Knowsley Council Liberal Democrats Closing Submissions

TOWN AND COUNTRY PLANNING ACT 1990 – SECTION 77
TOWN AND COUNTRY PLANNING ( GENERAL DEVELOPMENT

PROCEDURE ) ORDER 199TOWN AND COUNTRY PLANNING ( INQUIRES
PROCEDURE ) (ENGLAND ) RULES 2000
APPLICATION BY TESCO STORES LTD
LAND TO THE SOUTH OF CHERRYFIELD DRIVE, KIRKBY
Planning Inspectorate Ref : APP/V4305/V/08/1203375

Local Authority Ref : Amended Scheme APP 08001/HYB
KCLD
CLOSING SUBMISSIONS
1. The Application was supported within the framework

of local,
regional, and national planning policies.
The proposals, includes a 14,974 square metres

supermarket: and a new retail floor space of 38,139
square metres that is approximately double that in the
existing town centre, the demolition of the existing
civic centre, and location of a football stadium within
the new retail centre. Given its overall scale and wider
impact we say the scheme ought to have been made
through the development plan process, as ( vi ) SoS
letter 12 September 2008 Ref:
APP/V43005/08/1203375
2. Its passage through the planning process in our view

requires it to be measured and compliant with current
planning policies.
3. In accord with the directions of the Secretary of

State’s (SoS)
letter of 12 September 2008 ref:
APP/V4305/V/08/1203375.
Page 2 (a), these are the Knowsley Replacement
Unitary Development plan adopted in 2006 (KRUDP):
The North West of England Plan Regional Spatial
Strategy to 2021 published in September 2008. And
regard to the provisions of Section 38 ( 6 ) of the
Planning and Compulsory Purchase Act 2004.
In (b.) Planning Policy Statement 6: Planning for town

centres is also relevant.
1

4. There appears to be general consensus on all sides

that there is a qualitative need for retail development
in Kirkby Town Centre. The disagreement lies within
which centre the existing one or its potential rival
South of Cherryfield Drive ?
5. The quantitative need forms a basis for this proposal.

It has been argued by the applicant that the retail
uplift can only be achieved by a new supermarket and
additional retail space on a site away from the town
centre and outside the Kirkby Town Centre Action area
as defined in Policy S4 KRUDP.
6. The KRUDP had a gestation period from 2001 – to

adoption in 2006. This process was assisted by the
Chesterton Shopping Survey 2002 and a local inquiry
on the Kirkby Town Centre Action area in October
2005.
7. One of the Strategic Objectives of the Town Centres

and Shopping – Chapter 7 of the KRUDP
• “To improve the provision of shopping, leisure and

other uses normally associated with town centres
consistent with local needs, whilst protecting and
enhancing the viability and vitality of town, district
and local centres in Knowsley. “
This Inquiry received written evidence and oral

evidence from
Only two Council members. On the 21 January 2009 Cllr
Fricker was taken through his proof of evidence as a
Huyton based member with strong community links he
disputed the Evidence of J Williams TEV/P2 Page 65/79
para 10.24 that the majority of cumulative
diversion would be from the
overtrading Huyton Asda” Cllr Fricker challenged the

view Asda was overtrading. It was noted vacancy rates
2

in Huyton town centre were 19% against a national

average of 11% page 21/53 para 3.26 J Williams proof.
On the 22 January 2009 Cllr Smith’s written statement

dated
15 December was presented to the Inquiry along with
oral
evidence. As leader of the town council and borough
councillor
he disputed the evidence in J Williams Proof page
65/79” that
the Prescot Retail Park is seen as part of the town
centre, “and
outlined the impact of the retail park on Prescot’s
historic town centre. He confirmed the Council
had appointed a town
developer ( Brook house) to produce a development
for the
town centre which Cllr Smith said was run down, he
feared
the planned retail draw to Kirkby was a threat to the
viability of Prescot town centre.
• Prescot is located in Zone 2, Huyton in Zone 4 of the

Primary Catchment area for the Kirkby development.
The proposed size of the PCA will impact on both
Huyton/ Prescot
• The hierarchy of centres within Knowsley are set out in

7.6 Figure 7.1 of Chapter 7.
3

• It gives no indication that any the three centres would

grow or enlarge beyond their designated status within
KRUPD.
• As the Government Office for the North West has to

approve the development plan, they clearly accepted it
has a working document capable of taking forward the
Council’s objectives.
The proposed plan is supported by the Council.

