to consider the learning in this area.
3.8. More generally, for individuals and communities, the COVID-19 pandemic is an opportunity to think more about what being resilient means. There is a need for more transparency and communication with the public about the risks that the Government plans for, and consistent national/local messaging about preparedness: everyone, whether individuals, private businesses or public bodies, should be encouraged to think more about how to make themselves or their organisation resilient, and what that means in an interconnected society. The Government should work with councils to consider the best forms of communication to improve engagement in these issues. How should UK systems and capabilities be reformed to improve the development and delivery of national strategy?
3.9. A whole society approach should start from the top. We need a joined up, cross Government approach to resilience across all policies, with clear strategic oversight of the resilience agenda: it is not clear what exists currently beyond individual government departments checking what the latest policy initiative means for national, regional and local resilience. We also believe there should be consideration of the current split in functions between the Cabinet Office’s Civil Contingencies Secretariat and MHCLG’s Resilience and Emergencies Division.
3.10. The LGA would welcome a review of the Civil Contingencies Act, which provides the overarching framework for emergency preparedness and response in the UK, as well as the multitude of supporting guidance to the Act, which is now several years old, in some places out of date (for example, by referring to regional architecture that was abolished several years ago) and should be updated to incorporate the most recent practise and learning from the Rockefeller 100 resilient cities programme etc.
3.11. As well as embedding the concept of resilience into the Act alongside preparedness, a review should look closely at the role of LRFs, which have been used as a key delivery mechanism for both EU exit planning and COVID-19. Both councils and LRFs have highlighted that recent expectations of LRFs go far beyond the statutory duties set out in the Act, which are focused on multi-agency planning, and have placed significant demands and associated resource challenges on the component organisations the LRF comprises. While councils and LRFs have risen to this challenge, there is a need for clarity about the future role of LRFs, their legal obligations, the organisations which should be sitting round the table for LRF planning discussions, and how their work will be funded.
3.12. Despite being used as the key tool of local planning and response delivery in relation to these two national events, councils (both individually and as part of LRFs) have experienced significant challenges relating to the timely release of critical information and planning assumptions that would enable them to plan at the local level. UK emergency planning doctrine is based on the principle of subsidiarity, and local partners are being tasked with a range of roles alongside their individual organisational responsibilities: however, the failure to share vital planning assumptions or relevant data with councils and their partners, in relation to both EU exit and COVID-19, not only hinders councils’ ability to protect their communities, but also raises questions of trust.
3.13. One council reported a COVID-19 meeting where health partners had information from the Department of Health and Social Care which they could not share with the council; and the council had information from MHCLG which it could not share with health partners. The Government needs to demonstrate a trust in local partners that is line with the demands it places on them by providing the timely information they need to fulfil their role, whatever the emergency, and remove barriers to information sharing that undermine local partnership working.
3.14. Alongside a review looking specifically at civil contingencies mechanisms, there must also be a comprehensive review of the wider Government response to COVID-19 to ensure that lessons are learned, changes can be made and resilience strengthened. We need to understand whether our national plans were up to date, and if not why not, and how we can ensure national strategies and plans are kept up to date in future. We also need to reflect on the fact that the most effective aspects of the response have been what has been delivered locally, by frontline services delivered by councils and their partners, and therefore how these services can be effectively engaged in planning and decision making to ensure a more localist approach from the outset.
3.15. In recent years, the Government has sought to promote good practice across LRFs through updating the resilience standards. We support the approach of specifying a core set of outcomes that allow for local variation in how different LRFs meet agreed goals. The Government has also explored the idea of introducing some form of assurance or peer review process for LRFs, something that the LGA would be keen to help develop further, based on our successful and extensive experience of the sector led improvement model in local government, including the recent development of a bespoke resilience peer challenge approach for London councils, which has been successfully piloted and well received.
3.16. Finally, CCS and RED should also consider how they may be able to free up stretched local emergency planning capacity through improved reporting processes and IT systems, better sharing of good practice (eg, around exercises) and providing increased national support for shared tasks undertaken by all LRFs.