Comment

Representation ID: 22615

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

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 CPS5.

The CCWMP requests that Policy CSP5 the requirement to consider the threat of terrorism and measures to minimise crime and anti-social behaviours which can be associated with large gatherings.

PPG (Paragraph: 011 Reference ID: 53-011-20190722) recognises that for all locations which will generate crowds in public places, consideration should be given to appropriate security measures in the design of buildings and spaces. Good counter-terrorism protective security can also support wider prevention. The PPG identifies a number of sources of guidance in this respect including ‘Protecting Crowded Places: Design and Technical Issues’, which refers to ‘Secured by Design and ‘Safer Parking’ standards.

The NPPF is clear in its requirement that local planning authorities should anticipate and address possible malicious threats, especially in locations where large numbers of people are expected to congregate. It states that, ‘Policies for the relevant areas (such as town centre and regeneration frameworks) and the layout and design of developments, should be informed by the most up-to-date information available from the police and other agencies about the nature of potential threats and their implications. This includes appropriate and proportionate steps that can be taken to reduce vulnerability, increase resilience and ensure public safety and security.’

The CCWMP therefore requests that the following wording be added to Policy CSP5 as follows:

‘An assessment will be required to be undertaken as part of the design of new developments where large numbers of people are expected to congregate to demonstrate, through a fully documented process, that potential security and crime related vulnerabilities have been identified, assessed and where necessary, addressed in a manner that is appropriate and proportionate.’