In Proof of Evidence page 14 section 3.14 S. Ramsey
says
“The Council is of the view that the Tesco/ Everton
proposals will create a crucial step change in the long
term regeneration of Kirkby by creating much needed
local employment.”
8. However the applicants submissions in Inquiry CD 5.1

the
Planning report KMBC 9TH June 2008 page 32 says ”the
mixed use development is proposed including a new
stadium for Everton FC……… The cost of a new
stadium is such the EFC require a large element of its
overall cost to be provided through some form of gap
funding. The applicant submits that the application
site is the most form of development in the Liverpool
area, and offers the potential for the retailing
elements to fund a large element of its overall cost. “
9. The position is given further gravitas by the applicant

in the report on page 55/56
Everton’s Current Financial Position “ It states that

the key principle that underpins the proposals is that
the stadium, for viability / costs reasons, cannot be
secured without the enabling development proposed.
In essence without the retail there can be no stadium,
and furthermore the applicant states, without the
4

stadium the amount of retailing proposed would be

less supported by the Council for policy reasons.”
10.This would suggest the huge increase in retail floor

space
beyond the KRUDP allocation is to enable EFC – a
private limited company with Shareholders – to meet a
“pressing need for a new stadium”
11.For the applicant the Inquiry was provided with a

letter Ref: ESIM/T34/15237 dated 22 October 2008
blplaw
“This technical form of enabling development is not

the basis of our case and accordingly it will form no
part of our evidence “
12.Throughout the Inquiry the applicant parties used the

KMBC planning committee decision - to be mindful to
support the plan after considering the planning report
- as a lever to illustrate Council support.
13.It is our view the evidence would indicate the

departure from policy is proposed to enable EFC to
acquire a new ground.
14.What is the Councils policy on Kirkby Town Centre

without
the stadium element ?
15.The Inquiry has been told by a number of the

applicants
witness’s that the applicant has nothing on the books
as an alternative retail development in the event of
this plan failing.
“Stadium/Scheme all or nothing” ( Black xx’d Fisher)
28 Nov.
16.Having been a member of Knowsley MBC from its early
5

inception until early into the new millennium I hope

my observations help better understand Council policy
toward Kirkby Town Centre that has gradually led to
its current state.
It might also assist the SoS to balance evidence as to
why
Kirkby was without an anchor Supermarket for 30
years.
17. Asda opened their doors in Kirkby Town Centre in

April 1971
on a 25 year lease by Mars Securities/ Telegraph
properties.
18. In 1979 they vacated the store and complied with the
full terms of the lease until it expired in
December 1996
19. In evidence to the Inquiry KCLD/ INQ/1

correspondence and
reports indicate the level of lobbying from 1984 until
2001 to
urge KMBC to improve the retail and environment of
Kirkby
Town Centre
20 In 1997 following the expiry of the Asda lease

attempts
were made to obtain a CPO against the head lessee
Aubrey
Weiss to obtain the demolition of the old Asda and
secure a
large and prominent site for a new supermarket
anchor.
21. This move was unsuccessful and with the political

control
of this matter resting with two individual Councillors
this led
6

to Councillors having to rely on verbal feedbacks

and limited
committee reporting.
During the period Aubrey Weiss was receiving the

full
terms of the lease from [1979 until 1996 ] the old
Asda
store remained empty.
In May 2001 KMBC called a meeting in Kirkby

between all
its Kirkby Councillors, local town centre traders,
and St
Modwen Propertities who had just bought a 50%
share of
The town centre in conjunction with the joint
owners.. and
will be injecting substantial sums into upgrading it
and
seeking to improve its attractiveness to existing and
potential customers, Ref: KCLD INQ DOC 107- letter
from KMBC Deputy Chief Executive and Director of
Planning
to Cllr P Fisher, who was in attendance at the
meeting.
23. It says the meeting “would have benefited from a

higher
attendance of traders” Notwithstanding this the
efforts of
St Modwen were a clear vote of confidence in the
Town
Centres capacity and attractiveness to bring a major
retail
investment to Kirkby in 2003/5 during the passage
of
KRUD process.
7

