Planning Committee Representations Report

Representations
9.0 REPRESENTATIONS
The Council has carried out an extensive consultation exercise on the planning
application, with a view to raising awareness of the development proposals and
seeking community views. The exercise included a letter drop to all Kirkby
households, seven public drop-in events (in various town centre and neighbourhood
locations) and seven meetings with community / specific interest groups. The latter
included town centre businesses, market traders, the Community Empowerment
Network, the elderly and the young and two housing groups. Approximately 323
people attended the events / meetings.
The responses received are summarised below. The content of individual letters is
reported first, followed by that of ‘circular’ letters (i.e. pre-printed, but individually
signed letters), petitions, the comments of local groups / societies, and finally those
of local businesses / landowners.
Comments from Interested Individuals – Original Submission
370 individually written letters have been received from local residents. There were
61 in support for the application; 344 in objection and 15 were of a mixed opinion.
Specifically, 234 object to a stadium in Kirkby; 25 supported a stadium; 153 object to
a superstore and 38 supported a superstore in Kirkby
Comments on the application have been made on the following grounds:
Grounds for Objection
Economic and Regeneration:
• Gains from additional low paid, part time jobs or other advantages from the
scheme are not worth the disadvantages - 12
• The scheme will have no benefits to the residents of Kirkby - 1
• Jobs will only be part time and will not go to local residents; this will not help
unemployment/regeneration for the long term - 5
• Tesco operates unfair practices, breaks laws, has no morals / I will not
support a greedy Tesco - 7
• Tesco is not interested in regenerating Kirkby Town Centre; it wants a
monopoly - 6
• Local traders will lose businesses, there will also be a consequential loss of
jobs in the existing town centre - 56
• The scheme does not secure regeneration of the town centre, for Kirkby
people - 25
Town Centre and Retail:
• No need for more retail / expansion of town centre - 3
Page 123
Representations
• No need for a large foodstore / or 24 hour trading store - 53

• Overall scale of the development too large / it will not be sustainable - 51
• Existing town will lose vitality/viability as the focus moves South - 4
• No need for the offices/commercial elements proposed as this is already
provided for in the industrial park - 3
• Negative impact on neighbouring areas - 3
• Contrary to National, Regional and UDP Town Centre / Retail policies, fails
the sequential test – 28
• Focus should be on regeneration of the existing town centre - for Kirkby
people - 5
Transport:
• Inadequate infrastructure will lead to traffic congestion - 36

• Traffic congestion associated with use of the retail scheme - 55
• Traffic congestion associated with use of the stadium – 137
• There will be injuries (crushing) while using overloaded public transport - 5
• Rail infrastructure in Kirkby is inadequate for this proposal - 18
• Resident parking permits are unacceptable - 16
• The schemes car parking provision is inadequate - 16
• Access, parking and transport problems (general comment) - 26
• On-street parking problems associated with stadium use - 43
• On-street parking problems In Melling associated with stadium use - 3
• Road accidents/deaths will increase in Kirkby / It will not be safe for children -
20
• Unwanted increase in traffic and consequential adverse effects in Melling - 3
• Inadequate match day transport scheme; this will cause congestion in Kirkby -
19
• Transport infrastructure and match day scheme is inadequate to get fans to
an from the stadium fast and efficiently - 3
• Inadequate transport infrastructure to cater for this development will
discourage use of the retail scheme - 2
• Assessment focused on local roads, congestion in other areas too, Melling,
switch island Maghull - 1
• There is no partnership with Merseytravel and sustainable infrastructure is not
included in the plans e.g. cycle tracks/walk ways - 3
• The increase in traffic will be very dangerous for a cyclist in Kirkby,
inadequate infrastructure for a cyclist – 1
Urban Greenspace, Public Open Space, Sport and Recreation:
• Loss of well-used, accessible and amenity greenspace - 134

• Loss of football pitches and other recreation facilities due to this scheme - 12
• Loss of path ways linked through to St Chad’s church - 1
• Scheme needs to be adapted to address climate change issues - 1
Page 124
Representations
• Leisure facilities for young and old should be included - 1

