Earl Shilton and Barwell Action Area Plan.

Urban extensions, 4050 homes and supporting facilities.

Statement by Michael Lambert, Growth and Design Officer

Police and Crime Commissioner for Leicestershire

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Introduction.

These submissions are made in response to Main Matter 2 (‘MM2’). MM2 raises the following questions:

a. Is it understood that Regulation 122 means that provision can only relate to additional demands? b. Is there an agreed methodology to calculate increased demand? c. Are the sums of £97,524 and £63,504 sufficient to provide for the additional costs incurred in policing the extra population and represent a reasonable requirement meeting the Regulation 122 tests? d. Should there be a distinction in policy terms between Barwell and Earl Shilton neighbourhood centres?

Before dealing with each of these I make the following preliminary observations:

First, the basis upon which the AAP currently addresses the police contribution is founded upon a false assumption that policing the developments relies solely upon the local beat office. This is not the case. Policing Earl Shilton and Barwell is carried out by staff based at Headquarters Enderby, Basic Command Loughborough, Hinckley LPU and a local beat office. The development will impact upon resources at all the aforementioned. To illustrate, the beat office represents about 5% of staff we deploy to police Hinckley and about 30% of our people engaged in delivering policing to the settlements. Further, expanding this office as we require [120m2] represents only 26% of the infrastructure support we will need to police the urban extensions (‘UEs’). A contribution which only includes the local centre misses the point entirely.

Second, policing these developments is not simply a matter of needing extra accommodation for police staff. It requires: vehicles, CCTV, premises, communications systems, IT systems as well as other infrastructure. The policing of the additional development cannot function without all of these. Any sums required to mitigate policing the two developments must provide for all infrastructure required. The sums are set out below.

Third, the request is uncontroversial. Over the last 18 months we have been calculating requests at Local Plans/Core Strategies, planning applications and appeals as follows:

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· identifying the amount and type of development proposed, · identifying proportionate and comparable local policing demand, · providing crime information for the beat and LPU area. · identifying existing deployment of Police assets to the locality · forecasting the impact of individual developments · defining the funding and capacity position of Police. · identifying NPPF and local supporting policy. · making commitments to manage contributions and procure necessary infrastructure · Itemising required infrastructure with individual methodologies and CIL compliance testing of these.

This methodology has continually been found to be CIL compliant by developers, planning Inspectors and importantly, the Secretary of State1. Here, the police merely ask for a consistent approach to be taken in the AAP. a. Existing Accommodation Difficulties

The police confirm that it does not look to the AAP in order to ‘make good any existing accommodation difficulties’. The police request is simply for resources to mitigate the additional demands on the police service as a result of this proposed development. Any current difficulties are only significant in that they demonstrate that the police do not have ‘spare capacity’ to deal with new development. b. Agreed methodology The methodology the Council uses is not agreed and police have not been involved in the drafting of its Topic Paper [TP]. Other Councils have included Police and other infrastructure providers in this process.

c. The sums of £97,524 and £63,504 in the TP.

These are insufficient to provide for the additional costs incurred in policing the extra population and development of the two growth points. This much is evident from the following

1Springwell lane APP/T2405/A/13/2193758; Moira Road APP/G2435/A/13/2192131; Rearsby Roses APP/X2410/A/2187470; Seine Lane APP/t2405/A/13/2200867; Bill Crane APP/F2415/A/12/2179844; Melton Road APP/X2410/A/12/2173673; Hallbrook APP/F2415/A/12/218363

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justification for what is necessary. The Councils confirmation of the number of houses now proposed at Earl Shilton has been included in this.

Justification of Police needs at Earl Shilton and Barwell.

The nature of the development For the UEs to be sustainable, proportionate infrastructure needs to be provided. 4050 houses are proposed on green fields with other elements of the development not dissimilar to the existing settlements. Baseline data is drawn from these to provide a proportionate evidence base.

Current levels of local Policing demand Policing is provided "on demand" and on an "equal access" basis so that residents across the Force Area benefit from the same level of service. Control room calls and deployments give a good indication of the level of demand from the 8298 houses in the two settlements beat.

In the 2011 year we dealt with 83,315 calls from Hinckley, dispatched emergency attendances to 9,386 of these and visited on 5,314 occasions to follow up less urgent cases. At beat level (that is the smaller area in which the development is located) these figures were 14936, 1728 and 976 respectively.