24. Michelle Taylor the MD of St Modwen sets this out

in her rebuttal proof of statements. In her main proof
of
evidence Page 9 para 5.10. 11 and 12 evidence is
given as to
the reason the Council discontinued with St Modwen
and
chose Mr Weiss – as a joint owner of the town “to be
its
development partner for the wider regeneration of
the town
centre “ This redevelopment never took place with
Mr
Weiss later selling his interest to this applicant.
25. The decision, given this history and stagnation of the

town
centre while Mr Weiss was a head lessee, in our
view, beggars belief. It is clear the Council decision,
taken
outside the committee structure prevented the
redevelopment of Kirkby Town Centre and the loss of
hundreds of new jobs and further retail/ commercial
growth.
26. We therefore suggest that the lever of a 30 absence

of a
major supermarket being used to justify this scheme
is highly
questionable. We also say that the reluctance of the
Councillor, who wrote to the Inquiry stating he had
lead
responsibility for Economic Development 1990 – 2001,
to
appear before the Inquiry to help with background
information adds little weight to this argument.
8

27. Turning to the proposed retail development South of

Cherry
field Drive, and size of the new supermarket.
28. Mr William’s in his main proof of Evidence TEV/P/2

page 33
para 7.15 set out the applicants rational on arriving
at the
Primary Catchment Area [PCA ] for the proposed
Tesco in
Kirkby. In Table 1c appendices A1 this is 225,994 –
2008
rising to 226, 289 in 2013.
29. Interestingly Roger Tym Partners Final report – CD Ref

3.18
page 24 para 4.10 “ Our primary concerns relate to
the
applicant’s assessment of quantitative need in the
comparison goods sector.” i ) the PCA for Kirkby town
centre
is too extensive, geographically, in relation to its
current
position in the retail hierarchy ;
30 The PCA includes Huyton and Prescot and projects a

retail
draw from both centres to Kirkby post development.
Figures set out in Mr William’s main proof Table 19c
give a
Combined impact of £19.14million from Prescot and
£11- 35
million from Huyton up to year 2013.
31. This in our view will alter the shopping hierarchies in

the KRUP and have an adverse effect on the vitality
and viability of Kirkby’s neighbouring centres. SoS
letter b. iv.
9

32. The overall retail scheme in the applicants submission

offers
the potential for the retailing elements to fund a
large
element of its overall cost of the Scheme including
the
stadium. This increase in retail floor space is clearly
sought to
secure gap funding for the stadium Ref: INQ CD 5.1
page 32 .
33. In our view the case for increasing the retail space to
almost
double the size of the existing town centre has not
been made
on demand rather to enable Everton FC to build a new
stadium with funding derived from the retail
development.
34. Planning Policy Statement 6 - Promoting Growth and

Managing Change in Town Centres 2.3 says Councils
should
actively plan for growth and change in town centre
over the
period of their development plan. The pro active
approach by
St Modwens Properties 2001-5 and Development
Securities in
2007 confirmed a large development could be
accommodated
within Kirkby’s existing town centre.
Ref: Appendix CAO/A/4 A news article 19 November

2002. St Modwen said the that “ Kirkby remains an
attractive
location for both retailers and shoppers which bodes
well for
our longer term redevelopment plans “ Michelle
Taylor.
10

This would accord with PPS6 2.4 2.5 2.6 and dispel
the
negative descriptions of the Kirkby town centre
advanced
by a number of the applicants witness’s
35 Knowsley MBC undertook the UPD exercise to

determine the policy for its Town Centres. The retail
plan runs contrary to
KRUDP Policy S2 1 a) as it would be incompatible with
the scale and role of Kirkby Town Centre and have a
detrimental impact on the existing retail in the centre.
36. Policy S4 sets out the retail requirements for a major

food
store. The proposed Tesco store is approx double the
size
set out in the policy.
37. PPS Networks and Hierarchies 2.9 “ In promoting and

enhancing existing centres, local planning authorities
should consider the network of centres ( i.e. the
pattern of
provision of different centres) and their relationship in
the
hierarchy.” The PCA for the new Tesco will clearly
impact on
the KMBC Hierarchy of centres as set out in Chapter 7
KRUD
section 7.6 Figure 7.1 This plan and the proposed
retail draw
from two of those centres to the other will disturb
their
equilibrium in the KRUDP Policy and Strategic
Objectives in
11