• Council's should b planning for more greenspace, not removal or development
on them - 7
Environmental Protection and Sustainability:
• Adverse effect on the environment (general comment) - 64

• Increase risk of flooding - 6
• Drainage problems - 1
• Increase Air pollution and carbon emissions - 53
• Increase water pollution - 3
• Noise pollution – retail - 37
• Noise pollution – stadium - 48
• Light pollution – retail - 15
• Light pollution – stadium - 16
• The scheme doesn't promote renewable energy/sustainable development - 2
• Noise & disturbance from retail service traffic too close to housing - 32
• The scheme will increase the carbon footprint in Kirkby - 8
• Development on contaminated land could lead to resident health side effects /
environmental degradation - 12
Residential Amenity:
• Petrol Station is close to housing - 6

• Too much land used for parking i.e. bus and coach parks, retail parks - 15
• Noise problems (general comment) - 2
• Kirkby would be a construction site for many years - 8
• Loss of Privacy, overlooking/over-dominance from the development - 18
Site Layout, Design and Heritage:
• Negative impact on the landscape and townscape of the area - 14

• The scheme threatens the sustainability of the church and it's heritage - 1
• Potential damage to St Chad's Church - 3
• Stadium events will cause unacceptable/unworkable disruption to events held
at St Chad's church - 2
• Stadium should be of a high quality design - 2
• Negative impact on the quality of the Old Hall Lane Conservation area - 4
• Reduced access to St Chad's church will increase 'loss of identity' - 1
• Stadium should be out of town away from residential areas - 20
• Tesco/Retail park should not be in a residential area - 4
• Scheme creates a barrier for residents; no easy access to areas of the town,
there is no connectivity throughout the town by a sustainable means - 1
• The hills and playing fields are not for sale, Kirkby's heritage should not be
bought - 1
Page 125
Representations
• Low rise superstore should have an additional use above the store - 1
Nature Conservation and Ecology:
• Loss of flora and fauna and it's habitat - 36

• Biological reports require sharper focus and clarification - 1
• EIA does not comply with the legislation - 2
• No adequate survey for Bats - 1
• Alignment of Kirkby Brook / overall development will have adverse ecological
effects - 1
• Loss of wildlife habitat; consequently the rodent population will increase - 1
Health:
• Scheme will cause health side effects to residents - 22

• Need more health facilities for casualties from match-day fights - 2
• This scheme is not suited / in the best interests of Kirkby residents - 17
• Will take away Kirkby's lifestyle, its individual community spirit and decrease
quality of life for residents - 29
• Scheme design will increase geographical and social exclusion - 2
• Will cause unacceptable disruptions to residents - 37
• Will cause unacceptable increase in living expenses: insurance, council tax,
food shopping - 20
• Unwanted increase in visitors to Kirkby - 35
• Residents will not use retail facilities due to the crowds and fear of antisocial
behaviour - 5
• Disrupted access for emergency services due to the congestion on roads - 2
• Location of the petrol station will lead to adverse health effects for residents
close by - 1
• Disruption getting to and from work, and consequential flow on effects; child
care, employment, appointments - 1
Crime, Public Order and Personal Safety:
• Inadequate policing for the scheme - 22

• Anti social behaviour problems associated with 24 hour trading stores - 16
• Anti social behaviour problems associated with stadium use - 117
• Litter problems associated with stadium use - 46
• Food/drink uses will encourage more antisocial behaviour - 2
• Public footpath liked to the stadium is a crime risk; anti-social behaviour, easy
access to homes, damage to homes and gardens - 2
• Public footpath linked to the stadium at back of my garden will negatively
impact on the quality of our lives - 1
• Children and elderly will have to be sheltered by crowds and stay inside their
homes on match days - 19
Page 126
Representations
• Need to include ways prevent: prostitution, drugs, crime - 2

