Policy DEL1 – Infrastructure Provision

Comment

Representation ID: 12895

Received: 10/10/2021

Respondent: Dr Sarah Harris-Darley

I am also concerned about the impact of the multiple proposed sites in terms of sheer numbers of
people moving in to the area - what are the plans to enable schools and other local services to cope
with higher numbers? I am a local doctor and local GP Practices are already totally overwhelmed
with demand.

Comment

Representation ID: 13016

Received: 09/10/2021

Respondent: Mr Phillip Tapper

[Sutton Road] area is oversubscribed and has no doctors, health centres and schools overfull already.

Comment

Representation ID: 13481

Received: 24/09/2021

Respondent: Mrs Beryl Baldock

Building on these green spaces ... will put more pressure on our schools and emergency services

Object

Representation ID: 13731

Received: 06/10/2021

Respondent: Miss Jodie Hannon

We do NOT have enough resources such as they are already stretched beyond their limits!

Object

Representation ID: 13784

Received: 08/10/2021

Respondent: Miss Lisa Whitehouse

This will create more stress on the infrastructure, which is not fit for purpose now. I dread to think how bad our local services roads, education etc will be with a glut of new homes in the area and an influx of people. I personally know how stretched services are now, [Redacted-GDPR]. The BCP is going to add even more pressure on services, local Drs, schools, the services we pay for.

Object

Representation ID: 13799

Received: 08/10/2021

Respondent: Mr B Tolley

Not enough school places

Comment

Representation ID: 14841

Received: 10/10/2021

Respondent: Alison Wilkes

Policy DEL1
4.24
Comment: Accessible high-quality greenspace is important to local communities, as demonstrated in lockdown and in scientific research. Investment is required to ensure this and so public open space should be included in the list of infrastructure provision to ensure future development is sustainable.

Object

Representation ID: 16792

Received: 11/10/2021

Respondent: Ms Jenny Matthews

The more people who live in an area there is also need for more support services and infrastructure. This has been neglected in the past with the result that local roads are grossly over crowded.

Object

Representation ID: 16936

Received: 08/10/2021

Respondent: Mr Mark Francis

My objection is based on infrastructure plans.
Specific comment relates to Aldridge Road in Streetly.

Already conjected urban areas suffer from issues of infrastructure and schools.

How approx 1000 dwellings are able to intigate needs to be provided

Aldridge Road is a small single track road served by Queslett road which is most day conjested and bucks up around the Asda/Old Horns island. Additional residents will simply add to a disagreeable situation. Other road are Doe Bank Rd which is a residential road. How does road especially deal with increase

Equally 1000 house will provide children of school age Reasonable guide say 250. How and where does existing non extendable schools both primary and secondary cope/deal

Barr Beacon/Streetly are normally oversubscribed and Lindens is a single class/year school.

My objection is based on infrastructure plans.

Comment

Representation ID: 17148

Received: 11/10/2021

Respondent: Worcestershire County Council

Worcestershire County Council and Worcestershire Children First have noted the proposed allocations within the Draft Black Country Plan, with particular reference to cross-border educational impact.
Planned housing development sites have been identified within close proximity to the border between the Black Country and Worcestershire. It is envisaged that a small proportion of the Black Country’s pupil yield will commute to schools within Worcestershire, increasing the number of pupils at schools along the border, namely at Hagley and Romsley.
We shall continue to monitor the impact of housing growth on Worcestershire schools in and around the local area and will respond appropriately to ensure a sufficiency of school places, in line with current published policies.
We will continue to work with schools serving the local area to protect and enhance school assets and playing fields, in line with Government policies on the delivery of statutory education provision.

Object

Representation ID: 17158

Received: 11/10/2021

Respondent: Worcestershire County Council

Transport and Infrastructure Policies
Within the emerging Plan, there are a number of policies relevant to transport and of interest to WCC Highways. We particularly welcome policies DEL1 - Infrastructure Provision, Tran1 - Priorities for the Development of the Transport Network, and Tran3 - Managing Transport Impacts of New Development. Having reviewed these policies in detail, we feel there may be some minor amendments that may be beneficial in positively supporting the delivery of planned growth. We look forward to discussing these with you as we further engage to progress the transport evidence base.

