Publication Draft

Support

Representation ID: 66642

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 .
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Support

Representation ID: 66643

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 .

Object

Representation ID: 66644

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Policy DS15 makes no mention of the police infrastructure that will be required to support the development of the Strategic Sites. This is surprising and of concern for two reasons.
Firstly, the Council's 'Draft Infrastructure Delivery Plan - April 2014' makes reference to the following infrastructure requirements under the heading 'Emergency Services': -

*Police: Safer Neighbourhood Team Police Offices - 3 additional offices at Europa Way, Lower Heathcote Farm and Thickthorn

*Other police equipment and costs - A range of other "CIL Compliant" costs including vehicles, communications technology and surveillance equipment, training, uniform and personal equipment

This confirms that the Council accepts that additional police infrastructure will be required to deliver policing services to the strategic sites.

Secondly, at the time of writing strategic site H02 (South of Harbury Lane, including the former sewage works), the H23 site (Bishops Tachbrook - Land south of the school), unallocated sites by Europa Way and Bishop's Tachbrook have all been subject to the following recent planning applications: -

*W/14/0300 - The Asps, Warwick - 900 dwellings - Barwood Strategic Land II LLP - Refused - 30 May 2014 (Appendix 1)

*W/14/0661 - Land at Lower Heathcote Farm - 785 dwellings - Gallagher Estates (see Appendix 2 of the full submission)

*W/14/0681 - Land South of Gallows Hills - 450 dwellings - Gallagher Estate (see full submission Appendix 3)

*W/14/0689 - Land off Oakley Wood Road - 150 dwellings - Bloor Homes (see full submission Appendix 4)

*W/14/0763 - Land off Seven Acre Close - 25 dwellings - A.C. Lloyd Homes Ltd ( see full submission Appendix 5)

To each application we submitted representations in respect of the need for the development concerned to provide police infrastructure. These are enclosed as per the appendices indicated above. At the time of writing, four of the planning applications are still in the process of being determined.

As planning applications are made in relation to the other strategic sites, we will submit similar representations requesting developer contributions towards police infrastructure.

Given all of the above we contend that as presently drafted, Policy DS15 undermines the delivery of the infrastructure necessary to deliver policing services to the strategic sites. It is therefore ineffective and unsound currently.

Object

Representation ID: 66645

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Overall, we welcome and support the proposed policy approach by the Council to control the location of new Houses in Multiple Occupation (HMO's).
Alongside the problems associated with such properties identified in paragraphs 4.60-4.66, we would add that HMOs are also frequently recorded for breaches of fire safety regulations. They are also amongst the most common type of domestic dwelling for where crimes against the occupants take place. Other typical problems associated with such properties include increased levels of burglary and a proliferation of on-street parking, which prevents ease of access by emergency vehicles. Such problems are multiplied exponentially where HMOs are concentrated in particular areas.
Despite these common and well documented problems, policy H6 to our concern makes no reference to them at all in the proposed criteria for assessing whether planning permission should be granted for HMOs. We therefore ask that the amendments proposed below are made to policy H6.

Object

Representation ID: 66646

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Firstly there is an awareness of of disputes that could be exacerbated if sites had transit and permanent pitches in close proximity.
Secondly, once permission has been granted for a new site, it is quite possible that over the plan period further planning applications will be made to extend it. The policy therefore needs to give this possibility consideration and provide safeguards as to how to stop conflicting groups locating on the same site.
Thirdly, easy access to the emergency services is just as important to gypsy and traveller communities as it is to the settled community. This needs to be recognised in Policy H8.
Fourthly, Policy H8 as drafted contains no mention of the partnership work that is required when sites for gypsy and traveller pitches are proposed, given the often contentious nature of such proposals. The policy should cover discussions at the pre-application stage right through to when a decision on a planning application is made.
Finally, policy H8 makes no reference as to how new sites 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 this regard, including policy support for Secured by Design would help to ensure new pitches complied with a nationally recognised standard.

Object

Representation ID: 66647

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

Whilst we agree with and support part (c) of HS1, namely that design and layout of development will be important to minimise the potential for crime and anti-social behaviour and improve community safety, delivery of expanded and new police infrastructure will be vital as well. This has been accepted by the Council in its 'Draft Infrastructure Delivery Plan - April 2014'.

Object

Representation ID: 66648

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There is concern that Policy HS7's current wording asserts that design measures alone will ensure that developments enjoy low crime and antisocial behaviour rates, thereby ensuring community safety.

This is not to say Secured by Design measures won't reduce crime levels, they certainly will, as detailed elsewhere in our representations. However even when applied to the maximum possible extent, they can never reduce crime and anti-social behaviour rates in a development to zero. There will always be a necessity for policing and emergency services to deal with those incidents and crimes that occur no matter what design measures are put in place. That is why there is no such thing as a development policed entirely through architectural means.

The current wording of HS7 is surprising, not only because of the above reason, but because the Council's 'Draft Infrastructure Delivery Plan - April 2014' recognises that police and emergency services infrastructure will need to be provided if sustainable development in the District is to be achieved. The Plan also implicitly recognises that funding will be needed from Section 106 agreements and the Community Infrastructure Levy (CIL) to deliver this infrastructure.

Object

Representation ID: 66649

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

We do not consider TR1 to be effective in soundness terms, as it does not reference the fact that new developments should allow swift and easy access for emergency services vehicles to attend incidents and individuals quickly, helping to prevent crime and in some cases, save lives. The importance of TR1 requiring this therefore cannot be overemphasised.

Object

Representation ID: 66650

Received: 26/06/2014

Respondent: Place Partnership Limited (PPL)

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes

There are no references at all within Strategic Policy DS3, or within supporting paragraphs 2.9 - 212, to either of the following: -

* Designing out crime
* Emergency services infrastructure provision

This is a fact that also seriously undermines the achievement of the objectives contained within the following strategy documents: -

* 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