Comment

Draft Black Country Plan

Representation ID: 22614

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

Representation Summary:

The Tyler Parkes Partneship Ltd act for the Chief Constable of West Midlands Police (CCWMP).

This Comments Form TOGETHER WITH the accompanying letter dated 29th September 2021 comprise the CCWMP's representations on Policy CSP4.

The CCWMP welcomes the assertion at policy CSP4 paragraph 5 in the Draft Black country plan (BCP) that, ‘…The Black Country will be a safe and secure place to live and work in, through organising the urban environment in ways that encourage people to act in a civil and responsible manner. Development proposals will be required to provide active frontages, well-located, safe and accessible pedestrian and cycle infrastructure and an appropriate intensity of use in centres and elsewhere. Designs should promote natural surveillance and defensible spaces.’

He also welcomes the supporting justification explanation at paragraph 3.52 that, ‘The aim of the Black Country Plan is to create the conditions for economic and social growth, which will take place within a safe, attractive and accessible built and natural environment. The BCP also encourages and supports the growth of locations that encourage participation and community engagement. Successful placemaking in the Black Country will foster community stability and incorporate elements that create resilience to adverse economic and environmental impacts…’

However, the CCWMP objects to the omission of any reference to the ‘Secured By Design’ guide and the ‘Park Mark’ parking standards which would ensure a consistency in designing out crime standards. It is recommended that the following modification to the policy be included:
'…Designs should promote natural surveillance and defensible space. All new development should include consideration of crime prevention measures, Secured by Design, Park Mark principles, and the need for a maintenance plan to reduce crime, the fear of crime and anti-social behaviour.’