Comment

Draft Black Country Plan

Representation ID: 22619

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 HOU6.

The CCWMP welcomes the Justification for Policy HOU6, paragraph 6.59 which explains that harmful impacts associated with high numbers of HMOs can include: ‘…g) increased anti-social behaviour and fear of crime resulting from the lifestyles of some HMO occupants, the transient nature of the accommodation and inadequately designed / maintained properties;…’

In order to properly address this potential harmful impact, the CCWMP considers it is important for there to be a specific reference within the policy itself. He recommends a modification to introduce a new policy paragraph after bullet point b. as follows:

‘c. would not give rise to unacceptable adverse cumulative impacts on security, crime, anti-social behaviour and the fear of crime.’