Support

Representation ID: 17540

Received: 11/10/2021

Respondent: Sport England

Sport England is generally supportive of this policy which serves to ensure that required social infrastructure is provided to meet the respective development's needs, noting that sport and recreation facilities are expressly included in para 4.24 which defines the Council's broad list of infrastructure within the scope of this policy. The policy refers in part 1) to ensuring all new developments mitigate its impacts. Part 5) of the policy states that proposals that are unable to comply with BCP policies on viability grounds must be accompanied by a detailed Financial Viability Assessment. When read together, this potentially creates an unintended consequence that mitigation for loss might not be required under the terms of this policy where it is not viable to do so. Sport England would object to the loss any existing sports facilities, including loss of playing field that has not been appropriately mitigated in line with para 99 of the NPPF, Sport England's Planning for Sport Guidance, and Playing Fields Policy and Guidance on grounds that it would be unviable to do so. This would not be consistent with national policy since there is no viability criteria to para 99 of the NPPF. This could be addressed by ensuring that the wording of part 5) of the policy is amended to make clarify that this does not relate to mitigating the impacts of the development, and that viability testing relates solely to required infrastructure to meet the needs of the proposed development. The Council have commissioned a new Black Country-wide Playing Pitch and Outdoor Sports Strategy (PPOSS) which will assess the needs for outdoor sports facilities arising from the planned housing growth in the proposed plan. Sport England considers that the PPOSS should be added to the list of relevant evidence for this policy on page 62, ensuring that the PPOSS is then referred to in respect of infrastructure needs for outdoor sport when applying this policy.

Comment

Representation ID: 17875

Received: 10/10/2021

Respondent: Mr Peter Hepworth

Given the climate crisis all plans should incorporate the following requirements:
3) Housing developments to be supported by appropriate infrastructure in terms of schools, shops,
pubs, restaurants, public transport, etc, plus segregated pedestrian and cycle routes.

Object

Representation ID: 17905

Received: 04/10/2021

Respondent: Mr & Mrs Peter & Cheryl Norris

Not sufficient infrastructure to accommodate any further housing projects
I.e. schools, policing, doctors, fire services
Over the years new housing
i.e. Clockhill Wood - top common area
ryder hayes at least 3 developments
Jacksons Farm area
Hilltop Estate
Slackey Lane
Moat Farm
Charles Crescent Estate
The village can no longer accommodate any more housing projects

Comment

Representation ID: 18464

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.5 - "Policy DEL1 should be revised to identify these key tests set out in national policy to ensure all obligations required by DEL1 are properly justified."

Comment

Representation ID: 18465

Received: 11/10/2021

Respondent: L&Q Estates

Agent: Pegasus Group

Paragraph 4.6 - "Similarly, Criterions 4 and 5 refer to viability assessments. These should also reflect paragraph 58 of NPPF which sets out national policy in regard to these
matters and that particular circumstances can justify the need for a viability assessment at the application stage."

Object

Representation ID: 18574

Received: 11/10/2021

Respondent: Dudley Labour Group

Agent: Councillor Qadar Zada

Infrastructure


The Labour group is concerned that there has been no proper (or any) consideration of the impact of these proposals on the local infrastructure, i.e. roads, highways, health care, education, transport, which are already under significant strain in an already over developed borough.


Residents and councillors have been told verbally at public meetings that infrastructure modelling was ‘too expensive and too difficult to do at this moment in time’. This is clearly not true. Officers have received funding and had several years to work on these proposals and are still hiding behind the excuse of ‘too expensive and too complicated’.


There is also the question of the extent to which developers will fund additional infrastructure and in any event the obligations on them fall short of the impact that their developments are likely to place on local communities. For example, they are unlikely to agree to fund expensive transport improvements such as new roads near proposed developments and are not obliged to fund new health facilities. This will lead to a position, where local residents will end up paying for the profits made from these developments.


Until and unless these issues are resolved, then all proposals should be placed on hold.

Comment

Representation ID: 21203

Received: 11/10/2021

Respondent: Taylor Wimpey

Agent: Avison Young

Policy DEL1 – Infrastructure Provision

This policy requires that all new developments should be supported by the necessary on and offsite infrastructure to serve its needs, mitigate its impact on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area, unless material circumstances or considerations indicate otherwise.

With respect to our Client’s site, we note that Policy WSA7 of the Draft Plan suggests that the development of the site could deliver “appropriate local facilities to support new residents and to enhance the sustainability of the existing area, including a new primary school and local health centre”.

In terms of any necessary infrastructure required in Aldridge or the wider Black Country, we note that paragraph 4.5 of the Draft Plan states that the Plan will be supported by an Infrastructure Delivery Plan, however we cannot locate this within the evidence base the BCA have published on the Black Country Plan website. We would be grateful to have sight of this document if it is publicly available, in order that we can review and comment on it.

Notwithstanding this position, the provision of developer contributions should only be sought where these are proportionate to the level and impact arising from new development. As outlined in paragraph 57 of the NPPF:
“Planning obligations must only be sought where they meet all of the following tests:
a) Necessary to make the development acceptable in planning terms;
b) Directly related to the development; and
c) Fairly and reasonably related in scale and kind to the development.”

