Object

Representation ID: 66636

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There is considerable concern that paragraphs 1.55 - 1.59 make no reference at all to enabling the emergency services to provide and maintain facilities and services people currently need, or to enabling them to improve their infrastructure and services so that they can meet people's future needs.

The omission is at odds with the Council's own 'Draft Infrastructure Delivery Plan - April 2014', which includes the police and other emergency services. A number of infrastructure requirements are listed for the emergency services, which are deemed either strategically essential or strategically desirable by the Council.

We contend that as it stands paragraphs 1.55 - 1.59 of the Local Plan are not in accordance with following provisions of the National Planning Policy Framework (NPPF): -

* Securing sufficient facilities and services to meet local needs is a core planning principle (paragraph 17).

* Planning is to deliver facilities and services that communities need (paragraph 70).

* Local plan policies should deliver the provision of security infrastructure and other local facilities (paragraph 156).

* Local plan policy and decision making should be seamless (paragraph 186).

* Infrastructure planning should accompany development planning by LPAs (paragraph 177) who should work together with infrastructure providers (paragraph 162).

* The NPPF seeks environments where crime and disorder and the fear of crime do not undermine the quality of life and community cohesion (paragraph 69) and planning policies and decisions should deliver this (paragraph 58).

Should there be any remaining doubts regarding whether the Local Plan should support the delivery of emergency services infrastructure, please be aware that Ian Dove QC was instructed by the Association of Chief Police Officers (ACPO) to provide written advice in respect of developer contributions towards policing services. A copy of his advice is enclosed in Appendix 1 to these representations. His advice concluded that there is no difficulty in the proposition of Section 106 agreements and CIL contributions towards police infrastructure in the context of the Planning Act 2008.