Chapter 7 To improve the provision of shopping,

leisure and
other uses normally associated with town centres
consistent
with local need and enhancing the viability of town,
district
and local centres in Knowsley.
The Inquiry did not receive any guarantees that the

planned
development for the North of the town centre would be
completed within an acceptable timescale to ensure it
survives
as a main retail centre able to compete with a new
town centre
South of Cherry field drive
38. The Regional Spatial Strategy 2021 sets out the role
and
of the regional centres in Policy W5. KMBC would have
advanced any evidence based argument to justify the
extensive
increase in Kirkby’s town centre retail function.
Its clear the deliberations concluded Kirkby can provide
a retail base commensurate with its population, nearby
areas, and complementary to its existing retail offer.
39. The proposed Stadium is expected to be as high as a

three
storey building. Commenting on its design in INQ CD
5.1
page 310 KMBC planning officers observe “ It has been
acknowledged that the adopted design here, in
contrast
to some recent stadium proposals, is not one for an
iconic
exemplar building. Rather, the design is a somewhat
more
traditional stadium design….. Indeed, a somewhat
utilitarian
12

and cost – conscious design is evident in the way that

the under
side of the upper stands is revealed to outward view. “
40. On page 315 Planning officers say “ The main impact

from both
the stadium and new retail uses is likely to be on
existing
residential properties in the Grange estate….The
visual and
psychological impact of the presences of the stadium,
in such
close proximity to at the very least the most westerly
properties in the Grange Estate would be more difficult
to
address. Inevitably, there will be a significant
detrimental
imposition upon the amenities of occupiers of the
nearest
properties within the Grange Estate that cannot be
adequately
mitigated. “
41. There is a proposal to construct a Bund/ Acoustic

barrier to the
of properties in Whinberry Drive to alleviate noise
42. The Stadium/Bund needs to be tested against KRUP

Policy DQ1
“Design quality in New Development “ and Policy H5:
“ Development within Primary Residential Areas “
Policy DQ1:
New development should be of a high quality design
which will:
a) Respond to and, where appropriate, enhance the
13

characteristics of the immediate surrounding area

through
the use of appropriate scale, density, massing,
height, and
building lines.
b) Preserve or enhance views of important landscape

features/
buildings in surrounding areas.
Policy DQ1 applies to all new development.
n.) Achieve good design quality in all new buildings and

structures
in terms of their scale, style….
This “In order to preserve the amenities of neighbouring

occupiers,
New buildings should not have an overbearing effect
so that
They would not have an overbearing effect or cause
loss of
light or privacy”
Residents faced with seeing a bund [ which was evident in

the apartheid South Africa ] at the rear of their properties
are entitled to the safeguards provided in the KRUPD
We say that to construct what the Council planners describe

“ as not an exemplary iconic building, rather a more
tradition style
somewhat utilitarian and cost – conscious design is evident
in the way that the under side of the upper stands is
revealed to outward view. in the centre of a quality
residential area is contrary to the provisions of KRUP
Policies DQ1, and H5, which states: new development within
the Primary Development Areas will be permitted provided
that the that development [ either by itself or in conjunction
with other development would not :
14

a) Have an unacceptable impact on the amenity of

neighbouring occupiers by reason of noise, disturbance,
overlooking, visual intrusion, smells, fumes, on street
parking…
b) Adversely effect the character or street scene in the

area.
KRUPD Policy ENV2: 1. Says “Development that will either

cause an unacceptable level of noise or vibration levels or
itself be subject to unacceptable noise or vibration from an
existing source will not be permitted”
We say the prospect of residents on the Grange Estate

hearing the equivalent noise of a Hoover appliance being on
during football matches at the stadium is likely to create
these problems for residents and run contrary to KRUP
Policy H5: ENV2 and DQ1.
43 Civic Buildings and St Chad’s Conservation Area.
In Inquiry evidence SUP/KMBC/P/1 page 14 para 3.14 the

Council is of the view that the Tesco / Everton proposals will
create a crucial step – change in the long term regeneration
of Kirkby.
This includes the demolition of Kirkby two highly visible

