Comment

Representation ID: 22616

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; and letter dated 9th July 202 (with two Appendices) comprise the CCWMP's representations on Policy DEL1.

The Draft BCP sets out the anticipated housing and employment requirements for the Black Country area as 76,076 dwellings and 565 ha of employment land. This would mean increasing housing delivery across the Black Country from 2,600 homes per year to 4,000 homes per year. Whilst the Draft Plan currently proposes to allocate only around 1,200 hectares of housing land to provide approximately 47,837 dwellings and 354ha of employment land leaving a shortfall of 28,239 homes and 211 ha of employment land, this still represents a very significant increase in population numbers and development overall.

To achieve sustainable development, as required by the NPPF and PPG, the necessary support infrastructure must be identified through proactive engagement between the Councils and the infrastructure providers, including the Police. Infrastructure needs and costs arising as a result of the proposed growth in the Plan should be included in the Infrastructure Delivery Plan (IDP) and Viability and Delivery Study and specific requirements should be clearly set out in the individual site allocation policies and/or accompanying masterplan, Development Plan, Area Action Plans (AAPs) or Supplementary Planning Documents (SPDs), to ensure that developers are aware of their obligations at the outset.

The CCWMP is grateful for the inclusion in the Viability and Delivery Study of an indicative contribution of £43.00 per dwelling towards the funding gap in Police infrastructure arising from the need for additional services arising directly from the proposed scale of growth, as per our preliminary infrastructure shortfall evidence letter dated, 9th July 2020 (included with this letter for your ease of reference). However, he objects to the failure of the Councils to carry this need for financial contributions in the form of CIL/S106 forward into the policy or Justification text.

As set out in our letter last year, health and safety planning harm will result if West Midlands Police do not have the necessary funding to maintain an appropriate level of service for existing and for future residents, work and visitors within the four local authority areas. The CCWMP therefore formally requests that the Councils engage with West Midlands Police to ensure that the plan addresses the need for sustainable safe developments supported by essential infrastructure.

Whilst Justification paragraph 4.24 states that, ‘…There will also be locally specified requirements, such as crime prevention measures…’, this does not make clear that West Midlands Police function on a centralised shared resource basis, meaning that it is most appropriate to seek developer contributions from each dwelling within the medium to higher value zones where development has been assessed as viable. Funds will then be pooled to ensure the level of service can be maintained allowing the CCWMP to provide the same quality of Police service to residents in new developments.

The CCWMP recommends the Justification test be modified as follows:

‘4.24 4.24 …There will also be locally specified requirements, such as crime prevention measures and, where viable in the medium to higher value zones, a requirement for financial contributions (an amount per dwelling) towards Police infrastructure.’