Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 15251
Received: 11/12/2020
Respondent: West Midlands Police
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
- Policy P2 ‘Maintain Strong, Competitive Town Centres is unsound on the basis that it is contended that given the scale and type of development proposed in Solihull Town Centre, there should be express reference in the policy to the need for financial contributions towards the additional expenditure burden placed on West Midlands Police; as an element of social infrastructure required to deliver sustainable development, to ensure that safety and security can be maintained across the Borough, as anticipated in the Draft Solihull Town Centre Masterplan (TCM) 2020.
- West Midlands Police has a statutory duty to secure maintenance of efficient and effective police force for its area
- 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. Policy P2 and its supporting text omits any reference to the fact that development proposals within Solihull Town Centre should be expected to demonstrate how they have considered security and safety and how they achieve Secured by Design standards across the entirety of the area.
- 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.
- 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.
- Considered therefore contributions to policing are essential for delivery of DSP, and should be expressly stated in site policies and P21, not just Draft Infrastructure Delivery Plan.
- It is submitted that the omission of a reference to the evening economy within the wording of Policy P2 renders the policy inconsistent with national policy and, therefore, is unsound.
he following modifications to Policy P2 paragraph 3 and the supporting text are
sought (additions in " "):
‘Policy P2 Maintain Strong, Competitive Town Centres
Solihull Town Centre
……………………………………………………………………………………
3. The Town centre Masterplan establishes a number of principles:
v. The need to ensure that the provision of parking in the town centre meets the needs of retailers and businesses, whilst not acting as a constraint to development or mode shift "and which meets ‘Park Mark’ standards."
vi. The value of good urban design and green infrastructure for the town centre which meets "‘Secured by Design’ standards to reduce crime and the fear of crime," and the importance of creating legible, distinctive, flexible, attractive, safe and inclusive public realm throughout the town centre.
viii. "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.’"
ix. "Maximise partnership working with infrastructure providers, including those identified in the Infrastructure Delivery Plan in particular, in relation to issues of security and safety;"
x. "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, and the Infrastructure Delivery Plan."
In terms of the supporting text, the following modifications are requested (additions in " "):
Paragraph 124:
‘High quality urban design will therefore be expected to ensure that development will protect the character of the Centre’s historic heritage, improve public realm and
improve pedestrian movement around the centre, for example to improve links to the Centre’s parks and provide improved articulation between Touchwood and
nearby open spaces and improve the pedestrian link between Mell Square and the Warwick Road Morrison’s store which has poor public realm. Design principles that
developers will be expected to follow are identified in the policy. "All development should meet ‘Secured by Design’ and ‘Park Mark’ standards to promote safety and security in the town centre, minimising crime, the fear of crime and antisocial behaviour. This is particularly relevant in terms of facilities and services relating to the evening economy, which should be designed to create
safe, secure, accessible and inclusive places."
See attached representations forms