Publication Draft

Object

Representation ID: 66125

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There is concern that part (e) of policy SCO is inconsistent with national planning policy and not as effective as it might be, because it does not clarify what is precisely meant or intended by the term 'measures'. We are also concerned about part (f) of the policy, as it does not clearly and unequivocally reinforce the delivery of part (e) of the policy. This in turn undermines the achievement of sustainable communities.
With regard to promoting healthy communities, paragraphs 58 and 69 of the NPPF advise that planning policies, decisions and design should aim to achieve safe and accessible environments where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion.

Support

Representation ID: 66632

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Paragraph 1.30 criterion (k) as they recognise the crime and the fear of crime, particularly in town centres and the need to protect the community from harm.
Paragraph 1.30 (k) also provides reinforcement for the delivery of the emergency services element of the Council's 'Draft Infrastructure Delivery Plan - April 2014', as the funding of such infrastructure will be vital if this issue is to be full addressed over the plan period.

Object

Representation ID: 66633

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraphs 1.6 and 1.7 of the Local Plan are welcome and supported, however there is concern that no reference is made to paragraphs 58 and 69 of the National Planning Policy Framework (NPPF). These state that planning policies and decisions should aim to achieve places which promote: -

'Safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion.'

Paragraphs 58 and 69 of the NPPF put in planning terms the following statutory duty of local authorities: -

'Without prejudice to any other obligation imposed upon it, it shall be the duty of each local authority to exercise its various functions with due regard to the likely effect of those functions on, and the need to do all that it reasonably can, to prevent crime and disorder in its area.' Section 17(1) of the Crime and Disorder Act 1998.

Support

Representation ID: 66634

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Paragraphs 1.40, 1.42 and 1.52 of the Local Plan are welcomed and supported as they are currently written. This is because they recognise that businesses and communities require safe and secure environments within which to grow and flourish. Therefore, the design of new developments and provision of infrastructure will be essential to control crime, anti-social behaviour and reduce the fear of crime. This in turn provides reinforcement for the following provisions of the Local Plan: -

* Overarching Policy SC0: Sustainable Communities
* BE1 - Layout and Design
* Paragraph 5.9
* HS1 - Healthy, Safe and Inclusive Communities
* HS7 - Crime Prevention

Paragraphs 1.40, 1.42 and 1.52 also provide support for the delivery of the emergency services element of the Council's 'Draft Infrastructure Delivery Plan - April 2014'.

All of the above will therefore help achieve economic growth and the creation of strong, vibrant and healthy communities in the District, as per the targets contained within the following strategies: -

* A Shared Vision - Warwick District's Sustainable Community Strategy 2009-2026

* South Warwickshire Community Safety Partnership - Partnership Plan - April 2014 - March 2017

* Garden Town, Villages and Suburbs - A Prospectus for Warwick District Council - May 2012

Object

Representation ID: 66635

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Paragraph 6.3 omits to reference the emergency services as one of the infrastructure types that new development puts pressure on. This has the potential to undermine support for the delivery of required emergency services infrastructure, where this is required to ensure sustainable development.

As explained at length elsewhere in our representations and as recognised in the Council's 'Draft Infrastructure Delivery Plan - April 2014', new development can place considerable pressure on the police and emergency services. This point is evidenced by the recent representations we have been submitting to major planning applications for housing development in the District, which are enclosed in Appendices 1-5 of these representations. Further evidence is provided by the letter from our consultants WYG, enclosed in Appendix 6.

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.

Object

Representation ID: 66637

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The economic benefits that converting Use Class A1 retail units to Use Classes A3, A4, A5 and D2 units would bring to the locations covered by Policies TC8 and TC17 are not disputed, however there are deep concerns about the following problems in the Local Plan: -

1.No specific policy and supporting explanation on the evening and night-time economy.

2.What guidance there is in the Local Plan on this matter is fragmented and ineffectual.

