Insights
Is the Draft London Plan shifting responsibility for designing out crime?
At LMS, we ensure that all planning adherence complies with national, regional and local level legislation whether this be the National Planning Policy Framework (NPPF) or a local city plan.
Our collaborative approach and relationships with developers and planning authorities ensure that our knowledge of all security related requirements is embedded in our methodology for secure and safe places within accessible realm and buildings alike.
Having reviewed the Draft London Plan we note a distinct change in requirement wording; a broader ‘security and safety’ framing. Akin to the draft Design and Placemaking Planning Practice Guidance (PPG), this also focuses on safe public spaces, inclusive environments, good movement networks and treats security as a vital component of good placemaking.
Where once key words included DOCOs and Secured by Design, CCTV, Access control, Physical Security, HVM etc. the approach is now widened and softened and focused on safe outcomes, public realm quality, healthy streets (i.e. positively used), community safety, resilience and again, good placemaking. Ensuring the safety of women and girls (VAWG) and inclusivity are very much supported and a significant addition to the former policy.
The theme embeds a risk management approach, not on prescribing the exact security functions to be specified but more on how and where this is going to be achieved, based on what research and evidence, and proportionally why, without transferring risk elsewhere, emphasising a ‘designing out crime’ methodology rather than moving the problem elsewhere.
Are we witnessing the gradual transfer of responsibility for crime prevention from the police to the planning and development industry?
For many years, London planning policy has outlined a relatively clear framework.
Policy D11 of the 2021 London Plan explicitly referenced Designing Out Crime, counter-terrorism, physical security, electronic security and consultation with Metropolitan Police Designing Out Crime Officers (DOCOs) and Counter Terrorism Security Advisors (CTSAs). However, the Draft London Plan takes a different approach.
Security still exists through Policy MBUL10, and engagement with the Metropolitan Police, CTSAs and other stakeholders remains expected. However, the policy is more concise and excludes specific references as before, and places greater emphasis on creating places that are safe, inclusive and resilient through good design rather than through explicit security interventions alone.
Is this a weakening of security policy?
No. LMS see this as part of a wider trend that is emerging across planning, spreading responsibility across competent specialists that can advise and embed security strategy and appropriate design solutions within the requirements. And this reflects the same approach we take at LMS.
The Draft Design and Placemaking PPG, the National Model Design Code, Healthy Streets principles, VAWG guidance and the London Plan itself are increasingly pushing responsibility for ‘safety outcomes’ towards designers, planners, developers and specialist security consultants.
The expectation is no longer simply that developments are secure. The expectation is that developments can clearly demonstrate how safety, security, inclusivity and wellbeing have been considered proportionally and balanced from the earliest stages.
Historically, planning authorities and project teams have relied heavily on Police DOCOs to review layouts, challenge designs, identify vulnerabilities and advise on crime prevention through environmental design (CPTED), and to this day do still play a critical role in translating crime prevention principles into practical development advice. At the same time, the role itself has become more specialised, with the NPCC formally designating DOCO as a specialist policing function and recognising its growing importance within prevention-led policing.
However, anyone actively working in planning and development knows that public resources are under pressure and this includes policing.
Availability of specialist crime prevention input is increasingly stretched and the responsibility of providing crime prevention advice and early planning security needs or crime impact assessments is not new to the security consultant family.
As demand continues for new buildings, housing and mixed developments, there is also an increase in legislative compliance and a competent necessity for understanding the technological complexity that has increased around us within the past 10 years including the advancement of integrated electronic security systems, drone adaptability, political and socioeconomic threats and the emergence of AI.
So is this just more requirement for security consultants to undertake this work?
Yes and no. It is not just a matter of propping up support or completing a tick box exercise, this is about understanding what is being asked to demonstrate compliance.
The approach moving forward will require a wider remit and justification.
The focus is moving away from individual security features and towards broader questions:
- Does the place feel safe?
- Does the design reduce opportunities for crime?
- Are vulnerable groups able to navigate the space safely?
- Are hostile threats understood?
- Has operational security been considered?
- Is there evidence supporting the design decisions?
These are not purely policing questions anymore; they are planning questions and design questions. And increasingly, they are security consultant questions.
For security specialists like us at LMS, this presents both a challenge and an opportunity.
The challenge is that we can no longer rely solely on traditional security disciplines.
Understanding planning policy, urban design, placemaking, public realm design, design coding and legislation such as the Building Safety Act and the Terrorism (Protection of Premises) Act, is becoming just as important as understanding the technicalities of Electronic Security Systems and Hostile Vehicle Mitigation.
The opportunity is that security consultants are uniquely positioned to bridge the gap between planning, architecture, operational management and protective security.
The Draft London Plan is signalling a future where security is not a specialist add-on or tick box chapter within a Planning Report or Design and Access Statement, it is becoming a fundamental component of placemaking. Early doors consultation with experienced security specialists supporting the journey from the start, including before a premises has even been chosen.
As that happens, the responsibility for demonstrating how crime has been assessed, how risks have been mitigated and how safety has been embedded within the design may increasingly sit with specialist security design consultants.
If planning policy increasingly requires developments to demonstrate how they have addressed crime prevention, VAWG strategy, public realm safety, terrorism resilience, and operational security, then security consultants will need to take a much greater role in providing that evidence base.
In many ways, we are moving towards a model where security consultants will increasingly undertake functions that have historically been viewed as police-led activities. Not replacing DOCOs. Not replacing CTSAs. But undertaking the detailed vulnerability assessments, site location suitability processes, crime analysis, public realm safety considerations and architectural design reviews that allow projects to reach a point where police engagement becomes more strategic and less transactional.
This is something we see becoming increasingly important as Martyn’s Law starts to influence development thinking. The Terrorism (Protection of Premises) Act 2025 has changed the conversation around security. Physical security is still important, but there is now growing emphasis on preparedness, governance, incident response, operational resilience and appropriate and blended protection, whilst also mindful of a client’s budget.
Security is no longer simply about whether a building has CCTV or a host of bollards outside. It is increasingly about whether the organisation occupying that building understands risk and is prepared to manage and evidence it.