Written evidence submitted by Secured By Design [NPP 123]

I am writing from the police crime prevention initiative, Secured by Design, to offer our insight on the operation of the National Planning Policy Framework (NPPF). We support the ethos and much of the content of the NPPF; however, we believe that as part of the Committee’s inquiry, future risks to the framework posed by other Government reforms should be carefully considered.

1. Executive Summary

• Secured by Design is a crucial preventative measure which has proven to reduce burglary and anti-social behaviour, improving housing quality for residents across the UK
• The NPPF highlights the importance of crime not undermining community cohesion
• It is also welcome that the NPPF places sustainability at the forefront of planning; however, the environmental cost of crime is often overlooked when discussing this issue
• A simplified planning system is important and the NPPF is positive in this respect; however, other Government reforms such as the Housing Standards Review (HSR) and recommendations taken forward from Lord Taylor’s Review of Planning Practice Guidance risk undermining the safety and sustainability of housing
• Reducing unnecessary bureaucracy in the planning system is important; however, security should remain a central facet, and is not burdensome or costly
• The latest HSR announcement regarding a minimum security standard is welcome; however, there are many unanswered questions to address our concerns regarding the initial proposals – the minimum level must meet current Secured by Design standards
• We also remain opposed to the Government’s cancellation of the Code for Sustainable Homes – the main driver of Secured by Design homes – as this will significantly undermine the NPPF’s presumption in favour of sustainability
• The summary of responses to the HSR demonstrate overwhelming support for Secured by Design and the points we have raised with the Department for Communities and Local Government and Home Office
• Secured by Design developed a revised ‘Safer Places: The Planning System & Crime Prevention’ document following the Government’s decision to accept Lord Taylor of Goss Moor’s recommendation for its cancellation or revision. The Home Office indicated it would upload this to its website, but has yet to do so and the delay is concerning and risks undermining the NPPF’s principles
• The impact of the HSR proposals, revision/removal of the Code for Sustainable Homes, changes to planning process and the cancellation of  the ‘Safer Places’ document should be viewed collectively for the risk they pose to the safety of communities

2. Secured by Design and the NPPF

2.1 Secured by Design is a flagship initiative with the objective of designing out crime during the planning process and can be retrofitted to housing and other projects. We believe that communities have the right to feel safe in their area, and security standards are about ensuring this is a consideration in both the planning process and retrospectively.

2.2 Independent research has shown that developments with low level security suffer 75% more burglaries than those with realistic Secured by Design level security, while criminal damage is also reduced by 25%.

2.3 Secured by Design is a respected standard in the sector, and supported by numerous local authorities and professional bodies. The initiative is open to all sections of the construction industry provided they meet the security standards in our project.

2.4 The scheme is self-funded by our accreditation of a range of security products which can be shown to meet standards and reduce crime. Any surplus is reinvested in research and crime prevention projects across the country. There is no obligation on builders or architects to use these particular products, many of which are not related to construction. As such, it is evident that Secured by Design has tangible benefits to society as a whole, particularly in building sustainable and safe communities.

2.5 As you will know, the NPPF notes that planning policies and decisions should aim to achieve places which promote “safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion.” This principle is at the heart of our initiative and something we have worked tirelessly to achieve.

2.6 Moreover, we welcome the framework’s presumption in favour of sustainable development, a “golden thread” throughout the NPPF. We firmly believe that the cost of crime must be taken into account to ensure housing is as sustainable as possible; this is an area that is often overlooked when considering sustainability of future housing.

2.7 In fact, the International Energy Agency estimates that 2.5 tonnes of carbon dioxide are released as a result of each burglary. Moreover, the carbon cost of crime in England and Wales has been found to be a minimum of 6,000,000 tonnes of CO2 equivalent each year (Pease & Farrell 2009). Combating crime means that carbon costs such as police mileage in response to the crime, replacement of stolen and damaged property, and moving costs to new homes away from high crime areas are eradicated. Moreover, by reducing burglary and anti-social behaviour there are significant benefits reaped in terms of reduced maintenance costs and fewer void properties to protect. In numerous cases, planning developments from the 1980s, which stem from poor design, have even required demolition. Secured by Design is committed to not only reducing crime, but its environmental implications as well and therefore ensuring the sustainability of the housing stock. Such is our concern that we are match-funding the Home Office for a four year EngD placement at Surrey University to further investigate the carbon cost of crime.

2.8 The strength of research undertaken has reinforced our view that the safety and security of homes is a critical element of sustainable housing. Despite the evidence, there has always been a blind spot with regard to security standards which are rarely accounted for in the public sector’s environmental audits or carbon plans. Moreover, the Government’s definition of a zero-carbon home fails to mention crime and the contingent costs which crime would cause at all.

