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Support

Draft Charging Schedule and Draft Regulation 123 List

Representation ID: 21794

Received: 19/03/2015

Respondent: Sussex Police

Agent: Sussex Police

Representation:

Sussex Police strongly support the introduction of the Community Infrastructure Levy within the charging area of Rother District, as set out in the Draft Charging Schedule.

The Infrastructure Funding Gap Analysis provides evidence that there is a significant funding deficit, and the proposed levy will go partway to bridging that gap and thereby providing the infrastructure needed to support development in the Core Strategy. This infrastructure, including that required by Sussex Police, is vital to addressing the impacts of future development and achieving safe and sustainable future communities.

Full text:

Paragraph 4
Sussex Police strongly support the introduction of the Community Infrastructure Levy within the charging area of Rother District, as set out in the Draft Charging Schedule.

The Infrastructure Funding Gap Analysis provides evidence that there is a significant funding deficit, and the proposed levy will go partway to bridging that gap and thereby providing the infrastructure needed to support development in the Core Strategy. This infrastructure, including that required by Sussex Police, is vital to addressing the impacts of future development and achieving safe and sustainable future communities.

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It is noted that an Instalment Policy is proposed for the charging of the levy. It is agreed that this is a realistic approach to the application of CIL and will balance the desirability of funding necessary infrastructure against the potential effect on economic viability of doing so. However, the provision of policing infrastructure is critical to the delivery of safe, sustainable communities and will need to be provided at early stages of the development process. This is evidenced by the increased crime rates Sussex Police have noted in connection with theft from construction sites. There is also a need to provide safe and accessible environments where crime and disorder, and the fear of crime do not undermine the quality of life or community cohesion as part of planning for sustainable development and communities, as outlined in paragraphs 58 (5) and 69 (3) of the National Planning Policy Framework 2012. This is raised for information only, to inform the drafting and application of any Instalment Policy, and to ensure that policing infrastructure is recognised as a critical infrastructure type which should be considered early in the application of CIL.

Appendix 2
Sussex Police fully support the Draft Regulation 123 List accompanying the Draft Charging Schedule. The inclusion of 'Emergency Services' to be wholly or partly funded by CIL is particularly welcomed. It is also noted that this funding is for the 'provision of facilities.' Use of the term 'facilities' is welcomed as this ensures the levy may be utilised for the necessary provision, expansion and adaptation of Police Stations and Estate, as well as the provision of wider community safety facilities and supporting infrastructure, as permissible under CIL Guidance.

However, it is noted that no specific 'Emergency Services' infrastructure is included within the Draft Regulation 123 List, nor within the latest draft of the Infrastructure Delivery Plan (IDP) Schedule (February 2015). While it may be appropriate to maintain the general reference to "Emergency Services: Provision of facilities to address future needs" within the Regulation 123 List, Sussex Police would welcome inclusion of more detail on the Force's infrastructure needs within the IDP. This would provide further guidance and evidence that the Draft Charging Schedule and Regulation 123 List are based on appropriate available evidence on infrastructure planning. It would also ensure that this infrastructure is included as fundamental to the delivery of the objectives and spatial strategy of the Core Strategy, and provide a timeframe and importance rating for the provision of policing infrastructure.

Noting that the IDP is intended to be a "living document", Sussex Police would welcome further joint work on inclusion of more detailed information on policing infrastructure within the IDP Schedule, in the appropriate format. This should be based on the infrastructure needs set out to Rother District Council in June 2014. In summary, these include:

* Capital estate projects associated with accommodating additional staff required to provide policing services to the growing population of Rother, including the need to adapt Bexhill and Rye Police Stations to sufficiently accommodate new staff and equipment. There will also be the need to consider space in the new Battle Police Station, when this is reprovided as set out in the Sussex Police Estates Strategy 2013-2018.
* As Sussex Police provide force wide policing, there are also cross boundary infrastructure requirements. The Sussex Police Headquarters (based in Lewes) would require extension, adaptation and modernisation over the coming years to meet the policing needs of the growing population at a force-wide level, including the growth identified in Rother. There are also costs associated with custody provision from Hastings and Eastbourne for Rother, which are required as a result of development across all Districts in Sussex.
* In addition to the extended/refurbished/new police stations required, there will also be capital costs associated with providing supporting infrastructure required in connection with new development. This supporting infrastructure may include additional fleet (in the form of marked and unmarked cars to enable police patrols or operation of our Road Policing Unit); additional IT/Communications (including remote IT facilities to enable more effective policing and carrying out of duties on site, away from local police stations); supporting equipment (such as the provision of Automatic Number Plate Recognition cameras on key transport links in the District, including the new Hastings/Bexhill Link Road to aid in the detection of crime, and/or CCTV cameras within key locations of Anti Social Behaviour); and start up costs associated with the additional staff needed due to increased crime levels associated with new development (such as uniform costs, protective equipment costs, initial training).