Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 15250
Received: 11/12/2020
Respondent: West Midlands Police
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
P1 is unsound on the basis that that given the scale and type of development proposed in the hub area, there should be express reference in the policy to the need for financial contributions towards the additional expenditure burden placed on West Midlands Police.
- West Midlands Police has a statutory duty to secure maintenance of efficient and effective police force for its area
- Policy P1 and its supporting text omits any reference to the fact that development proposals within the hub should be expected to demonstrate how they have considered security and safety.
- Council statutorily required to consider crime, disorder and community safety in exercise of its duties, with aim to reduce crime. Planning policies therefore require the theme of community safety and crime prevention be given prominence in the Solihull Local Plan Review, which is vital in the context of creating sustainable communities.
- NPPF and PPG refer to designing out crime, supporting safe communities, working with police and security agencies, importance of considering and addressing crime and disorder, and fear of crime.
- PPG provides for planning obligations in policy requirements, understanding infrastructure evidence and costs and guidance for CIL.
- In order to sustain the level of growth proposed in the SLP Draft Submission Plan, in particular in relation to Policy P1 and to meet national and local policy objectives relating to safety and security, contributions will be required through S.106 agreements and/or CIL payments to help fund the provision and maintenance of Police services. It is vital that Police are not deprived of legitimate sources of funding so they’re not under-resourced
- If additional infrastructure for WMP is not provided, then Police’s ability to provide a safe and appropriate level of service will be seriously impacted by level of growth in the DSP.
- Important to note that increase in local population or number of households does not directly lead to an increase in central government funding or local taxation.
- Viability Assessment shows that police contributions are viable.
The omission of an explicit reference to the need for financial contributions for Police infrastructure in the overarching UK Central Hub policy of the Plan or in its supporting text, renders the policy ineffective and inconsistent with national policy and is therefore unsound.
On behalf of the CCWMP the following modifications are proposed to Policy P1 paragraph 3 and the supporting text (additions in “ “): ‘Policy P1 UK Central Solihull Hub Area
Policy wording insert:
3.
vi. Create distinct and unique places ”that are safe with a strong sense of identity, incorporating high quality design which meets ‘Secured by Design’ standards to reduce crime and the fear of crime”, innovation for development and the public realm, whilst maximising the efficient use of land;
vx. "Provide for contributions towards measures to mitigate the impact of development and make it acceptable in planning terms by providing for physical, social, green and digital infrastructure as identified in Policy P21, the Infrastructure Delivery Plan and the hub Framework Plan;"
x. "Maximise partnership working with infrastructure providers, including those identified in the Infrastructure Delivery Plan in particular, in relation to issues of security and safety;"
xi. "Support the evening economy by providing facilities in such a way as to ensure safe, secure, accessible and inclusive environments so that crime, the fear of crime and anti-social behaviour are minimised."
In terms of the supporting text, the following modifications are sought (additions in " "):
Paragraph 82:
The Policy sets out the key objectives that development will be expected to contribute towards, including sustainable and economic growth "and the need for development to achieve ‘Secured by Design’ standards to promote safe and secure environments, the provision of necessary infrastructure, including social infrastructure and ensuring that in terms of the evening economy, facilities are secure, inclusive and accessible." Growth that is inclusive should demonstrate that the benefits will accrue to all by building on the strengths of communities, ensuring that wealth is more evenly spread and enabling everyone to contribute and participate.’
See attached representations forms