Comment

Representation ID: 21260

Received: 11/10/2021

Respondent: Redrow Homes Ltd

Agent: Savills

Policy DEL1 – Infrastructure Provision
Policy DEL1 states that all new developments should be supported by the necessary on and off-site infrastructure. It is currently unclear what level of infrastructure is required to support Strategic Allocation WSA2 and whether this is required on-site or as an off-site contribution. The Viability and Deliverability Study (May 2021) states that no health or education input has been received for Walsall. Point 3 of the policy states that further detail will be provided by the BCA to confirm what level of infrastructure should be provided. We consider that this is required in order to ascertain what level of contribution is required for Strategic Site WSA2.

Support

Representation ID: 21284

Received: 11/01/2022

Respondent: NHS Property Services

Policy DEL1 states that unless material circumstances or considerations indicate otherwise, development proposals will only be permitted if all necessary infrastructure improvements, mitigation measures and sustainable design requirements and proposals are provided and /or can be phased to support the requirements of the proposed development. These will be secured through planning obligations, the Community Infrastructure Levy, planning conditions or other relevant means or mechanisms, to an appropriate timetable that is prioritised, resourced, managed, delivered and co-ordinated across the sub-region, where appropriate. NHSPS supports the policy.

Context
The NHS, Council and other partners must work together to forecast the infrastructure and costs required to support the projected growth and development across the borough. A vital part of this is ensuring the NHS continues to receive a commensurate share of s106 and Community Infrastructure Levy (CIL) developer contributions to mitigate the impacts of growth and help deliver transformation plans.

It is important the boroughs maximise opportunities to use planning obligations to secure healthcare infrastructure.

Paragraph 34 of The NPPF is clear that ‘Plans should set out the contributions expected from development. This should include setting out… infrastructure (such as that needed for… health) ’

Large residential developments often have very significant impacts in terms of the need for additional healthcare provision for future residents, meaning that a planning obligation requiring that the development delivers a new healthcare facility is necessary. The requirement that planning policies recognise the role development sites can play in delivering necessary health facilities is welcomed.

The significant cumulative impacts of smaller residential developments should also be welcomed, and health facilities should be put on a level footing with affordable housing and public transport improvements, given their strategic importance, when receiving funds.


We’d also make clear that whilst large sites have an important role to play in delivering necessary health infrastructure as a s106 in kind, the supporting test should acknowledge that a s106 in kind health facility provided as shell and core let to the NHS at a market rent is in fact a c ommercial arrangement and not a planning obligation.

It is imperative that planning policies are positively prepared, in recognition of their statutory duty to help finance improved healthcare services and facilities through effective estate management.

We suggest that when setting planning obligations policies, the Council should seek to address strategic as well as local priorities in planning obligations. In the instance where planning obligations cannot viably be supported by a specific development, then no priority should be stated, and each planning application should be addressed on its merits.

NHSPS therefore welcomes Policy DES1 and supports its inclusion in the Draft Black Country
Plan.

Support

Representation ID: 21290

Received: 11/10/2021

Respondent: Owl Homes

Agent: Barton Willmore

Draft Policy DEL1 – Infrastructure Provision
Draft Policy DEL1 sets out how the BCA will secure infrastructure provision from future planned development. It also sets out the requirement for viability evidence where, in exceptional circumstances, proposals are unable to comply with the policies of the BCP.

In this regard, Owl Homes are willing to provide any contributions as part of the delivery of the Site, providing they meet all of the tests set out within Regulation 122(2) of the Community Infrastructure Levy Regulations 2010 and paragraph 57 of the NPPF and subject to any viability work.

Comment

Representation ID: 21337

Received: 11/10/2021

Respondent: William Davis Homes

Agent: Define Planning and Design Ltd

POLICY DEL1 – INFRASTRUCTURE PROVISION: COMMENT
WDH recognises the intention of Policy DEL1 and the importance of delivering the infrastructure required to support sustainable development. In that regard, it is important that the policy recognises the role of a wide range of actors in delivering infrastructure. In doing so, the policy policy should be more explicit to encourage the proactive involvement of actors within infrastructure delivery. For example, the policy should reflect that it is the responsibility of the utilities company to provide necessary water supply and wastewater infrastructure to support development. Their investment programmes are not necessarily integrated with Local Plans, and often will not address the development requirements for an area until specific proposals become committed, normally through the grant of planning permission.