The beat had 866 recorded crime incidents in the last year. There were 4651 recorded incidents across Hinckley demonstrating a higher crime rate in the beat. I refer to this at page 11. Mapping shows an even spread of crime with burglary, theft and vehicle related the main content. There is a concentration in the centres of the settlements used by locals to visit and shop. At Force level total crime declined in the past three years although it peaked towards the end of 2013. In the beat total crime levels are more static. Vehicle crime increased Forcewide but remained static in the beat. Burglary has increased significantly Forcewide and this is reflected in the beat. Theft has been static Force wide and locally. 2658 incidents of ASB were recorded at District level with 488 of these attributed to the beat.

Present Deployments to Police Hinckley · 61 staff in the LPU and local beat offices in the District [14 in the settlement] · 40 staff in the Braunston emergency response hub,

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· 11 staff in the Loughborough Basic Command Unit - investigations, intelligence and LPU management · Support teams at Force HQ Enderby - including criminal justice and courts, prisoner detention and processing, control centre, Intelligence research, Operations planning, dogs and firearms, special branch, forensic, Road Policing, Workshops/garages, Tactical Support Group, Road Safety Unit, IT and comms, Safeguarding/ vulnerability, Child abuse team, Economic crime team and in Regional/major crime working; and · Support functions at Force HQ Enderby providing finance, welfare, estates, training and top level management.

158 staff are employed delivering these later two functions to Hinckley LPU area.

No Police function, nor station can operate independently. An existing development of this size occupies 24 of the 270 staff serving the District. Staffing levels are under constant review to minimise numbers to meet current demand. There is no additional capacity to extend staffing to cover additional major development.

Unless we increase infrastructure deployment to support additional growth, that growth cannot be accommodated resulting in acute pressure on existing deployment. That undermines our ability to maintain delivery of policing to existing and new communities. I describe the facilities and infrastructures we rely on in Hinckley and their capacity will be exceeded by additional development there.

Inadequacy of other Funding Our primary funding is insufficient to provide infrastructure to support the UEs. There are no capital-funding regimes to provide for re-investment in our facilities. We fund capital infrastructure by borrowing. As over 90% of our budget is staffing related, our capital can only be used to overcome pressing issues with existing facilities e.g. premises defects or to provide new vehicles. ACPO2 have recognised this and Local Councils have verified this - Leicester and Leicestershire HMA Authorities Growth Infrastructure Assessment Executive Summary 2009, para 82 of which confirms in relation to Policing "It is sensible to assume that most of the capital requirements incurred by growth will not be covered by existing mainstream central and local funding".

2 Association of Chief Police Officers

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We use our local rates and Home Office revenues to pay for staff salaries, our day-to-day routine costs [e.g. call charges on telephony and IT, vehicle maintenance] and any loan debt to overcome deficiencies with existing premises.

The Policing impact of 4050 houses proposed in the AAP.

The overnight population will increase by 9315. The daytime population will swell by employees and service users. 4050 houses will bring additional Policing demands for a wide spectrum of support from in and beyond the settlement.

We forecast this will be manifest in- · 7290 control room calls and responses pa. · Attendance to 844 emergency events pa. · 476 non-emergency events pa. · 423 recorded crimes pa plus 238 recorded anti social behaviour incidents. · Demand for increased patrols. · Additional vehicle use · Additional calls on our radio system. · Additional use of our PND systems equating to 324 hits and data entries pa. · Additional deployment and use of CCTV technologies · Additional demand for access to local beat staff. · Additional Policing cover and interventions in all the areas above with impacts on staffing and the need for additional accommodation to deliver Policing. Existing development of this size is policed by the equivalent of 24 Leicestershire Police staff.

Planning Policy justification

The police case is supported by national policy. Planning should deliver sufficient community and cultural facilities and services to meet local needs [NPPF para17 bullet 12]. That Core Planning Principle is reflected in para 70 where positive planning should provide local services to enhance the sustainability of communities and residential environments.

Local Plans should include policies to deliver the provision of security infrastructure and other local facilities [para17 bullet 12]. Similarly, para157 first bullet says local Plans should plan positively for the development and infrastructure required to meet the principles and policies of the Framework and this should be based on co-operation with public sector organisations

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(third bullet). Para 162 reiterates the theme of co-operation where LPAs should work with infrastructure providers in assessing capacity and need.

