The Public Protection and Enforcement Policy Development & Scrutiny Committee of Bromley Council scheduled a meeting to discuss public safety, environmental issues, and budget concerns. The agenda included updates on the Regulation of Investigatory Powers Act 2000 (RIPA), a mortuary contract, budget monitoring, planning enforcement, fly-tipping, and the Safer Bromley Partnership. A key focus was to be a deep dive into the council's neighbourhood enforcement services.

PPE Neighbourhood Enforcement Services

A briefing paper on Neighbourhood Enforcement Services was prepared for discussion. The Neighbourhood Management (NM) service is described as the operational lead for protecting public spaces and delivering contracted waste services. It enforces a range of statutory duties to keep streets and open spaces safe, clean and accessible for residents, investigating environmental offences such as fly-tipping, offences under the Highways Act, and breaches of the Environmental Protection Act.

The paper was intended to provide committee members with context, key risks, and strategic options to support direction-setting at a time of rising demand and constrained resources.

The scheduled scope of enforcement included:

• Illegal waste deposits on public land
• Organised Crime Groups (waste OCG)
• Surveillance activities conducted under RIPA
• Littering enforcement
• Dog fouling enforcement
• Abandoned and untaxed vehicles
• Illegal waste carrying
• Highway obstructions
• Overhanging vegetation enforcement (OHV)
• Commercial waste Duty of Care compliance
• Unauthorised Encampments (UAE)
• Damage to the Highway
• Encroachment of the Highway
• Vehicles for sale or repair on the Highway
• Skips, hoarding and portable sanitary units
• Unlawful crossing and excavations
• Unauthorised signage
• Water/residue escape causing hazard to highway users

The report noted recent achievements including increased investigative capacity and effectiveness through targeted investments in technology, partnerships and team development, strengthened collaboration with the Environment Agency, police, Sevenoaks and Kent County Council, plus improved internal problem-solving.

The report also noted that effective environmental investigations and enforcement require two complementary capabilities:

• NIOs: Specialist investigators
• NEOs: Dedicated, visible uniformed enforcement officers focused on rapid, place-based responses

Since January 2024 five APCOA officers were integrated into the Neighbourhood Investigations team as Neighbourhood Enforcement Officers (NEOs), providing targeted boots-on-the-ground capacity for hotspot patrols and rapid FPN deployment.

The report also gave details of the council's use of vehicle seizure, overt CCTV, covert CCTV, RPAS (drones), injunctions, Section 34 Producer Notices, and Open-Source Data.

The report highlighted that the Neighbourhood Investigations team is experiencing growing demand driven by shifting offending patterns, expanded surveillance capability and increasingly complex investigations, and posed five questions for policy development:

1. How can the Council best balance proactive and reactive enforcement given current resource constraints?
2. What additional administrative or partnership support is needed to sustain and scale enforcement activity?
3. How effective are the current enforcement tools (FPNs, CPWs, CPNs, prosecutions, injunctions) in changing behaviour and deterring repeat offenders?
4. What are the risks and opportunities associated with expanding surveillance technologies (CCTV, drones, open-source data) for environmental enforcement?
5. How can the Council strengthen coordination with national agencies and neighbouring authorities to address organised waste crime and cross-border offending?

Fly-Tipping Action Plan Update

The committee was scheduled to discuss an update on the council's fly-tipping action plan¹. The report noted that there were 6,981 instances of 'dumped rubbish' reported via the Fix My Street system in 2024/25, compared to 4,619 the previous year. The report stated that the increase in reports could be attributed to the integration between Fix My Street and the street cleansing ECHO logistics system. It also noted that the temporary closure of Waldo Road Reuse and Recycling Centre occurred during February 2025, but that this was unlikely to have had a direct influence on the increased reports.

Between 1 October 2024 and 30 September 2025, the Neighbourhood Investigation Team secured the following enforcement outcomes:

• 210 Investigations
• 3 Warning Letters
• 10 Community Protection Warnings
• 20 Formal Notices
• 93 Fixed Penalty notices
• 11 Vehicle Seizures
• 1 Civil Injunction
• 17 Successful Prosecutions

The report also noted that the Parking Services contract held with APCOA was amended in January 2024 to provide additional resource by introducing uniformed Neighbourhood Enforcement Officers, and that to date 6,054 Fixed Penalty Notices have been issued, with 64 cases successfully prosecuted at court and a further 14 cases referred to Legal Services for prosecution due to non-payment of the Fixed Penalty.

The report recommended that the Portfolio Holder for Public Protection & Enforcement agree to increase the amount payable for Fixed Penalty Notices for littering to £150, for Householder Duty Of Care to £250, and for Business Duty Of Care to £500.

