A “compelling” case exists for all conflict-related deaths to receive an independent review, the Police Service of Northern Ireland (PSNI) has said.
Institutions proposed by the Government will focus on the circumstances of 3,400 deaths and 47,000 people injured.
Reviewing all killings would provide the highest level of public confidence and give a greater sense of equality to all affected, the force added.
A Government consultation on legacy arrangements, including a criminal re-investigation unit and an information retrieval organisation, is closing this month.
The PSNI also raised concerns about resourcing of the review arrangements following the collapse of Stormont powersharing and warned of a shortage of detectives in the UK.
The police’s submission said: “The PSNI is of the view that there is a compelling argument for all Troubles-related deaths to receive an independent review by the Historical Investigations Unit (HIU).”
The 2014 Stormont House political agreement involving the British and Irish Governments and the main Northern Irish political parties envisaged a comprehensive mechanism for addressing the legacy of past violence, include creation of an HIU to comb old cases for opportunities for criminal prosecutions.
With many victims’ families unlikely to see prosecutions decades on, Stormont House also suggested an Independent Commission on Information Retrieval whereby they can obtain more knowledge about what happened to their loved ones in a non-prosecutorial setting.
An oral history collection would be made as part of the proposals.
In the absence of devolution at Stormont - the institutions have been suspended since last year - the Northern Ireland Office (NIO) is taking the matter forward through a public consultation.
Victims and families have frequently cited concerns about police independence in relation to legacy matters.
The PSNI’s submission said some of those affected may not have confidence in proposed processes surrounding disclosure of material and the proposed certification of cases for review.
The force said that meant that chief constable George Hamilton would in effect be determining the HIU’s workload.
“This could be perceived as the PSNI leading the director of HIU and thus undermining the independence of that office.”
Police could also have to certify as complete 1,800 cases considered by a previous team of detectives, the Historical Enquiries Team (HET), to provide assurance to victims.
The force said: “The chief constable is also mindful of the perception that PSNI is the gatekeeper of sensitive and secret information associated with Troubles-related deaths.
“Public confidence in policing is of paramount importance to PSNI and so the chief constable wishes to state clearly that we have no selfish ambition to retain exclusive control over that material during the life of the proposed institutions.”
George Clarke, assistant chief constable with responsibility for legacy issues, said staffing the new HIU with independent detectives could prove challenging since there was a shortage in other parts of the UK.
He said non-police investigators with current expertise could be recruited, thereby avoiding too heavy a reliance on a limited pool of retired detectives.
The PSNI said care should be taken to ensure that what was promised to victims could be delivered.
That required significant financial commitment, high levels of resources and careful planning.
Mr Clarke said it was important to avoid re-traumatising victims and give careful consideration to transitory arrangements before and after the institutions were constituted.
The Stormont House Agreement provided for £150 million of government funding, while further money would be made available through the devolved institutions at Stormont.
The PSNI said: “In the light of the current political impasse and the recent High Court judgments (restricting the ability of civil servants to take decisions without ministers), it is unclear how the proposed institutions will be funded and how decisions will be made in that regard.”
Funding the HIU will be dependent on the extent of its remit, the size of the caseload and the timeframe within which it is required to complete its work. Five years had been suggested.
Under the proposals the HIU could investigate the actions of former and serving police officers.
The PSNI said: “Misconduct investigations should not be limited to police officers only.
“A range of state bodies including police, army and security services operated within Northern Ireland during the Troubles and could, potentially, be suspected of having committed misconduct within their own roles.
“The limitation within the draft bill could restrict the ability of the HIU director to provide a clear and complete account to victims and families, and, in turn, the confidence of victims and families could be undermined.
“Consideration should be given to applying misconduct investigations to all State agencies.”