Plans should be positively prepared taking account of objectively assessed development and infrastructure requirements, and be sustainable/consistent with the Framework [182]. Planning should achieve the well being of healthy communities and good design, providing ‘safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion' [58, 69]. The relationship between plan making and decision taking should be seamless [186].

These policies justify the approach we take as confirmed by Local Plan content elsewhere and the views of Planning Inspectors and the Secretary of State expressed through various decisions.

Hinckley Local Plan Policy IMP 1 provides local over arching Policy justification for developer contributions and Leicestershire County Council Statement of Requirements includes Policing. This context emphasises the need for the AAP to make adequate provision.

Costing - what should be in the AAP.

Baseline background. At October 2012 total Force floorspace was 54,274m2. 3606 staff employed. 405,500 existing Households in the Police area, 45,400 in Hinckley and Bosworth.

Households to staff for Hinckley is 168:1 Occupancy, Floorspace to staff Forcewide is 15m2.

Equipping staff. Police Officer - uniform £873, radio £525, Workstation £1508, foundation/basic accreditation £2333, External Training £2182. Some uniformed officers share workstations in shifts. Start up cost £7421. For the rest - workstation £2286 and training £687, total £2973. Staff to officers ratio of 0.33 to 0.66 so cost per new is £5879. 24 additional staff required to Police growth and therefore £141096 to equip them. Police cannot risk ill equipped staff delivering Policing.

Vehicles. Current fleet deployment to Hinckley District is 35. Average equipped cost £15,774. Vehicles are replaced at 120,000 miles/3 years and there is a 10% resale value. 35 units at net value £496881

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45,400 households = £10.94 per H hold x 2 to give 6 year life.

£88614 is required for additional vehicles. Impact without this will be an unacceptable spread of cover well below current levels/capacities.

Radio Cover/capacity. In order to meet call demand we spend £19220pa adding capacity to the existing system in Hinckley at £0.42 per household. Capacity improvements last 5 years. An additional £8505 is required for additional capacity for growth. Impact without this will be unacceptable attendance time and communications failures that could risk Officer and community safety.

Police Database capacity. Additional hits as a result of the development to access information and add to this. The system is at planned capacity. We spend £10,244 on system enhancements to serve Hinckley each year at £0.22 per household and these last for 5 years. £4455 is required to ensure speed of access, processing and additional data storage.

HQ Control Room telephony. Already used to capacity at peaks. £199,000 required to meet needs of planned growth across Leicestershire. For additional telephony - lines, licences, workstations and monitoring screens. 8% of all current calls relate to Hinckley. With 6,600 houses proposed we will need to invest £2.41 per additional household. £9760 is required for growth at ES and B. Call handling impact and delays without this.

Roadside ANPR CCTV. Police have invested because of local needs and demands. Settlement expansion requires additional cameras, upgrade of support hardware and re locations. Three additional cameras required at £24666. Without this the existing network will be undermined with impacts on detection and crime.

Mobile CCTV Deployment. No provision for cover of additional areas in current deployment. Cameras detect and deter crime. Unit cost £1500 and 3 required for UEs and their environs to ensure consistency of cover and equality of policing across the Force area. . £4500.

Premises. Neighbourhood Policing at Hinckley LPU and the beat office. Emergency responses from Braunstone. Command functions from Loughborough and essential support functions primarily from Force HQ Enderby. Premises occupation is minimised to capacity by overt estates interventions. Premises cost = force occupancy rate [15] x number of staff required [24] x Build and land/lost opportunity cost [£2794pm2]. £1005840 required, verified

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by tendering.

There is no spare capacity at Hinckley LPU to take additional staff and extension is necessary. Braunstone, is used to capacity and needs internal refurbishment to increase this. Loughborough rebuilding to current needs underway and will need to be extended. In relation to HQ typical is the Force Control room - Heavily secured and with standbys and used to capacity. Additional space for additional staff to handle additional calls required.