Civic Buildings, The six storey Municipal will be replaced by
a smaller building as part of a cost cutting exercise as
stated in J Francis
Proof of Evidence page 44 of 121 para 11.13
The Demolition of the Kirkby Suite will leave the town of

Kirkby without a Civic Suite that was transferred to KMBC
serve the wider Kirkby Community. It is a better building
than its counterpart in Huyton which will be the only
remaining Civic Suite in the borough.
15

In JD Francis Proof of Evidence page 45 of 121 para 11.15

the effect of the closure is stated “ This will assist in the
removal of existing running costs associated with the Kirkby
Suite and deliver associated financial savings”
44. These two buildings on there own may be of limited

architectural merit, but collectively give the town a sense of
scale that will be lost by their demolition.
In our view to describe this kind of asset stripping as “

regeneration” is ludicrous.
In any future local Government Boundary Review Kirkby

residents may well take the view they would wish self
governance rather than
a council centred entirely in Huyton. These important
buildings will be needed and ought to be retained and
refurbished and not sacrificed for retail units.
45. St Chad’s Church is in the epicentre of the town, a Grade

Two listed building and located within the Old Hall Lane
Conservation Area
The Church faces the prospect of a visual intrusion into its

realm.
KRUDP Policy DQ5 Covers “ Development in conservation
Areas “
1. New Development within or close to a Conservation area

must preserve of enhance the character or appearance of
the areas having regard to the following :
a) The scale, form , massing, height, materials and

architectural detail of existing buildings in the Conservation
area
St Chad’s is a tall Church built with bunter sandstone and

visible
with a distinctive tower.
16

How will a three storey Football stadium look against this

historic building ? We conclude it would be out of keeping
ascetically
b) Existing plot layouts street scene.
48. These will see major changes on the streets around the
Church to facilitate the traffic and spectators generated on
stadium match days and nights.
c) Important views into, within and out of the Conservation

area
This scheme will remove one side of Valley Road a major

vantage point into the conservation area
e) Likely levels of noise, pollution, traffic, parking or

disturbance caused by the development.
These problems have been highlighted during the Inquiry we

invite the Inspector (s ) to make their own judgements on
these issues.
We would like to direct the Inspector (s) to consider Policy

DQ5 page 132 para 11.34 To assess the policy “ New
Development Affecting Conservation areas”. And its likely
impact on St Chad’s Church and the Conservation area
49. Traffic Issues were widely considered by the Inquiry we

say the upheaval faced by residents on match days and
nights will cause disruption for residents. Areas near to the
proposed site include
well established residential estates that don’t benefit from
access and egress from all sides, similar to streets and
roads around Goodison Park. The prospect of up to 4,000
spectators being shepherded up the narrow Kirkby Row b
road en route to Kirkby Station will deter many residents
from routines of accessing roads
17

shopping and visiting Liverpool travelling via the Northern

Line
50. Loss of Playing Pitches
The effect of the plan would see the loss of 2 grassed

football pitches on the site of the development. The Council
have identified 2 sites as replacements. These are,
Charlottes Pagsy which is located on the UPD illustrative
map on the extreme northern fringe of Kirkby abutting the
Melling area of Sefton. It already serves an existing
purpose, and is considerable distance from the lost playing
fields.
The other site is at Copthorne Walk, in the Westvale

Substantial Residential Area [ SRA ]. It current
designation is POS. In planning report App 05/0064 KMBC1
dated 04.03.2005 the Council set out the Public Open Space
Supply for the Westvale SRA-17- it states that Copthorne
POS is not surplus. And is needed to maintain the 800m
walking distance criteria for community access to Public
Open Space in this area of Kirkby.
As the Council failed to provide new pitches and amenities

as required by planning consent Ref : GOME/308/1/2 27
September
2001 after a local inquiry into application ( no APP97/00651)
1-3
December 1997 we feel this is a matter the SoS should take
into account before any weight is given to the qualitative
and quantative merits of Copthorne and Charlotte Pagsy.
In our view, their location and existing use does not provide
alternative provision of a qualitative standard as required
by Policy 0S4 1. ( a) & (d) of the KRUPD.
51. Good and convenient provision of playing fields are

essential in Kirkby given the loss of sporting facilities since
the closure of Kirkby Stadium/ Sports Centre which are set
18

out in INQ KRAG/P /3 Peter Ross proof of evidence para 4.0

.
52. Representation, and Formal Consultation was conducted

and invited by the Council. The findings are set out on
pages 123- 167
of the Inquiry doc CD 5. We invite the Inspector (s) to
consider there findings.
53. The retail element of the scheme is the main driver for a
new football stadium, the scale of the floor space is outside
planning policy for KMBC. We do not believe securing the
future of a football club located outside the borough
boundary is a material consideration to justify departure
from the local development plan having regard to the
provisions of Section 38 (6) of the Planning and Compulsory
Purchase Act 2004.
For all the above reasons and relating to breaches of the