Public Protection and Enforcement Performance Overview

The committee was scheduled to review performance against indicators in the Public Protection & Enforcement Portfolio Plan 2024/25 for July to September 2025. The plan includes five priorities aligned to the council's corporate strategy:

• Keeping Bromley safe
• Protecting consumers
• Supporting and regulating businesses
• Protecting and improving the environment
• Providing value for money

The report stated that all key performance indicators for this plan were risk rated as green for Quarter 2 of this financial year.

Annual Update - Regulation of Investigatory Powers Act 2000

The committee was scheduled to receive an annual update on the council's use of powers under the Regulation of Investigatory Powers Act 2000 (RIPA). The report noted that there is a requirement in the 2018 Code of Practice for Covert Surveillance and Property Interference that elected members are kept informed about the council's use of powers under RIPA.

The report stated that in 2024, the council made one application for directed surveillance in connection with a fly-tipping investigation, and that since 2018 the council has obtained 12 sets of communications data of individuals from mobile telecoms providers indirectly through another agency, under the Investigatory Powers Act 2016.

Direct Award of Contract for the Mortuary Service

The committee was scheduled to discuss a report seeking approval to award a new contract for mortuary services to King's College Hospital NHS Foundation Trust via direct award. The report noted that the current contract, awarded via direct award in 2019 following a failed tender, is due to expire on 31 December 2025, and that the Trust remains the only viable provider within the HM South London Coronial District.

The report recommended that the Portfolio Holder for Public Protection and Enforcement approve the direct award of the Mortuary Services Contract to King's College Hospital NHS Foundation Trust for an initial period of three years, commencing on 1 January 2026, with an option to extend for a further three years, resulting in a whole life value of £2.28 million.

Budget Monitoring 2025/26

The committee was scheduled to discuss a report setting out the results of the quarterly revenue budget monitoring exercise for the 2025/26 financial year for the Public Protection & Enforcement Portfolio. The report stated that the position for quarter two for the Portfolio is showing a breakeven position based on financial information available at that time.

Safer Bromley Partnership Update

The committee was scheduled to receive an update on the activities, initiatives, and progress of the Safer Bromley Partnership (SBP). The SBP brings together statutory agencies, Bromley Council, Metropolitan Police, London Fire Brigade, Public Health, South East London Integrated Care Board and National Probation Service, commissioned services and community and voluntary representatives.

The report noted that the SBP Responsible Authority Group met on 16 October 2025, and that the Counter Terrorism Strategy (CONTEST) was discussed, and the Bromley PREVENT Duty Risk Assessment 2025 was scrutinised and agreed.

The report also noted that the SBP Group meeting received presentations on the Bromley Youth Justice Service (YJS) Stop and Search Workshop and Evaluation, the IRIS Programme, and measures to combat Retail Crime.

Planning Enforcement Actions Progress and Monitoring Report April 2024 to March 2025

The committee was scheduled to receive an update on the progress of current cases where planning enforcement action has been taken or is pending consideration. The report included cases currently at appeal, those awaiting compliance periods, prosecution cases awaiting action, cases with authorised enforcement, cases with the legal department for further action, cases where direct action has been authorised, and cases that have been closed.

The report noted that since 1 April 2024 a Call In Process was implemented, whereby Ward Councillors are notified of proposed enforcement action and given five working days to request that the matter be referred to the Plans Sub-Committee.

The report also noted that a total of 76 enforcement notices were served in connection with breaches of planning control between April 2024 and March 2025, and 22 between April 2025 and September 2025, and that a total of 686 cases have been closed between April 2024 and March 2025, and 282 cases have been closed between April 2025 to September 2025.

The report also included a list of tree enforcement and planning enforcement prosecution cases in progress, and a list of cases where delegated authority action has been approved between April 2024 and September 2025.

PP&E Risk Register

The committee was scheduled to receive the revised Public Protection and Enforcement Risk Register for scrutiny. The report noted that the Risk Register forms part of the Annual Governance Statement evidence-base and has been reviewed by the Environment and Public Protection Departmental Management Team and Corporate Risk Management Group.

The report stated that the Public Protection and Enforcement Portfolio currently has 13 risks, and that the key changes to the register since November 2024 are that there have been no score changes to the register, and no new risks added or removed.

Corporate Contracts Register

The committee was scheduled to receive an extract from the Corporate Contracts Register of contracts with a whole life value of £50k or higher, for detailed scrutiny. The report noted that the Council has 298 active contracts across all Portfolios as of 1 November 2025, and that the Public Protection & Enforcement Portfolio has 8 contracts.

The report also noted that a simple Part 1 report is provided every other quarter, accompanied by a Part 2 report to provide additional commentary only where a contract has been flagged for attention by the Corporate Procurement Team, and that a full report is provided twice a year (May and November) including a detailed Part 2 report which includes a commentary and RAG rating on each relevant contract to inform Members of any issues or developments.