Comment

Representation ID: 45920

Received: 29/09/2021

Respondent: Chief Constable of West Midlands Police (CCWMP)

Agent: Tyler-Parkes

Policy CEN1 – The Black Country Centres



48. The large sale of population and housing growth proposed in the draft BCP will impact
on the use and operation of the centres. Policy CEN1 encourages the expansion of
the leisure evening economy.



49. The CCWMP objects to the lack of appropriate wording within Policy CN1 policy to
address the expansion of the leisure evening economy which will impact Policing. It
would be unsound for the impact of this significant area of growth and development to
be ignored as it could potentially undermine the Plan’s vision and objectives and the
sustainable development objectives of the NPPF.



50. The CCWMP considers that the general objectives of evening specific issues for any
decision-maker include: ensuring a thriving, vibrant economy where people can feel
safe, with reduced crime and a reduction in the fear of crime.



51. The problems of the evening economy can include: if crime or the fear of crime
increases, people will not feel safe, are unlikely to use the entertainment/night-time
facilities, with the potential of an economic spiral of decline. This can result in the
closure of bars, restaurants and shops, less people being attracted to the area, leading
to the closure of more premises and companies going out of business.

52. Safety issues of particular relevance to the evening economy include for example:



• Access to and from the facilities (e.g., nearby public transport network,
access to taxis and private-hire vehicles);
• Safe and reasonably-priced parking facilities (well-lit, accessible car
parks where people feel safe, with CCTV and good access control)
meeting the standards set in the NPCC Park Mark accreditation scheme;
• Well-run premises, with qualified/licenced door staff, who are able to deal
with the conflict and problems associated with such premises, as well as
presenting a welcoming ‘customer-service’ approach to people visiting
the City and the premises concerned;
• CCTV facilities within bars, clubs and restaurants;
• Licensed premises and ‘change of use’ planning applications;
• Hot food takeaways/late-night refreshment houses can be the flashpoint
for violence after the pubs and clubs close;
• Late opening off-licences and small retail stores (that sell alcohol) tend
to be ‘honey pots’, i.e. areas where people tend to linger for longer than
they would normally do so and attract increased levels of anti-social
behaviour;
• Position of Automated Teller Machines (ATM) both ‘hole in the wall’ and ‘stand-alone’. These are often situated in night-time economy areas and
can become ‘crime-generators’;
• ATMs and ATM replenishments. Across the UK there have been an
increased number of physical attacks on ATMs, including the use of gas
and ‘cash in transit’ robberies from cash vans, of particular concern
where an apartment or dwelling is above the premises.



53. The CCWMP requests that the policy be modified by the introduction of the following
text shown in bold:



‘In order to have a successful evening economy it is important
that a variety of facilities, appealing to a wide range of age and
social groups, are offered and that these are provided in such a
way to ensure a safe, accessible and inclusive environment and
any anti-social behaviour is discouraged, for example through
management, improved lighting and CCTV coverage where
appropriate.’



54. In addition, just as has been highlighted in response to Policy CSP5 ‘Cultural Facilities
and the Visitor Economy’ the CCWMP highlights the need to consider the threat of
terrorism and measures to minimise crime and anti-social behaviours which can be
associated with large gatherings, such as in town centres.



55. All locations which will generate crowds in public places should consider the need for
appropriate security measures in the design of buildings and spaces. Good counter-
terrorism protective security can also support wider prevention. 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.



56. 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.’



57. The CCWMP therefore requests that the following wording be added to Policy CEN1
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.’