3. Impact of Government Reforms on NPPF

3.1 I would put on record our support for a simplified planning guidance system and housing standards that enables planners and developers to understand the requirements placed upon them. Simple guidance and standards can help to create sustainable and safe developments for communities across the UK. The NPPF, in isolation, has the potential to make a valuable contribution in this respect, but we are concerned that other areas of Government reform will hinder its effectiveness. I would urge you to consider this as part of the inquiry because, in our view, any success achieved over the past two years by the NPPF risks being undermined by initial proposals in the Department for Communities and Local Government’s (DCLG) ongoing Housing Standards Review (HSR) and steps taken following Lord Taylor of Goss Moor’s Review of Planning Practice Guidance.

3.2 Regarding the HSR, you may be aware that the DCLG published a Written Ministerial Statement on 13th March 2014 regarding the Housing Standards Review (here). A ‘roadmap’ is due to be published, but in the meantime, an accompanying note stated the following:

“The Government recognises the value of a single minimum security standard for new homes, based on industry’s best practice. The Government is considering the evidence on whether such a standard should be applied to all new homes, as a Building Regulation applied nationally or whether it would be more proportionate if applied on a local basis.”

3.3. Whilst this is welcome news, a number of crucial questions remain unanswered. Initially, proposals were put forward by DCLG for a two-tier standard for security, but the department undermined local authority powers to select the enhanced, yet affordable level for developments in an attempt to sideline decent housing standards. This enhanced level was also lower than the respected and recognised Secured by Design standard; it is essential that any minimum standard does not fall below our current level, otherwise the principle of crime safety contained in the NPPF will be fundamentally undermined. Moreover, as the only organisation undertaking this type of work, we would reiterate our call for Secured by Design to be signposted by the Government to ensure that planners, local authorities and others can continue to keep residents safe from crime.

3.4 The initial proposals were formed using spurious claims that Secured by Design is bureaucratic and costly, when independent assessment conducted in 2010 showed the additional cost of standards in the average home is just £170, and estimated that installations pay for themselves in no more than 2 years, and in some cases as little as 8 months. Moreover, we have undertaken further analysis of the cost which supports our arguments. We would not dispute that where unnecessary burden on developers exists, it should be reduced. However, security standards are fundamental to housing quality and residents’ safety, as noted within the NPPF, and we believe they should be engrained in the planning process.

3.5 In addition, alongside the announcement, a summary of responses to the HSR was published (here), which indicates overwhelming support for Secured by Design, as well as calling into question the Impact Assessment used to guide proposals. We are delighted to see so many organisations and individuals across the board highlight the importance of crime prevention, and the Secured by Design initiative in particular.

3.6 The DCLG has also recommended the winding down of the Code for Sustainable Homes (CfSH). Secured by Design is included within the CfSH, and has been the main driver of homes built to the standard, reinforced by the Homes and Communities Agency’s (HCA) insistence on social housing meeting a certain level of the Code. Its demise will damage the sustainability and safety of homes, and contradicts the NPPF’s important principles. We remain firmly opposed to this move.

3.7 We await further detail on the ‘roadmap’ referred to within DCLG’s recent statement and will continue to work proactively with the DCLG and Home Office to ensure that Secured by Design remains a critical element of housing standards and planning, allowing the NPPF to remain an effective tool for planners.

3.8 Regarding the Government’s National Planning Practice Guidance portal, set up following recommendations made by Lord Taylor of Goss Moor, we are concerned that designing out crime does not feature heavily enough. ‘Safer Places: The Planning System and Crime Prevention’ was ordered for cancellation following Taylor’s review. Deregulation of the housing sector is perceived as a driver for growth in the housing market, but stripping back sensible guidance and standards is a false economy which will impact communities for decades to come, conflicting with the beneficial outcomes outlined in the NPPF.

3.9 I would note that following further discussions, Secured by Design have prepared an updated version of the document as, whilst we agree that it required updating, there were vital principles that must remain embedded in planning. The Home Office was set to upload our revised document on its website; however, there is no sign of this. Any attention the Committee can draw to this point would be very valuable in ensuring that the NPPF’s commitment to community safety is fulfilled.

3.10 We would stress that the Select Committee takes all these factors into account as part of its inquiry, because too often the HSR, the revision/removal of the Code for Sustainable Homes, changes to planning process and the cancellation of the ‘Safer Places: The Planning System & Crime Prevention’ document are seen as separate issues. However, both individually and collectively they remove or reduce the ability to set local policy and standards of security and undermine the principles contained in the NPPF.

I would reiterate my offer  to provide further evidence during the Committee’s oral sessions. In the meantime, a detailed explanation of our work, including research papers and information to the general public on how to improve safety and security can be viewed at www.securedbydesign.com.

May 2014