KRUPD and conflict with RSS Policy W5 and consideration of
PPS6
We invite the Inspector ( s ) not to grant planning

permission for Application 08/00001/HYB.
Kirkby Public Inquiry 18 November 2008

Deposited 4 February 2009
19

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TOWN AND COUNTRY PLANNING ACT 1990 – SECTION 77

TOWN AND COUNTRY PLANNING ( GENERAL DEVELOPMENT

Planning Inspectorate Ref : APP/V4305/V/08/1203375

1. The Application was supported within the framework

The proposals, includes a 14,974 square metres

2. Its passage through the planning process in our view

3. In accord with the directions of the Secretary of

In (b.) Planning Policy Statement 6: Planning for town

Planning Inspectorate Ref : APP/V4305/V/08/1203375

4. There appears to be general consensus on all sides

5. The quantitative need forms a basis for this proposal.

6. The KRUDP had a gestation period from 2001 – to

7. One of the Strategic Objectives of the Town Centres

• “To improve the provision of shopping, leisure and

This Inquiry received written evidence and oral

overtrading Huyton Asda” Cllr Fricker challenged the

Planning Inspectorate Ref : APP/V4305/V/08/1203375

in Huyton town centre were 19% against a national

On the 22 January 2009 Cllr Smith’s written statement

• Prescot is located in Zone 2, Huyton in Zone 4 of the

• The hierarchy of centres within Knowsley are set out in

Planning Inspectorate Ref : APP/V4305/V/08/1203375

• It gives no indication that any the three centres would

• As the Government Office for the North West has to

The proposed plan is supported by the Council.

8. However the applicants submissions in Inquiry CD 5.1

9. The position is given further gravitas by the applicant

Everton’s Current Financial Position “ It states that

Planning Inspectorate Ref : APP/V4305/V/08/1203375

stadium the amount of retailing proposed would be

10.This would suggest the huge increase in retail floor

11.For the applicant the Inquiry was provided with a

“This technical form of enabling development is not

12.Throughout the Inquiry the applicant parties used the

13.It is our view the evidence would indicate the

14.What is the Councils policy on Kirkby Town Centre

15.The Inquiry has been told by a number of the

16.Having been a member of Knowsley MBC from its early

Planning Inspectorate Ref : APP/V4305/V/08/1203375

inception until early into the new millennium I hope

17. Asda opened their doors in Kirkby Town Centre in

19. In evidence to the Inquiry KCLD/ INQ/1

20 In 1997 following the expiry of the Asda lease

21. This move was unsuccessful and with the political

Planning Inspectorate Ref : APP/V4305/V/08/1203375

to Councillors having to rely on verbal feedbacks

During the period Aubrey Weiss was receiving the

In May 2001 KMBC called a meeting in Kirkby

23. It says the meeting “would have benefited from a

Planning Inspectorate Ref : APP/V4305/V/08/1203375

24. Michelle Taylor the MD of St Modwen sets this out

25. The decision, given this history and stagnation of the

26. We therefore suggest that the lever of a 30 absence

Planning Inspectorate Ref : APP/V4305/V/08/1203375

27. Turning to the proposed retail development South of

28. Mr William’s in his main proof of Evidence TEV/P/2

29. Interestingly Roger Tym Partners Final report – CD Ref

30 The PCA includes Huyton and Prescot and projects a

31. This in our view will alter the shopping hierarchies in

Planning Inspectorate Ref : APP/V4305/V/08/1203375

32. The overall retail scheme in the applicants submission

34. Planning Policy Statement 6 - Promoting Growth and

Ref: Appendix CAO/A/4 A news article 19 November

Planning Inspectorate Ref : APP/V4305/V/08/1203375