Part One: Spatial Strategy and Policies (Regulation 19)

Object

Representation ID: 1433

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Detailed crime statistics that could be included in the plan.

Recent announcements by the new Government suggest an increase of 143% in the level of housing provision (rising from 657 dwellings per annum to 1,594 dwellings per annum). A consequential increase in population will inevitably result an unfortunate increase in crime levels. Recent statistics show levels of offending in Dudley Borough 12% higher than the national rate for England as a whole.

The PCCWM requests that in accordance with national planning policy, the theme of community safety and crime prevention is given prominence in the Dudley Local Plan, with appropriate references being included as set out in the following detailed comments.

Support

Representation ID: 1434

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

PARAGRAPH 1.4

Support 5th bullet point responding to comments at Reg 18.

Comment

Representation ID: 1435

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Chapter 3

In relation to Paragraph 3.2, the PCCWM made the following representation to the Regulation 18 consultation:
“ could usefully have an additional bullet making reference to healthy, secure and safe
living environments. The PCCWM requests this is added as it would demonstrate
commitment to the importance of these matters to the built environment. [Objection]”

The Consultation Statement acknowledges this representation and suggests an amendment has been made to the plan adding a new bullet point to (an incorrectly numbered paragraph 1.4). This appears to be a drafting error and the PCCWM requests this should be re-examined. Pending this re-examination the PCCWM objects to this omission and requests the addition of a further bullet point to paragraph 3.2 making reference to, “healthy, secure and safe living environments”.

Object

Representation ID: 1436

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

SUSTAINABILITY APPRAISAL

It is noted that paragraph 3.39 states, “A Sustainability Appraisal (SA) is a statutory requirement, which ensures that the environmental, social and economic effects of a plan ..” However, it is noted that the SA’s objectives are materially different to the objectives and strategic priorities of the Local Plan and appear to focus on the environmental arm of sustainable development. If this interpretation is correct, then it implies that social and economic matters (including those of the PCCWM and those of others) receive lesser priority in the assessment process because of its focus on environmental considerations.

Table 3.2 - various entries in this table that relate to design quality and infrastructure do tend to gloss over the importance of providing a secure and safe living environment. Additionally, there is no reference to policing, yet all other public services and infrastructure providers do appear to have been picked up.

Suggested edits (see reps):
Page 43 – The PCCWM objects to the omission of necessary text. Amend the issue to read, “Delivering homes of a high-quality, safe and secure design that reflect the
character and distinctiveness of the borough” and the proposed policy to, ‘Design is an overarching concept which interacts directly or indirectly with all other aspects of the plan. Strategic design policies in the DLP aim to form the foundations on which to build future detail and ensure that development is located and designed to create safe and secure places for all residents in future”.

• Page 44 – The PCCWM objects and requests amendments. Under the issues, “Ensuring access to local services and supporting infrastructure” and “Balancing growth across communities by ensuring that local services and facilities continue to thrive”, under column 3 in both entries, amend second bullet to:
‘• Liaison with health, West Midlands Police and education providers’.

• Page 45 – The PCCWM objects and requests amendments. In relation to the issue,
“Addressing the health and wellbeing of residents and inequalities across the borough”, under the proposed policy approach, ‘The Plan recognises the important role that spatial planning has in the creation of healthy, safe, secure and inclusive communities and that the places that we live in have a fundamental impact on health quality of life. Many of the policies of the Plan will have an impact on these matters, so it is important that community needs are supported through the provision of appropriate physical and social infrastructure and the built and natural environment, including the public realm, allows for and supports healthy living choices for residents everyone.’ The third column should add reference to ‘Liaison with West Midlands Police’.

• Page 46 – The PCCWM objects and requests amendments. Under the issue “Infrastructure needed to support new growth”, under column 3, amend second bullet to: ‘• Liaison with health, West Midlands Police and education providers’.

Object

Representation ID: 1437

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

See rep for changes which are bold and underlined.

