Solihull Local Plan (Draft Submission) 2020

Object

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.

Support

Representation ID: 15253

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Policy P14 ‘Amenity’ is supported as worded, as it is consistent with national policy and therefore sound.
Policy P14 confirms (paragraph 1i), that the Council will permit new development, extensions and changes of use only if such proposals secure high quality design by reference to Policy P15 (Design). It also confirms (paragraph 1 vii), that the Council will protect residential and shopping areas, community facilities and open space from the introduction of incompatible development or anti-social uses that may jeopardise local amenity. Policy P15 confirms that all development proposals must be of high quality design which will be expected to adhere to specified principles including creating safe places, and reducing crime and the fear of crime through the adoption of Secured by Design principles and The National Design Guide 2019. These references in Policy P14 and P15 are welcomed.
The Police Design Out Crime Team, Senior Leadership Team and Local Policing Unit should be effectively engaged in the planning and design process in relation to matters likely to affect crime and the fear of crime, in the preparation of masterplans and policy implementation.
Policy P14, is supported as worded, as it is consistent with national policy and therefore sound.

Support

Representation ID: 15254

Received: 11/12/2020

Respondent: West Midlands Police

Agent: Tyler Parkes Partnership Ltd

Policy P15 ‘Securing Design Quality’ is supported as worded, as it is consistent with national policy and therefore sound.
Policy P15 confirms (paragraph 1), that all new development must be of high quality design. It also confirms (paragraph 2), that development proposals will be expected to create safe streets and public spaces (paragraph 2 vii) and should contribute positively to the creation of high quality places (paragraph 2 ix), emphasising that the design and layout of developments should reduce crime and the fear of crime through the adoption of Secured by Design standards. These references within Policy P15 are welcomed and supported.
The Police Design Out Crime Team, Senior Leadership Team and Local Policing Unit should be effectively engaged in the planning and design process in relation to matters likely to affect crime and the fear of crime, in the preparation of masterplans and policy implementation.
In terms of Policy P15, the policy as worded is supported as being consistent with national policy and therefore sound.