UPSVLP 0428
National policy and guidance on the need to reduce crime and the fear of crime and anti- social behaviour, should be reflected in local policy. The CCCC therefore recommends additional wording be included within the Vision to ensure that the UPSVLP is consistent with national policy and therefore considered sound.
Whilst the CCCC supports objective W4 which seeks to ?promote safer and more sustainable travel?, the Plan Objectives make no reference to the creation of safe and secure neighbourhoods and communities or crime and disorder prevention/reduction. The objectives are underpinned by the key aim of enabling ?sustainable growth of Warrington through the ongoing regeneration of Inner Warrington, the delivery of strategic and local infrastructure, the strengthening of existing neighbourhoods and the creation of new sustainable neighbourhoods?. CCCC maintains that crime reduction and prevention principles are fundamental to the delivery of sustainable development growth and this should be acknowledged within the Plan Objectives. On this basis, the plan does not accord with the provisions of paragraphs 8 and 9 of the NPPF which outline that sustainable development should be supported by the guiding principles of economic, social and environmental objectives and take account of local circumstances.
Whilst the CCCC supports objective W4 which seeks to ?promote safer and more sustainable travel?, the Plan Objectives make no reference to the creation of safe and secure neighbourhoods and communities or crime and disorder prevention/reduction. The objectives are underpinned by the key aim of enabling ?sustainable growth of Warrington through the ongoing regeneration of Inner Warrington, the delivery of strategic and local infrastructure, the strengthening of existing neighbourhoods and the creation of new sustainable neighbourhoods?. CCCC maintains that crime reduction and prevention principles are fundamental to the delivery of sustainable development growth and this should be acknowledged within the Plan Objectives. On this basis, the plan does not accord with the provisions of paragraphs 8 and 9 of the NPPF which outline that sustainable development should be supported by the guiding principles of economic, social and environmental objectives and take account of local circumstances.
Whilst the CCCC supports objective W4 which seeks to ?promote safer and more sustainable travel?, the Plan Objectives make no reference to the creation of safe and secure neighbourhoods and communities or crime and disorder prevention/reduction. The objectives are underpinned by the key aim of enabling ?sustainable growth of Warrington through the ongoing regeneration of Inner Warrington, the delivery of strategic and local infrastructure, the strengthening of existing neighbourhoods and the creation of new sustainable neighbourhoods?. CCCC maintains that crime reduction and prevention principles are fundamental to the delivery of sustainable development growth and this should be acknowledged within the Plan Objectives. On this basis, the plan does not accord with the provisions of paragraphs 8 and 9 of the NPPF which outline that sustainable development should be supported by the guiding principles of economic, social and environmental objectives and take account of local circumstances.
In order for the UPSVLP to be considered sound, Objective W4 should be amended to achieve the overarching objective of delivering safe and secure communities and places.
Whilst the CCCC supports objective W4 which seeks to ?promote safer and more sustainable travel?, the Plan Objectives make no reference to the creation of safe and secure neighbourhoods and communities or crime and disorder prevention/reduction. The objectives are underpinned by the key aim of enabling ?sustainable growth of Warrington through the ongoing regeneration of Inner Warrington, the delivery of strategic and local infrastructure, the strengthening of existing neighbourhoods and the creation of new sustainable neighbourhoods?. CCCC maintains that crime reduction and prevention principles are fundamental to the delivery of sustainable development growth and this should be acknowledged within the Plan Objectives. On this basis, the plan does not accord with the provisions of paragraphs 8 and 9 of the NPPF which outline that sustainable development should be supported by the guiding principles of economic, social and environmental objectives and take account of local circumstances.
Whilst the CCCC supports objective W4 which seeks to ?promote safer and more sustainable travel?, the Plan Objectives make no reference to the creation of safe and secure neighbourhoods and communities or crime and disorder prevention/reduction. The objectives are underpinned by the key aim of enabling ?sustainable growth of Warrington through the ongoing regeneration of Inner Warrington, the delivery of strategic and local infrastructure, the strengthening of existing neighbourhoods and the creation of new sustainable neighbourhoods?. CCCC maintains that crime reduction and prevention principles are fundamental to the delivery of sustainable development growth and this should be acknowledged within the Plan Objectives. On this basis, the plan does not accord with the provisions of paragraphs 8 and 9 of the NPPF which outline that sustainable development should be supported by the guiding principles of economic, social and environmental objectives and take account of local circumstances.
