Part One: Spatial Strategy and Policies (Regulation 19)

Comment

Representation ID: 1459

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

The PCCWM supports 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”. This is welcome in itself but the PCCWM considers that it is very important that wider references are made in relation to Secured by Design principles, where appropriate, to ensure the rationale is equally strong elsewhere.

Object

Representation ID: 1460

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

Requested that an 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.' It is extremely disappointing that this has not been incorporated. In addition, the Delivery section should add, 'Liaison with West Midlands Police’s Design Out Crime Officers'. [Suggested changes in bold and underlined).

Object

Representation ID: 1461

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 requires the strengthening of point 6 as follows to read:
'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).

The Consultation Statement rejects the PCCWM’s suggestions by indicating these matters are covered by Policy DLP39 and that a cross reference to that policy in the reasoned justification covers the point. However, there is no cross reference to DLP39 but in any event the PCCWM wishes to maintain his objection.

One further 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).

Object

Representation ID: 1462

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 supports the amendments made to policy DLP29, and in particular point 3 of
the policy which has been amended in line with the PCCWM’s requests, 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.’

However, the PCCWM objects to the Delivery section and the previous Regulation 18 objection is maintained with the addition of the wording: 'Liaison with West Midlands Police Design Out Crime Officers' still considered necessary (Suggested changes in bold and underlined).

Figure 10.2 Hierarchal Approach Monitoring
The PCCWM welcomes and supports the inclusion of Secured by Design principles.

Support

Representation ID: 1463

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

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.

The PCCWM objects in relation to the further guidance in paragraph 11.95. The PCCWM reiterates a point made at Regulation 18 stage and suggests that this paragraph should 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)

Object

Representation ID: 1599

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

GLOSSARY

The PCCWM objects. The PCCWM has mentioned the need for a definition of infrastructure at various points within this response. The current glossary fails to mention the emergency services and this omission should be rectified, as highlighted above, as follows:

“Infrastructure: Generic term to describe structures or buildings, services and facilities which support residents, animals and nature residing in certain areas. This could be in terms of transport, for example walking, cycling paths and public transport infrastructure, in social infrastructure in the form of community or health facilities, measures to improve the emergency services or measures to improve and encourage nature and climate
change adaptation and mitigation in the form of green and blue infrastructure.” (Suggested changes in bold and underlined)

Additionally, the PCCWM makes further objections to omissions within the Glossary and requests two new additions as follows:

Secured by Design

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. (Suggested changes in bold and underlined)


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. (See 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 (See About The Scheme).(Suggested changes in bold and underlined)

Comment

Representation ID: 1604

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

INFRASTRUCTURE DEVELOPMENT PLAN

The Infrastructure Delivery Plan (IDP) dated October 2024 acknowledges, at paragraph 7.1.2, that the response of the WMPCC, whilst not site specific, highlighted a need for more policing resources and supporting infrastructure. However, it goes on to comment that no specific physical infrastructure was identified.

The day-to-day operation of a modern police force such as WMP requires flexibility and mobility to be able to respond in an effective and efficient manner. Officers are increasingly mobile, and as such there is a reduced reliance on physical “bricks and mortar” and a greater emphasis upon infrastructure such as, but not restricted to, equipment and police vehicles.

As has previously been indicated within this submission, the planned growth within Dudley during the plan period will bring with it increased levels of crime, of all sorts, and in turn increased demands placed upon WMP. For new development to be considered truly sustainable, it must deliver necessary associated infrastructure, and within this must be provision for police infrastructure.

The basis, and support for such provision has been set out above, with the attached Appendix 3 providing a detailed breakdown of household numbers; crime figures; and increased Police infrastructure requirements, all costed out to provide the current (2023) figures, which suggest that for new residential development a figure of approximately
£128.50 per new home, on qualifying sites, would provide the necessary mitigation and ensure that appropriate levels of WMP infrastructure can be provided to assist with future policing of the development. This could be achieved either via CIL, or S106 obligations.

Comment

Representation ID: 1606

Received: 10/12/2024

Respondent: Police Crime Commissioner for West Midlands (PCCWM)

Agent: Tyler Parkes

The PCCWM has suggested some improvements that could be made to the objectives of the plan. On examination of the SA, it is clear from Table 2.1 that the appraisal adopts a generic set of different strategic objectives. Is this entirely appropriate? Shouldn’t the SA adopt the objectives as set out in the emerging plan? Otherwise, isn’t there a risk of divergence when the objective should be the opposite?

Paragraph E1 of the Executive Summary refers to high level environmental protection whereas Paragraph E2 (correctly) identifies that the SA has to consider, and presumably balance, social, economic and environmental performance. This apparent discrepancy should be reviewed as it suggests that the environmental point of the triangle is given greater prominence in the assessment.