Furthermore, it is noted that Policy DEL1 states that the BCAs will “set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and where appropriate, Masterplans” the infrastructure that is to be provided or supported, the prioritisation of and resources for infrastructure provision, the scale and form of obligation or levy to be applied to each type of infrastructure, and the procedure for maintenance payments and charges for preparing agreements. However, in order to give clarity to developers as to the scale and form of the infrastructure provision and contributions required, it is important that this is set out within the BCP itself, rather than being deferred to DPDs, SPDs, and Masterplan Reports that are produced thereafter. Indeed, recent case law has confirmed that policies that have a cost implication on development proposals cannot be deferred to an SPD or alike.

WDH does, however, welcome that the policy makes provision for “material considerations” that may indicate that some elements of required infrastructure cannot be delivered; which is an entirely sensible approach.

Comment

Representation ID: 21616

Received: 11/01/2022

Respondent: Pall Mall Investments

Agent: Highgate Land and Development

Policy DEL1: ‘Infrastructure Provision’
Draft Policy DEL1 at Limb (2) states that: ‘development proposals will only be permitted if all necessary infrastructure improvements, mitigation measures and sustainable design requirements and proposals are provided and/or can be phased to support the requirements of the proposed development.’
Limb 3 (a) of draft Policy DEL1 states that the Black Country Authorities (BCAs) will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, the infrastructure that is to be provided or supported.
Therefore, as currently drafted, this policy encapsulates both known infrastructure requirements (that should be reflected in the viability study undertaken by Aspinall Verdi underpinning the draft BCP to date), but also, future/emerging requirements that at this stage are unknown but could be brought forward in the future.
Therefore, it is appropriate Limb 4 of draft Policy DEL1 acknowledges that there will be circumstances where site specific viability concerns mean that some of these infrastructure requirements cannot be delivered. However, draft Policy DEL1 limits this to ‘exceptional’
circumstances. We therefore propose that the word ‘exceptional’ is removed from draft Policy DEL1
in order to provide sufficient flexibility to reduce the level of infrastructure requested at the planning application stage (either as the infrastructure requirement was
not envisaged (or known) at the time that the BCP viability evidence was prepared, or that there are site specific issues which impact on viability, and hence the ability to deliver the identified infrastructure).
This will also ensure that other proposals for other forms of residential development across the Black Country (such as 100% affordable housing schemes which have not been tested by the viability study undertaken by Aspinall Verdi) can come forward, by ensuring that the infrastructure requirements on such schemes can be ‘flexed’ appropriately.

Object

Representation ID: 22097

Received: 11/10/2021

Respondent: Mr Roger Tye

There are far too many houses currently in the areas around Streetly and Aldridge, and the traffic is
horrendous in all the areas that are due to be built on for houses, there is no infrastructure for schools, doctors, hospitals( you cannot see a doctor at the moment and the queue on the phone is out of control with a wait time of 2hours)

The area needs an infrastructure plan before the housing plan???
there will just be hundreds more houses and cars and people with children etc/ illness and no more doctors/ hospitals/road infrastructure or schools to carry the already overstretched burden around this area
i completely object to this plan before a solid infrastructure plan is developed and approved

Support

Representation ID: 22270

Received: 21/01/2022

Respondent: Miss Jodi Stokes

4.0 INFRASTRUCTURE AND DELIVERY

Infrastructure Provision

4.1 Draft Policy DE1 (Infrastructure Provision) sets out that “all new developments should be supported by the necessary on and off-site infrastructure to serve its needs, mitigate its impacts on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area”. We strongly agree that all new development should provide the necessary on and off-site infrastructure to support or mitigate the proposals. This draft policy reflects the requirement of paragraph 20 of the NPPF that strategic policies should make sufficient provision for infrastructure including transport, telecommunications, security, waste management, water supply, wastewater, flood risk and coastal change management, and the provision of minerals and energy (including heat).

4.2 Part 3 of draft Policy DEL1 sets out that the Black Country Authorities will provide further detail on what infrastructure should be provided and the scale and form or this provision through Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and masterplans (where appropriate). We agree that these are the appropriate mechanisms for this further level of detail.

Comment

Representation ID: 22344

Received: 11/10/2021

Respondent: Canal & River Trust

Policy DEL1 states that the Black Country Authorities will set out in Development Plan Documents, Infrastructure Delivery Plans, Supplementary Planning Documents, and where appropriate, masterplans what infrastructure will be provided, how it will be prioritised and what funding sources will be used. The Trust looks forward to working with the Black Country Authorities on this to ensure that the potential of our waterways to support sustainable development is unlocked, including through towpath upgrades, access improvements and wayfinding, as is supported by policies TRAN5 and ENV7 in the plan. We suggest that the Black Country Canals Strategy may identify priority areas for investment, which could be fed into
infrastructure delivery plans or other relevant documents.

