Sandwell Local Plan - Reg 19 Publication

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Sandwell Local Plan - Reg 19 Publication

Policy SHO2 – Windfall developments

Representation ID: 1494

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

The PCCWM objects to Policy SHO2, as it should include reference for the need for contributions for social, environmental and physical infrastructure to support windfall development. Windfall development, as well as development on larger sites/ allocations, should be subject to CIL/ S.106 agreements to help fund the provision and maintenance of Police services, and the requirement for this infrastructure should be enshrined in the wording of Policy SHO2.

Support

Sandwell Local Plan - Reg 19 Publication

Policy SHO7 - Houses in Multiple Occupation 

Representation ID: 1495

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the wording of the policy and justification to Policy SHO7, which reflects the representations made to the Sandwell Issues and Options consultation and the Regulation 18 consultation.

The PCCWM supports the specific reference within the policy itself, point 3(e) as follows: - ‘3. Once the current level of HMO provision has been established in a relevant area, the following criteria will be applied to a new proposal: …

e) the development would not give rise to unacceptable adverse cumulative impacts on amenity, character, appearance, security, crime, anti-social behaviour or the fear of crime.’

The PCCWM also fully supports the footnote to this policy (174) which recommends that pre-application and planning application advice is sought for HMO proposals from the West Midlands Police Design Out Crime Officers.

In addition, the PCCWM supports the reference in point 6 of the Policy that states that the policy criteria will also apply to the intensification or expansion of an existing HMO.

The justification to Policy SHO7, paragraph 7.54(g) is also supported by the PCCWM. It explains that harmful impacts associated with high numbers of HMOs can include: ‘…g) increased anti-social behaviour and fear of crime resulting from the lifestyles of some HMO occupants, the transient nature of the accommodation and inadequately designed / maintained properties;’

However, in addition to the support for Policy SHO7, it is noted that the Council acknowledge (para 7.57) that: ‘Whilst this type of accommodation [HMO] can address certain housing needs, HMOs tend to be grouped together in parts of the urban area, becoming the dominant type of housing, which can lead to social and environmental problems for local communities. Alongside this, an over-concentration of HMO properties can lead to a loss of family-sized units. This in turn can lead to a consequential increase in the overall number of units unsuited to family occupation. This can pose a serious issue for
maintaining a mixed sustainable housing offer across the Black Country.’ In light of these concerns, the PCCWM recommends a Borough wide Article 4 Direction be introduced to seek to remove the permitted development right to convert a residential dwelling to a small HMO (providing living accommodation for 3 to 6 unrelated persons), such that planning permission would be required for any proposals, alongside the proposed policy against which all HMO applications, as well as planning applications for large HMO (for which there are no permitted development rights and thereby planning permission is required) will be assessed. This is an approach taken elsewhere, including in neighbouring Birmingham.

An Article 4 Direction regarding permitted development for HMOs, alongside the proposed policies of the Reg 19 draft Sandwell Local Plan would manage the distribution and delivery of HMOs, to reduce the potential harm that arises from the over-concentration and poor quality of HMOs, and the consequential impact this has on crime and disorder and to community safety, and the increased pressure this places on Police resources.

Support

Sandwell Local Plan - Reg 19 Publication

Policy SHO9 – Accommodation for Gypsies, Travellers and Travelling Showpeople

Representation ID: 1496

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the wording of the policy and justification to Policy SHO9, which reflects the representations made to the Sandwell Issues and Options consultation and the Reg 18 consultation

Support

Sandwell Local Plan - Reg 19 Publication

Policy SCE1 - Sandwell's Centres

Representation ID: 1498

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the wording in Policy SCE1 ‘Sandwell’s Centres’ at 6(d), as this reflects the representations made to the Sandwell Issues and Options consultation and the Reg 18 consultation. ‘6. A land use approach will be adopted to encourage regeneration and to meet the challenges facing Sandwell's centres, particularly as little retail capacity has been identified to support additional floorspace, through supporting:

“…d. a variety of facilities, appealing to a wide range of age and social groups, provided in such a way to ensure a safe, accessible and inclusive environment and any anti-social behaviour is discouraged, for example through management, improved lighting and CCTV coverage where appropriate.’

