Solihull Local Plan (Draft Submission) 2020

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Object

Solihull Local Plan (Draft Submission) 2020

Policy HA2 - Oak Farm, Catherine-de-Barnes

Representation ID: 14908

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Support

Solihull Local Plan (Draft Submission) 2020

Policy HH1 - Land South of School Road, Hockley Heath

Representation ID: 14909

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy KN1 - Hampton Road, Knowle

Representation ID: 14910

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy KN2 : South of Knowle (Arden Triangle)

Representation ID: 14911

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy ME1 - West of Meriden (Between Birmingham Road and Maxstoke Road)

Representation ID: 14912

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy SO1 - East of Solihull

Representation ID: 14913

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy S02 - Moat Lane Depot

Representation ID: 14914

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy UK1 - HS2 Interchange

Representation ID: 14915

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Representation Summary:

- 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.
- 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.
- Site policies should include more social infrastructure, such as ‘emergency services’ within likely infrastructure requirements, as within 2013 Local Plan.
- Site policies are unsound without reference to need for financial contributions to police infrastructure in list of ‘likely infrastructure requirements’
- Site policies are unsound without cross-referencing need to comply Policy P15
- Site policies are contrary to the requirements of NPPF Para.’s 34, 91, 95 and 127f) and PPG Para: 004 ID: 23b-004-20190901, Para: 017 ID: 25-017-20190901, and Para: 144 ID: 25-144-20190901.

Change suggested by respondent:

- An additional sub-paragraph to be included under Paragraph “Development of this site should be consistent with the principles of the Concept Masterplan for this site, which includes the following”:
‘Create a place which is 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 and to this end applicants are encouraged to engage with the West Midlands Crime Prevention Advisor at the earliest opportunity.’

- An additional sub-paragraph to be included Paragraph “Likely infrastructure requirements will include”:
Developer contributions to Police infrastructure to ensure an appropriate level of service can be maintained so that crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P1 UK Central Solihull Hub Area

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

Representation Summary:

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.

Change suggested by respondent:

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.’

Full text:

See attached representations forms

Attachments:

Object

Solihull Local Plan (Draft Submission) 2020

Policy P2 Maintain Strong, Competitive Town Centres

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

Representation Summary:

- 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.

Change suggested by respondent:

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."

Full text:

See attached representations forms

Attachments:

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