Whilst the CCCC supports objective W4 which seeks to ?promote safer and more sustainable travel?, the Plan Objectives make no reference to the creation of safe and secure neighbourhoods and communities or crime and disorder prevention/reduction. The objectives are underpinned by the key aim of enabling ?sustainable growth of Warrington through the ongoing regeneration of Inner Warrington, the delivery of strategic and local infrastructure, the strengthening of existing neighbourhoods and the creation of new sustainable neighbourhoods?. CCCC maintains that crime reduction and prevention principles are fundamental to the delivery of sustainable development growth and this should be acknowledged within the Plan Objectives. On this basis, the plan does not accord with the provisions of paragraphs 8 and 9 of the NPPF which outline that sustainable development should be supported by the guiding principles of economic, social and environmental objectives and take account of local circumstances.
CCCC requests that the following be added to the list in Improving the Town Centre?s Environment part 7: ?f. incorporate measures for crime reduction including Secured by Design Principles and urban and landscape design solutions to mitigate the risk of potential terrorist attacks.? CCCC also requests that the supporting text to Policy TC1 be amended to include reference to the need for CC Designing Out Crime Advisors together with Counter Terrorism Security Advisors to be consulted at the pre-planning stage to ensure major Town Centre projects contain appropriate design solutions, which respond to the potential level of risk whilst ensuring the quality of places is maximised.
The policy does not include any reference to measures to promote civil resilience, reduce incidents of crime in the town centre and increase the general public?s feeling of safety. Measures to design out crime, including counter terrorism measures should be integral to development proposals particularly in public areas that experience high levels of footfall and those which generate large numbers of people, such as the Town Centre. The policy does not therefore accord with the NPPF.
Part 7
Requested that Emergency Services be included in the planning contributions recipient list in INF5. However, it is understood that WBC is not prepared to update the list to include Emergency services on the basis of concerns surrounding viability and subsequent deliverability of UPSVLP housing allocations. No evidence has been provided to CC to substantiate this position.
The recognition in INF5 that the Council will seek planning obligations where development creates a requirement is welcomed and supported. However, CCCC objects to policy INF5 as currently drafted on the basis that it omits Emergency services infrastructure from the list of valid recipients of planning contributions. To preclude the Emergency services inclusion from Policy INF5 is against the spirit of positive partnership and collaborative working. In this regard, it is contended that as worded, Policy INF5 is not effective nor consistent with national policy and is therefore not sound. it will be necessary for CC to secure Section 106 contributions towards infrastructure, due to the direct link between the demand for policing services and the changes in the operational environment beyond the Constabulary?s control i.e. the housing growth proposed in the UPSVLP and the subsequent and permanent impacts it has upon policing. Case Law and Appeal Decision references provided to support case reference the above.
In order for the policy to be effective, CCCC requests that the following text be added to the list of development requirements in Part 2.?j. Include crime prevention and reduction measures.?
the policy makes no reference to the need to ensure existing and emerging communities in these area are safe and secure and where the propensity of crime is low, contrary to Paragraphs 8, 97, 119 and 130 of the NPPF.
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?l. For all relevant buildings and developments, consider and address fire safety matters as they relate to land use planning matters. Information provided should be proportionate to the scale, type and complexity of the proposal.?
UPSVLP Policy DC6 fully addresses the comments made by the Constabulary?s Designing Out Crime Team. CCCC therefore considers that Policy DC6 is justified, effective, wholly consistent with and supported by national policy. However, with regards to fire safety, request that text be added.
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In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
In order to make the plan sound, the CCCC, therefore requests the following additional principle is added under the ?Detailed Site-specific Requirements? section. ?Appropriate emergency services infrastructure?
The impact of this site upon the Police and other Emergency services is not recognised or accounted for. This is in contrast to the site specific requirements for all other infrastructure and service providers (health, education, green and natural infrastructure, transport and utilities etc) which are explicitly covered in the site allocation policies. We therefore request that Policy be amended to include specific policy recognition of the need for additional Police infrastructure, in line with national policy requirements.
IDP
Please see full representation for the full requested paragraphs to be inserted in to the IDP.
The IDP neither considers nor makes any provision for future emergency services infrastructure requirements as fundamental elements of sustainable development. This is inconsistent with NPPF Paragraph 20 which requires strategic policies within a local plan to make sufficient provision for infrastructure and community facilities. although work by the Constabulary is currently on-going to establish the precise Police infrastructure requirements for the allocated housing sites, this should not preclude the Council from including the following marker in the IDP to refer to the need for developments to mitigate their impacts on policing infrastructure.
CCCC does not support the ?Vision ? Warrington 2038 and beyond? in its current form as it makes no reference to the need to create and maintain safe, secure and low crime communities, places and buildings in Warrington Borough. This is at odds with paragraphs 8, 97, 119, 130 of the NPPF and the PPG.