Comment

Sandwell Local Plan - Reg 19 Publication

Policy SCE2 - Non-E Class Uses in Town Centres

Representation ID: 1499

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the wording in Policy SCE2 as this reflects the representations made to the Sandwell Issues and Options consultation and the Reg 18 consultation, specifically the addition to the policy of clause 5: ‘5. In all areas of Town Centres, it is important that a variety of facilities, appealing to a wide range of age and social groups, are offered and that these are provided in such a way to ensure a safe, accessible and inclusive environment and any anti-social behaviour is discouraged, for example through management, improved lighting and CCTV coverage where appropriate.’

Support

Sandwell Local Plan - Reg 19 Publication

Policy SCE3 - Town Centres (Tier-Two centres)

Representation ID: 1500

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the inclusion of the following wording in each of these policies – namely ‘In determining planning applications for new development or changes of use in local centres, the Council will consider any issues concerning community safety, crime, and disorder and will, where necessary, seek advice from the police and other safety organisations.’

Support

Sandwell Local Plan - Reg 19 Publication

Policy SCE4 - District and Local Centres (Tier-Three centres)

Representation ID: 1501

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the inclusion of the following wording in each of these policies – namely ‘In determining planning applications for new development or changes of use in local centres, the Council will consider any issues concerning community safety, crime, and disorder and will, where necessary, seek advice from the police and other safety organisations.’

Comment

Sandwell Local Plan - Reg 19 Publication

Policy SCE5 - Provision of Small-Scale Local Facilities not in Centres

Representation ID: 1502

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the inclusion of the following wording in each of these policies – namely ‘In determining planning applications for new development or changes of use in local centres, the Council will consider any issues concerning community safety, crime, and disorder and will, where necessary, seek advice from the police and other safety organisations.’

Support

Sandwell Local Plan - Reg 19 Publication

Policy SDM1 – Design Quality

Representation ID: 1503

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM supports the wording in Policy SDM1 as it reflects the representations made to the Sandwell Issues and Options consultation and the Reg 18 consultation and now includes the requirement that the need for new development must not cause an adverse impact on the living environment of occupiers of existing residential properties, or unacceptable living conditions for future occupiers of new residential properties, in terms of crime and safety., and at 2d. that “Development proposals must demonstrate that the following guidance has been considered and where appropriate used to inform design and access statements that reflect their Sandwell-specific context:… d. compliance with crime prevention measures, such as Secured by Design and / or Park Mark principles;”

Comment

Sandwell Local Plan - Reg 19 Publication

Policy SDM6 - Hot Food Takeaways

Representation ID: 1504

Received: 11/11/2024

Respondent: Police and Crime Commissioner for West Midlands (PCCWM)

Agent: The Tyler Parkes Partnership Ltd

Representation Summary:

The PCCWM acknowledges the wording in Policy SDM6 – Hot Food Takeaways. However, whilst associated Policy SDM7 ‘Management of Hot Food Takeaways’ has been amended as requested in the PCCWM’s Regulation 18 consultation response (new clause 9) However, the PCCWM remains of the view that Policies SDM6 and SDM7 should be amalgamated into one policy as the inference is that if a proposal complies with the prescriptive and numerical thresholds under Policy SDM6 it will be acceptable, even though it at may not meet the criteria set out in Policy SDM7 – Management of Hot Food Takeaways – and vice versa. Accordingly, the PCCWM objects on the basis that Policies SDM6 and SDM7 should be amalgamated since it is considered that the criteria in Policy SDM7 to be equally important in the consideration of a planning application for a hot food takeaway, particularly as hot food takeaways are often a flashpoint for violence after pubs and clubs close.

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