Object
Solihull Local Plan (Draft Submission) 2020
Representation ID: 15252
Received: 11/12/2020
Respondent: West Midlands Police
Agent: Tyler Parkes Partnership Ltd
Legally compliant? Yes
Sound? No
Duty to co-operate? Yes
- It is submitted that Policy P21 is unsound on the basis that there is an omission of an explicit reference to Police infrastructure in the overarching infrastructure policy of the Plan or its supporting text which is inconsistent with national policy. The recognition in Policy P21 that major development will be expected to provide, or contribute towards provision of ‘social’ infrastructure, to support the needs associated with development and the fact that it confirms that the Council will, where appropriate, seek to secure site-specific, mitigation measures through planning obligations or CIL payments is welcomed and supported
- 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.
- 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. It is contended that, as worded Policy P21, is not effective and is inconsistent with national policy as set out in paragraph 34 of the NPPF.
- The term ‘social’ infrastructure is not defined in the Policy P21 nor in the supporting explanatory text. Policy P21 makes no reference to the Draft Infrastructure Delivery Plan and Police infrastructure is not identified as being included within the term ‘social’ infrastructure within the Draft Submission Plan.
- 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.
- 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.
The CCWMP has a statutory duty to secure the maintenance of an efficient and effective Police force for its area, and the Council has a statutory requirement to consider crime, disorder and community safety in the exercise of its planning functions.
In terms of Policy P21, the inclusion of ‘social’ infrastructure within the policy is welcomed, but it is contended that the omission of an explicit reference to Police infrastructure in the overarching infrastructure policy of the Plan or its supporting text, is inconsistent with national policy and therefore is unsound.
The following modifications are proposed to Policy P21 and its supporting text (additions in " "):
Policy P21 Developer Contributions and Infrastructure Provision:
ii. Physical, social, green and digital infrastructure to support the needs associated with the development "as identified in the Infrastructure Delivery Plan. Social infrastructure includes emergency services infrastructure."
7. The Council will work in partnership with infrastructure providers, "including those identified in the Infrastructure Delivery Plan."
In terms of the supporting text, the CCWMP suggests the following modifications (additions in " "):
Paragraph 481:
‘Planning for infrastructure is an essential element in delivering the local plan. Infrastructure in this sense is not just the physical infrastructure such as roads and
pipes, but also the social, green and digital infrastructure (e.g. health care, open spaces, community facilities, "emergency services infrastructure" etc.) required
to enable sustainable development’.
Paragraph 484:
‘New development will be expected to meet its own physical infrastructure needs, such as on-site provision of utilities or a new road junction to access a site. Where
new development puts pressure on social or green infrastructure, or creates a need, e.g. for new community facilities, open space "or on the emergency
services, including the Police", then provision will also have to be made for these………..’
Paragraph 502
‘In preparing the Local Plan, the Council has considered the requirements of other public service providers, "including the emergency services". Delivering many of
these services will be critical to delivering the Local Plan objectives. The Council will work with these service providers in delivering the Local Plan in "accordance
with infrastructure contributions set out in the Infrastructure Delivery Plan’."
See attached representations forms