Evening and night-time economy related development is the most resource intensive type of development that the emergency services have to attend to on an-going weekly basis. We would therefore like to see the following in the Local Plan: -

1.Policy and guidance that sets out in a clear and concise way where and when evening/night-time economy related development will be located and delivered within Warwick District. Whilst this information can be predicted from reviewing the Local Plan as a whole, it would be much better if a clear list of sites was provided in a similar manner to proposed housing and employment sites. This would in turn help stakeholders like the emergency services to undertake their own planning work in relation to this type of development.

2.Providing sufficient policy and supporting guidance in terms of explaining how the well documented negative side effect of evening/night-time economy related development will be actively managed. This is essential in order to ensure that the public are safe and feel safe and thereby secure the maintenance of The Queen's Peace in the District.

3.Establishing the basis by which public sector agencies, private companies and other stakeholders will work together to coordinate the active management of the evening/night-time economy in Warwick District. The relationship between the partnership work concerning the planning system and that taking place in respect of implementing licensing arrangements, as required by the Police Reform and Social Responsibility Act 2011, also requires explanation in the Local Plan.

Object

Representation ID: 66638

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

The economic benefits that converting Use Class A1 retail units to Use Classes A3, A4, A5 and D2 units would bring to the locations covered by Policies TC8 and TC17 are not disputed, however there are deep concerns about the following problems in the Local Plan: -

1.No specific policy and supporting explanation on the evening and night-time economy.

2.What guidance there is in the Local Plan on this matter is fragmented and ineffectual.

Evening and night-time economy related development is the most resource intensive type of development that the emergency services have to attend to on an-going weekly basis. We would therefore like to see the following in the Local Plan: -

1.Policy and guidance that sets out in a clear and concise way where and when evening/night-time economy related development will be located and delivered within Warwick District. Whilst this information can be predicted from reviewing the Local Plan as a whole, it would be much better if a clear list of sites was provided in a similar manner to proposed housing and employment sites. This would in turn help stakeholders like the emergency services to undertake their own planning work in relation to this type of development.

2.Providing sufficient policy and supporting guidance in terms of explaining how the well documented negative side effect of evening/night-time economy related development will be actively managed. This is essential in order to ensure that the public are safe and feel safe and thereby secure the maintenance of The Queen's Peace in the District.

3.Establishing the basis by which public sector agencies, private companies and other stakeholders will work together to coordinate the active management of the evening/night-time economy in Warwick District. The relationship between the partnership work concerning the planning system and that taking place in respect of implementing licensing arrangements, as required by the Police Reform and Social Responsibility Act 2011, also requires explanation in the Local Plan.

Object

Representation ID: 66639

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

It is considered that the effectiveness of policy BE1 is undermined through lack of a direct reference to 'Secured by Design'. The omission is surprising, given that paragraph 5.9 of the supporting Explanation does reference Secured by Design.
Policy support for Secured by Design would help to ensure new developments comply with a nationally recognised consistent standard. This in turn would mean they would contribute to the achievement of the Government's objectives for the planning system set out in paragraphs 58 and 69 of the National Planning Policy Framework (NPPF).
In case the Council and Inspector are not aware, Secured by Design is a long-running flagship initiative of the Association of Chief Police Officers (ACPO). Its objective is to design out crime during the planning process. It is a respected standard in the sector, supported by numerous local authorities (including Warwick District Council) and professional bodies and is therefore, a vital guidance resource for planners.

Support

Representation ID: 66640

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Warwickshire Police fully supports the development strategy for housing and the specific allocations identified in the pre‐submission version of the LP at Leek Wootton. The
identified allocations are in suitable locations and on land which is available now.
Development would fulfil the requirements of the emerging Development Plan in terms of layout and design (BE1), without impacting adversely on the Green Belt or detracting from the significance of heritage assets.
Warwickshire Police has been pursuing in full consultation with the local and wider communities , a considered, orderly and comprehensive plan for the disposal of the
Woodcote estate in so far as this is compatible with policing objectives and public interest. A decision as to whether the existing communications function will be relocated has yet to be made.
The allocations identified in the draft LP for the Woodcote estate are an important ingredient in facilitating the necessary realignment of policing assets in Warwickshire and
Warwickshire Police wishes the wider public benefit of making these allocations to be noted by the Council and, in due course, when the LP is subject to public examination .