Comment

Representation ID: 22618

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 ENV9.

The CCWMP welcomes the proposed policy requirement that Design and Access Statements should demonstrate that a number of aspects of design have been addressed, including, ‘…d) consideration of crime prevention measures and Secured by Design principles, in addition to the requirements of Part Q of the Building Regulations 2010 or any successor legislation;…’ However, he considers the policy does not go far enough as it does not have a requirement for Secured by Design principles and Park Mark to be incorporated into development proposals.

The CCWMP recommends that the policy wording is amended as follows, modifications shown below:

‘2) Development will be designed to the highest possible standards, creating a strong sense of place. Development proposals must address as appropriate:…
f) the need to ensure crime prevention measures and Secured by Design and Park Mark principles are incorporated to reduce crime, the fear of crime and anti-social behaviour.’

The CCWMP welcomes the inclusion in paragraph 7 of the policy requirement that development must not cause a detrimental impact on the living environment of occupiers of existing residential properties, or unacceptable living conditions for future occupiers of new residential properties, including in terms of ‘h) crime and safety’.

He also welcomes the wording of justification paragraph 10.134 which explains that ‘A key objective for new developments should be that they create safe and accessible environments where crime, or the fear of crime, and anti-social behaviour do not undermine the quality of life, health or community cohesion. Good design, layout and spatial relationships (including the use of sensitively designed and located landscaping that reduces opportunities for anti-social behaviours) can make a positive contribution towards improving community safety in an area. It is the intention of the BCA and the police to work together towards the reduction of crime and the fear of crime, and anti-social behaviour across the Black Country. This will be a material consideration in all planning proposals.’

The CCWMP requests that reference is made within Justification paragraph 10.134, to the need for developers, as well as the local authorities, to engage with the West Midlands Police Design Out Crime Officers (DOCO) at the pre-application as well as the planning application stage.
 
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 HOU4.

The Government’s good practice guide on ‘Designing Gypsy and Traveller Sites’ published in 2008, recommends that consultation should take place with the Police on site security issues and the Police Architectural Liaison Officer’s advice should be sought on the design of specific schemes with the aim of ‘designing out’ crime and social exclusion and ‘designing in’ community safety and social inclusion.

The CCWMP therefore formally requests that the wording within Policy HOU4 be amended to state that there is a requirement to consult with West Midlands Police and to consider issues of security and the need to promote community safety, social inclusion create environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion.

The proposed modification to the policy is shown below:

‘5) The location, design and facilities provided on new sites will be determined in consultation with local gypsies and travellers and travelling show people and will also consider / reflect any available national guidance. Proposals for development will be expected to be well designed and laid out respecting Secured by Design principles. It is recommended that pre-application advice is sought from the West Midlands Police Design Out Crime Officers.’