Representation by Suffolk Constabulary (Suffolk Constabulary)
- Date submitted
- 25 September 2020
- Submitted by
- Other statutory consultees
Dear Sir / Madam, I write to formally register Suffolk Constabulary (SC) as an Interested Party in the Sizewell C (SZC) Nuclear Power Station Development Consent Order (DCO) application and provide below our Relevant Representation. I can also confirm that SC is a Statutory Party (as defined by Schedule 1 of The Infrastructure Planning (Applications: Prescribed Forms And Procedures) Regulations 2009)) and was consulted by EDF (the scheme promoter) prior to submission of the DCO application in accordance with Section 42 of the Planning Act 2008. Context SC is the territorial police force responsible for the county of Suffolk and has a mission to make Suffolk a safer place to live, work, travel and invest. Under the leadership of the Chief Constable, SC uses its resources to protect its communities and prevent crime happening in the first place, with a particular focus on preventing harm and protecting the most vulnerable in our communities. This is articulated in SC’s Strategic Plan 2020 - 2023. The Suffolk Police and Crime Commissioner is responsible for setting policing objectives and does this through his Police and Crime Plan. SC currently has an establishment of 1,172 FTE police officers, 40 PCSOs and over 872 police staff divided between local policing teams, support functions and specialist teams. The county is split into three operational policing areas and constituent Local Policing Commands (LPCs), with the SZC site falling within the Eastern area and Halesworth LPCs respectively. However, in an emergency situation police resources from across the county may be called upon. A number of operational and back-office functions are also provided in collaboration with Norfolk Constabulary. Areas of Interest SC holds no views as to the virtues of nuclear energy or the planning merits of the proposed development itself. In responding to the SZC DCO application, SC is solely concerned with ensuring that all likely significant impacts relating to community safety and policing arising from SZC are fully identified, assessed, and adequately mitigated. Policing is a complex and multi-faceted activity which plays a key role in responding to and managing many community safety risks, extending well beyond what may be perceived as deterring and investigating traditional crime types. It is welcomed that EDF has recognised the need to manage community safety impacts from SZC and proposed associated mitigation measures, which are broadly supported. However, from information provided in the SZC DCO application and SC’s own analysis, it is clear that the construction and operation of SZC is likely to generate a wide range of community safety impacts on both the SZC workforce and existing communities which will also require additional input from SC to manage effectively. SC’s objectives in relation to the Examination and determination of the SZC DCO application are therefore to: • Understand and address the full range of likely community safety and policing impacts from SZC. Acting as a statutory consultee, SC will be pleased to assist the Examination Authority in considering these matters fully; and, in doing so, • Secure appropriate mitigation to avoid likely significant adverse community safety impacts and any other unacceptable community safety risks. SC operates to capacity and will require additional resourcing to address the net additional impacts of SZC. Potential Community Safety Impacts SC has engaged with EDF throughout all pre-application stages of consultation and continues to do so, including ongoing work to prepare a Statement of Common Ground (SoCG). SC has also participated in, and attended, meetings of the Emergency Service Working Group and Community Forum convened by EDF. As highlighted to EDF through pre-application consultation, the nature and scale of SZC is likely to give rise to the following community safety impacts: • Substantial demographic changes (increased population and altered profile compared with the baseline situation) giving rise to changes in safety, crime and welfare and wellbeing. This includes community safety impacts affecting both the SZC workforce (e.g. risk of becoming a victim of crime or otherwise requiring police assistance) and existing communities. Community safety impacts requiring involvement from SC are likely to include mental health and missing person incidents, reduced community cohesion, a rise in anti-social behaviour, impacts associated with growth of the night-time economy (e.g. from licensed premises and drug related crime), impacts on vulnerable groups, exploitation, and increases in a wide range of crime-types being committed and detected; • Substantial traffic changes, which SC will need to help manage to protect road safety and the functioning of the transport network. This includes a requirement for SC to escort significant volumes of abnormal indivisible loads (AILs) safely and timeously to facilitate the efficient construction of SZC. Other construction traffic impacts and proposed road infrastructure works are also likely to result in changes in use of the transport network road safety and increased emergency response times; and, • Substantial changes in emergency / civil contingency planning, preparedness and response requirements. Working alongside EDF and partner agencies, SC will need to fulfil a key role in mitigating the net additional community safety impacts associated with SZC. These impacts will therefore generate net additional police resourcing requirements, which need to be addressed in full for SC to help mitigate identified community safety risks whilst continuing to provide a high quality policing service to communities across Suffolk. Alongside police officers, adequate police staff, technology, fleet, estate resources and co-ordination with partner agencies are also essential to maintain a high-quality policing service. All parts of SC would be engaged in addressing the community safety impacts of SZC, with significant resourcing implications for: • Local Policing – responding to incidents, investigations and wider community safety issues; • Command and Control – responding to 999 and 101 calls, incident response, co-ordination and emergency preparedness; • Custody – arrest and custody suite demand; • Roads Policing – escorting AILs, road safety, traffic management and incident response; and, • Public Order response and intelligence. Principal Issues and Concerns Based on our review of relevant documents including the SZC Environmental Statement (ES) and associated Community Safety Management Plan (CSMP), SC is concerned that important points made in our pre-application consultation responses have not been fully addressed and in consequence there are gaps in the published assessment of community safety and policing impacts. Without prejudice to detailed matters which may be raised in subsequent representations, SC has consistently identified the following key concerns: • Narrow scope of assessment - the singular focus of the policing impact assessment on recorded crimes is inadequate. Whilst the CSMP calls for SC to play an active role in managing community safety, which is to be welcomed, no consideration is given to the associated assessment of wider community safety impacts requiring police involvement (whether in terms of emergency preparedness, prevention, deterrence, safeguarding, incident response or investigation). The role of SC in addressing community safety impacts beyond recorded crime should have been recognised and addressed; • Limited consideration of demographic risks – the published assessment of effects on population dynamics does not appear to have been factored into the assessment of policing impacts, as this only considers crime impacts quantitatively on a per capita basis. Coupled with the narrow scope of assessment, it is therefore difficult to determine whether the mitigation proposals set out in the CSMP will be effective in avoiding significant adverse community safety impacts; and, • Sufficient information has not been provided regarding the range of potential transport impacts likely to require a net additional police response. To help address these concerns, SC has undertaken a demographic analysis and is currently using SZC workforce and traffic data provided by EDF to model the wider scope of likely community safety and policing impacts. SC has also sought clarifications from EDF regarding the assessment of potential transport impacts. Next Steps SC welcomes the opportunity to participate in the SZC Examination as an Interested Party. Building upon this DCO Relevant Representation, in due course SC intends to submit a detailed Written Representation covering the following two substantive elements: • Detailed comments regarding the assessment and acceptability of likely community safety impacts presented in the published SZC DCO application; and, • SC’s own assessment of likely community safety and policing impacts arising from SZC. Based on information provided in the SZC DCO application, an early draft has been issued to EDF in order to facilitate discussions around the preparation of a SoCG. Once finalised, this will provide a fuller understanding of community safety impacts and will support the quantification of net additional policing resource requirements. In tandem SC intends to continue working with EDF to ensure that likely community safety and policing impacts from SZC are appropriately identified, assessed and mitigated. This will include working to agree a SoCG and Strategic Relationship Protocol (SRP) between EDF and SC. Should you wish to clarify any of the matters raised above, please direct any communications in the first instance to Natalie Maletras of Stantec UK Ltd, which is providing planning and technical advice to SC in connection with the SZC DCO application. Yours sincerely, David Cutler Detective Chief Superintendent Suffolk Constabulary