Para 2.4 of the plan includes an 'open' list of the types of infrastructure that may need to be funded to support development. We suggest that 'sustainable travel' and 'green and blue infrastructure' are added to this list in the interests of internal consistency within the plan.

Comment

Representation ID: 22349

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

This policy requires that all new developments should be supported by the necessary on and off-site infrastructure to serve its needs, mitigate its impact on the environment and the local community and ensure that it is sustainable and contributes to the proper planning of the wider area, unless material circumstances or considerations indicate otherwise.

With respect to our Client’s site, we note that Policy WSA7 of the Draft Plan suggests that the development of the site could deliver “appropriate local facilities to support new residents and to enhance the sustainability of the existing area, including a new primary school and local health centre”. In terms of any necessary infrastructure required in Aldridge or the wider Black Country, we note that paragraph 4.5 of the Draft Plan states that the Plan will be supported by an Infrastructure Delivery Plan, however we cannot locate this within the evidence base the BCA have published on the Black Country Plan website. We would be grateful to have sight of this document if it is publicly available, in order that we can review and comment on it.

Notwithstanding this position, the provision of developer contributions should only be sought where these are proportionate to the level and impact arising from new development. As outlined in paragraph 57 of the NPPF:
“Planning obligations must only be sought where they meet all of the following tests:
a) Necessary to make the development acceptable in planning terms;
b) Directly related to the development; and
c) Fairly and reasonably related in scale and kind to the development.”

With that in mind, the BCAs will note that Taylor Wimpey’s proposals for land at Aldridge Road (detailed in the Development Statement at Appendix II) envisage that approximately 360 units can now be accommodated on the site, compared to the indicative capacity of 592 dwellings identified in the Local Plan, when taking into account technical constraints and design considerations. The reduced number of units will, in turn, mean that the development will have less of an impact on nearby amenities and services, which brings into question the requirement for a new on-site primary school and local health care centre, as identified in Policy WSA7. To that end, Taylor Wimpey is of the view that scale of the proposals at Aldridge Road do not warrant the provision of on-site facilities, in accordance with paragraph 57 of the NPPF. We would be grateful if Planning Officers could confirm that this approach is acceptable.

Comment

Representation ID: 22423

Received: 11/10/2021

Respondent: Mr Maurice Sanders

Agent: Avison Young

Policy DEL1 – Infrastructure Provision
This policy requires that all new developments should be supported by the necessary on and off-
site infrastructure to serve its needs, mitigate its impact on the environment and the local
community and ensure that it is sustainable and contributes to the proper planning of the wider
area, unless material circumstances or considerations indicate otherwise.

Notwithstanding this position, the provision of developer contributions should only be sought
where these are proportionate to the level and impact arising from new development. As outlined
in paragraph 57 of the NPPF:
“Planning obligations must only be sought where they meet all of the following tests:
a) Necessary to make the development acceptable in planning terms;
b) Directly related to the development; and
c) Fairly and reasonably related in scale and kind to the development.”
We therefore recommend that the policy is reworded to make clear that all new developments
should be supported by the necessary on and off-site infrastructure, where it is viable to do so.
Policy HOU2 – Housing Density, Type and Accessibility
Policy HOU2 recognises that the density and type of housing to be provided on any housing site
will be informed by (i) sub-regional and local needs, (ii) access to sustainable transport methods
and (iii) the need to achieve high quality design. Insofar as (i) is concerned, our Client considers it
will be important to maintain flexibility to allow for changing local market circumstances. In this
regard, it will also be important to ensure that housing mix prescriptions are determined in line
with up-to-date evidence.
Paragraph 125 of the National Planning Policy Framework states:
“Where there is an existing or anticipated shortage of land for meeting identified housing needs, it is
especially important that planning policies and decisions avoid homes being built at low densities and
ensure that developments make optimal use of the potential of each site.”
This policy also states that plans should contain minimum density standards for city and town
centres and other locations that are well served by public transport, and that the use of minimum
density standards should also be considered for other parts of the plan area and that it may be
appropriate to identify a ‘range’ of densities that reflects the accessibility and potential of different
areas.
Barnardo’s, therefore, as a matter of principle, support the range of minimum net densities set
out in Policy HOU2 of between 40 dph and 100 dph.

Comment

Representation ID: 22492

Received: 24/01/2022

Respondent: Taylor Wimpey

Agent: Avison Young

Paragraph 3.38-3.41 The infrastructure provisions of DEL1 should match that outlined in paragraph 57 of the NPPF.

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.’