The local office content of additional premises space will be 8 staff x 15m2 x £2794pm2 = £335280. The TP ignores the culmination at 22/3/13 of work with the Councils legal advisers in relation to Barwell and concluding a cost of £153090. The only difference now is the increase in our build costs revised as a result of tendering. The TP also ignores the Councils legal advice at 5/3/133, in relation to compliance, which also recommended "expanding the local office and furthering the Police concern to expedite this through discussion with the County Council". We do not own this building and we are unaware of any discussions in response to this recommendation.

Without additional floorspace there will be unacceptable overcrowding and inefficiencies in local responses/Policing delivery.

Crime Prevention Measures. New occupiers will bring additional demands for equipment such as Smartwater kits [fluid, sprays, detectors] and signage. Restricted funds are only available to deliver to existing communities. £4050 required for additional communities.

Summary of additional Infrastructure Costs. Start up equipment £141096 Vehicles £88614 Additional radio capacity £8505 PND additions £4455 Additional phone handling £9760 ANPR £24666 Mobile CCTV £4500 Additional premises £1005840 Crime prevention £4050 Total £1291486

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Justification Conclusion The Police approach is to identify the baseline, identify impacts of the development then cost mitigation where infrastructures do not have capacity and there is no funding to procure this. This is an objective assessment and it is proportionate. Being contemporary, and based on known information, it is robust. We referred to this in our pre-examination submissions [dated 2/12/11 and 12/11/12], the submissions in relation to Barwell at the 22/3/13 and all other requests against planning applications and appeals in Hinckley. The Council could have considered evidence from any of these sources.

Police need £1291486[£319pd] and cannot just absorb this and subsidise the developments. Stretching cover will put the safety of existing and new communities at risk and is unsustainable. We invite the Inspector to consider the difficulties that will result for Police and the community in assuring community and officer safety without this support or at the levels the Council suggest in their TP. It is inadequate and at odds with the reality of the situation and the consistent justification being made by police.

D. Distinction between Barwell and Earl Shilton? The local Police beat is both settlements and the beat is the lowest level at which we can aggregate information. Our justification applies to the content of the AAP proposing growth in both settlements. All our functions and deployments are made to the beat which is both settlements.

Other Issues between the Police and the Council It is pertinent to make the following comments in relation to the Council’s consideration of the Police request in the context of the Barwell Planning application (paras 3.10-3.18 Topic Paper):

i]There has been an ongoing dialogue between the Council and the police regarding the Barwell application;

ii] On 5 March 2013 the Council sought advice form external solicitors which confirmed that, subject to further information, five of the items sought met the compliance tests, and that a further two might well do if alternative approaches were used. They concluded that four (based on information at that point) did not. They suggested that the Police worked on this with input from Counsel. This is what police did. The revised request presented was based on the same methodology used in the justification in this statement.

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As such, paragraph TP 3.20 is simply not correct. The Council received the further information prepared under Counsel’s advice on 22/3/13. The Council has chosen to select a very small part of what the Police need to mitigate the impact of development planned through the AAP with apparently no rational basis for rejecting other components which have been supported consistently in all recent appeal decisions. Further in relation to their selection they have ignored the invited Police submission of the 22/3/13 which superseded this.

Viability and other matters. In relation to MM1 l. and p: We have considered the viability work of the Council and concluded that meeting our full requirements would not have a negative impact on the viability of the development. The Council does not dispute this.

Turning to the EIA/ Sustainability appraisal NPPF [paras 165 to 167] is clear about the role this has in plan making. The basic concern of Police, that this is inadequate without considering the up to date baseline and mitigations information we have supplied, remain unanswered in any of the Councils responses.

In a similar vein Police have drawn attention to the recognised link between local deprivation and crime and the particular efforts we have made to ensure and maintain a local Police presence to address this. We are happy to expand on this at the examination. This is not considered in the AAP. A local presence wholly depends on all the infrastructures described in our justification. Unless this is urgently addressed by the Council, community safety needs will be increasingly unmet as their planned growth takes place.

Overall conclusion In order to correct the Councils omissions a main modification is required if the plan is to achieve soundness and we ask the Inspector to recommend this in his report. Because of the potential seriousness of this Police approached the Inspector to suggest an Exploratory Meeting and formal sessions to fathom the Councils conduct and scrutinise this in public. The Inspector resolved to hear the matter in the usual Examination sessions. This is the written statement and representation of Police for this process. What is necessary to insert in the AAP infrastructure plan is captured in the justification above.

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