Community Infrastructure Levy (CIL) Preliminary Draft Charging Schedule and Regulation 123 List

Sussex Police strongly support the introduction of the Community Infrastructure Levy within the charging area of the Rother District, as set out in the Preliminary 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 subsequently providing the infrastructure needed to support development in the Core Strategy. This infrastructure, including that required by Sussex Police, is vital to achieve safe and sustainable future communities, thus should be provided by the levy to address the impacts of future development and comply with this national and local planning policy.

The Infrastructure Funding Gap Analysis identifies a significant funding gap for the provision of infrastructure, across the Rother District, needed to support development coming forward in the Core Strategy. Whilst the Analysis does not specify all types of infrastructure required, including Sussex Police infrastructure set out in our IDP representation of June 2014, paragraph 1.11 sets out that additional service provision will contribute towards the widening of the infrastructure gap. Sussex Police consider that their infrastructure requirements, needed solely to support new growth, will also contribute towards further widening of this gap.

Sussex Police therefore agree that there is a significant infrastructure funding gap across the District. The existence of this funding gap is clear, based on the information provided, and gives justification on the need to charge the levy.

It is noted that an Instalment Policy may be introduced in the process of 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. This approach has been adopted by neighbouring local planning authorities in their proposed application of CIL.

However, the provision of policing infrastructure is critical to the delivery of safe sustainable communities and this policing infrastructure 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, in drafting and applying any Instalment Policy, and to identify policing infrastructure as a critical infrastructure type, which should be considered early in the application of CIL.

Sussex Police agree with and support the Draft Regulation 123 List accompanying the PDCS.

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.' Again, this wording of '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 'Emergency Services' infrastructure is included within the Infrastructure Delivery Plan Schedule. Sussex Police would welcome inclusion of the Force's infrastructure needs within this Schedule, to further evidence that the PDCS and Draft Regulation 123 List is based on appropriate available evidence on infrastructure planning. This 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.

Sussex Police would welcome further joint work on inclusion of policing infrastructure in the IDP Schedule, in the format required and as based on the infrastructure needs set out to Rother District Council in June 2014. It is hoped that this may enable a revision to the IDP Schedule, prior to formulation of the Draft Charging Schedule, to ensure that this Schedule is based on up to date available and appropriate evidence.

Sussex Police agree with and support the Draft Regulation 123 List accompanying the PDCS.

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.' Again, this wording of '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 'Emergency Services' infrastructure is included within the Infrastructure Delivery Plan Schedule. Sussex Police would welcome inclusion of the Force's infrastructure needs within this Schedule, to further evidence that the PDCS and Draft Regulation 123 List is based on appropriate available evidence on infrastructure planning. This 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.

Sussex Police would welcome further joint work on inclusion of policing infrastructure in the IDP Schedule, in the format required and as based on the infrastructure needs set out to Rother District Council in June 2014. It is hoped that this may enable a revision to the IDP Schedule, prior to formulation of the Draft Charging Schedule, to ensure that this Schedule is based on up to date available and appropriate evidence.