The PCCWM objects to the omission of text relating to safety and security within the vision statement, and specifically seeks the following amendments:

• Amend 4th bullet to read, “• sustainable urban growth delivering distinctive, safe and secure places - meeting the needs of its communities and businesses.” (Suggested changes in bold and underlined).
• Amend 9th bullet to read, “• a high quality and beautiful natural, built and historic environment and safe and secure public realm that respects and enhances local character and distinctiveness, including valued historic buildings and areas, and continues to be regarded as a tourist destination, and UNESCO Global Geopark with enhanced tourism facilities”. (Suggested changes in bold and underlined).

Objective 3: Enhancing Places and Communities
The PCCWM objects to the lack of reference to the need to plan for safe and secure places. It is requested that Strategic Priority 5 be amended to read: Creating safe and secure well designed and beautiful places, promoting the health and social wellbeing of communities by:’ and also, add additional bullet on the following lines, “Ensure that the principles of Secured by Design are integral to new development and improvements to the public realm”. (Suggested changes in bold and underlined).

Object

Representation ID: 1438

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Policy DLP1 Development Strategy
The PCCWM objects to the current wording of Policy DLP1 and requires amendments to strengthen the policy, and in particular sub-paragraph 2.a. to read: Delivering high quality development in the existing urban area supported by infrastructure to meet the needs of communities and businesses supported by the integration of Secured by Design principles. [Suggested changes in bold and underlined).

Object

Representation ID: 1439

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The PCCWM objects to the current wording of Policy DLP4 which requires, inter alia, greater reference to matters of crime prevention measures. The PCCWM suggests that the policy should be strengthened to read: “7. Dudley Borough will be a safe and secure place to live and work in, through organising the urban environment including the public realm in ways that encourage people to act in a responsible manner (see Policy DLP39). All new Development proposals should include consideration of crime prevention measures and will be required to integrate ‘Secured by Design’ and ‘Park Mark principles to provide active frontages, well-located, safe and accessible pedestrian and cycle infrastructure and an appropriate intensity of use in centres and elsewhere. Designs should promote natural surveillance and defensible spaces. Proposals should also include a maintenance plan to reduce crime, the fear of crime and anti-social behaviour on an ongoing basis. Developers will be encouraged to seek advice from Design Out Crime Officers where appropriate.”

The reasoned justification could helpfully also refer to the types of development where developers should actively seek advice regarding designing out crime. While not exclusive, it is recommended that this should include the following categories of development:

• Major developments
• Houses in Multiple Occupation (HMO)
• Hot Food Takeaways
• Public realm works
• Public transport infrastructure proposals.

Furthermore, the Evidence section to the Policy should include reference to Secured by Design, and the Delivery section should refer to, West Midlands Police’s Design Out Crime Officers. (Suggested changes in bold and underlined).

Object

Representation ID: 1445

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

The PCCWM objects and requests this policy should include the following as a new sub- heading and paragraph:
“Safety and Security. 11. An assessment should be undertaken (as part of the design of new developments likely to attract large numbers of people) to demonstrate and document how potential security and crime related vulnerabilities have been identified, assessed and where necessary, addressed in a manner that is appropriate and proportionate.”

The Delivery section to this policy should also refer to ‘Liaison with West Midlands
Police’. [Suggested changes in bold and underlined).

Comment

Representation ID: 1455

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Support addition to paragraph 6.10

6.20 which forms the reasoned justification to Policy DLP6 does not specifically refer to policing facilities while referring to a wide range of other infrastructure. The PCCWM objects to this glaring omission and its inconsistency with paragraph 6.10

The PCCWM considers it essential that, ‘Policing infrastructure and services’ to paragraph 6.20

The definition and support for infrastructure should be explicitly set out in the Local Plan, to meet national and local policy objectives relating to safety and security, and it should be clearly set out that contributions will be required through CIL/ S.106 agreements to help fund the provision and maintenance of facilities and equipment for Police services - see full rep for details.

As the statutory Development Plan, it is the purpose of the draft Dudley Local Plan to confirm the types of infrastructure which will be required to provide sustainable development in the Borough during the plan period and the Policy DLP6 and supporting text should be amended as suggested above to specifically include reference to Police infrastructure. Without these changes, the PCCWM objects.

Object

Representation ID: 1458

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Strengthening of paragraph 8.2 at Regulation 18 stage 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.’ (in line with the DLP design policies). [Suggested changes in bold and underlined).