Part One: Spatial Strategy and Policies (Regulation 18)

Object

Representation ID: 731

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Moving onto Section 8 Housing, the PCCWM would like to suggest a strengthening of paragraph
8.2 through the following addition, ‘New housing will be of a well-designed high build quality,
meeting national space and water efficiency standards, achieving high levels of energy efficiency,
and adapting to climate change and integrating ‘Secured by Design’ and ‘Park Mark principles.’
[Suggested changes in bold and underlined). [Objection]

Comment

Representation ID: 732

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Paragraph 8.35, Gypsies and Travellers. The reference to, “...that pitches and plots are well
designed in line with Secured by Design principles, and it is recommended that advice is sought
from West Midlands Police Design Out Crime Officers” is welcome in itself but it is very important
that wider references are made in relation to Secured by Design principles as the rationale is
equally strong elsewhere.

Object

Representation ID: 733

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Policy DLP17 Houses in Multiple Occupation, it is requested that the following additional bullet
point is added to the policy, 'All proposals will be expected to demonstrate how the relevant
‘Secured by Design’ principles have been met including the outcome of consultation with Design
Out Crime Officers (DOCO) at the pre-application stage and preparation of a management plan
to demonstrate how the crime prevention measures will be maintained.' In addition, the
Delivery section should add, 'Liaison with West Midlands Police’s Design Out Crime Officers'.
[Suggested changes in bold and underlined). [Objection]

Object

Representation ID: 734

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Policy DLP24 Dudley Borough Centres, the PCCWM suggests strengthening point 6 as follows, '6.
Measures to enhance the vitality, accessibility, and sustainability of centres, including maximising
the extent, safety and security of the public realm, open space, provision of green infrastructure
and vehicle charging points, including integration of ‘Secured by Design’ and ‘Park Mark principles.’ will be supported.' In addition, the Delivery section should add, 'Liaison with West
Midlands Police’s Design Out Crime Officers'. [Suggested changes in bold and underlined).
[Objection]

Object

Representation ID: 735

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

One potential omission from this policy is in relation to the specific consideration of proposals
affecting Gambling and Alternative Financial Services. There is a case for a specific policy
reference on the following lines, “proposals for all pay day loan shops, pawnbrokers, and
gambling uses will take full account of any issues concerning community safety, crime, and
disorder and will, where necessary, seek advice from the police and other safety organisations.’
[Suggested changes in bold and underlined). [Objection]

Object

Representation ID: 736

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Policy DLP29 Hot Food Takeaways, the PCCWM requests that point 3 of the policy be amended as
follows, 'In all locations, planning permission for Hot Food Takeaways will only be granted where
there would not be an adverse impact on public or highways safety. Regard will be given to:
a. Existing traffic conditions, including availability of parking spaces.
b. Availability of safe legal loading areas
c. Proximity to junctions, pelican crossings, bus bays and bus stops
d. Accessibility of the site by public transport and cycling
e. Secured by Design, Park Mark principles, and the need for a maintenance plan to reduce
crime, the fear of crime and anti-social behaviour.’
In addition, the Delivery section should add, 'Liaison with West Midlands Police Design Out
Crime Officers'. (Suggested changes in bold and underlined). [Objection]

Support

Representation ID: 737

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

In relation to Figure 10.2, the PCCWM welcomes and supports the inclusion of Secured by Design
principles. [Welcome]

Support

Representation ID: 738

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Policy DLP39 Design Quality, the PCCWM welcomes and supports the references to consideration
of crime prevention measures and Secured by Design and Park Mark principles, in addition to the
requirements of Part Q of the Building Regulations 2010 or any successor legislation within this
policy. and the further guidance in paragraph 11.95. In relation to the latter, it is suggested that
this could be further strengthened by adding the following sentence, ‘Developers are encouraged
to undertake pre-application discussions with West Midlands Police's Design Out Crime
Officers.’ (Suggested changes in bold and underlined) [Support]

Comment

Representation ID: 739

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

The PCCWM requests that definitions be provided of the following which are referred to in the
draft Dudley Local Plan.
Secured by Design (SBD) is the official police security initiative that is owned by the UK Police Service with the specific aim to reduce crime and help people live more safely. The Police seeks to improve the physical security of buildings using products, such as doors, windows, locks and
walling systems that meet SBD security requirements. In addition, the Police include proven crime
prevention techniques and measures into the layout and landscaping of new developments, such
as maximising natural surveillance and limiting excessive through movement.
Through SBD, the Police work closely with builders, developers, local authorities and registered
housing associations to incorporate police crime prevention standards from initial concept and
design through to construction and completion. West Midlands Police have specially trained
Designing Out Crime Officers (DOCOs) who offer police designing out crime and Secured by Design
advice free of charge. (NB. based on Secured by Design - About SBD)
Park Mark
The Safer Parking Scheme is a national standard for UK car parks that have low crime and
measures in place to ensure the safety of people and vehicles. Each car park undergoes a rigorous
assessment by specially trained police assessors and a Park Mark is awarded to each car park that
achieves the challenging standards. A Park Mark is awarded to parking facilities that have met the
requirements of a risk assessment conducted by the Police, meaning the operator has put in place
measures that deter criminal activity and anti-social behaviour (NB. based on ParkMark - About
The Scheme).

Comment

Representation ID: 740

Received: 21/12/2023

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

The Safer Parking Scheme is a national standard for UK car parks that have low crime and
measures in place to ensure the safety of people and vehicles. Each car park undergoes a rigorous
assessment by specially trained police assessors and a Park Mark is awarded to each car park that
achieves the challenging standards. A Park Mark is awarded to parking facilities that have met the
requirements of a risk assessment conducted by the Police, meaning the operator has put in place
measures that deter criminal activity and anti-social behaviour (NB. based on ParkMark - About
The Scheme).