• Damage to property and house - 5
• Increased risk of theft or an attack while at work and leaving work - 2
Housing:
• Unacceptable to demolish schools, order CPO on homes; detrimental to

quality of life and children’s education - 41
• Demolition of buildings paid for by tax payer - 8
• Difficulty in selling property or loss of property value; should get compensation
for this - 25
• Removal of a facility or building and no replacement in the scheme - 2
• No need for residential housing development in Kirkby - 2
• Location of the replacement housing must be suitable for the residents - 2
• A 'bund' is not sufficient to mitigate the noise effects from this proposal - 1
• Housing is of poor quality and not up to the required standards - 1
• There is only replacement housing - Kirkby needs more - 1
• Demolition of Care Home will result in: unemployment and re-housing stress
to residents - 1
• Housing in Kirkby are not suited to block noise generated from this scheme
i.e. no double glazing on windows - 1
• This scheme will discourage people to live in Kirkby - 1
Implementation and Phasing:
• Phasing needs review and to be planned better to minimise adverse effects

on community - 1
• Concern that all phases of the scheme would not be completed - 10
• Town centre phases should go first - 1
Stadium:
• Would hold more people than live in Kirkby, the influx of people is too great -
15
• I require peace and quiet to work from home, scheme will take this away - 1
• Unwanted possible other events e.g. concerts and other matches all times of
day and night - 1
• Shopping and moving around town would be impossible on match days - 8
• Everton has not shown any interests in Kirkby and the community – 2
Other:
• Not enough consultation on this has been carried out i.e. volume and areas
canvassed - 1
• No grounds specified - 7
Page 127
Representations
• Tesco site should be used to re-build a school learning centre or sports

facilities - 1
• Consultation exercises fail to meet regulations - 1
• Scheme doesn't indicate partnership with local community groups – 2
• Gifting land to Everton, land should be sold - 5
• There is no need to re-build leisure centre - 1
Grounds for Support
• Scheme will enable regeneration - 20

• Will provide employment / boost current employment - 25
• Area is declining, no first class clothes shops - 4
• Fantastic opportunity / Enable Kirkby to move forwards - 18
• Only chance Kirkby has - 2
• Improve quality of life / make me proud to live in Kirkby - 19
• Bring investment to Kirkby - 2
• Put Kirkby on the map / enhance region / make it a destination not a ghost
town - 15
• Kirkby is in need of a foodstore, shopping complex / retail park - 24
Transport:
• More traffic once a fortnight will be fine - 3
• The green site does not get use by residents - 1

• Will provide needed recreational and leisure uses - 3
• Vast greenspace has been taken away by housing associations
developments, no one complained then, they have double standards - 3
• Kirkby needs a cinema / theatre for young actors - 1
• The school was closing regardless of this proposal - 1
• Need some restaurants, nice bars - 1
• Hotel would encourage people to visit - 1
Environment and Sustainability:
• Soni will give us the worst pollution more than anything in this scheme - 4
Page 128
Representations
Other:
• Areas of concern in the application can always be mitigated - 6

• Objectors are a noisy minority / Most residents are in favour - 3
• KRAG widely distributed flyers do not speak for the majority - 2
• Disagree with pre-filled in comment form objections - 1
• Asda - broken promises no guarantees - 1
• Everton deserve a better stadium / proud for Kirkby to be the home of Everton
-4
• Residents around Goodison don’t want Everton to leave, so it can not be that
bad - 1
• People are just set in their ways and afraid of change - 1
• This is a good proposal - 2
• Support for whole scheme no reasons specified - 7
Statements / Suggestions
• Will leave / think of leaving Kirkby if the stadium comes - 5

• KMBC resource have been withheld from people not in support of application -
1
• Regeneration not always about retail / jobs there can be degeneration
cause/effect on other areas - 3
• Political representations of Kirkby and Knowsley have been prejudiced - 1
• Council should be looking at building future for Kirkby not retail developments
-1
• Should use vacant site for foodstore in town centre - 1
• Tesco should be in existing town centre - 3
• Kirkby can not provide for everyday amenities, have to go elsewhere - 1
• Redevelopment should come from years of Council Tax - 1
• This is not Kirkby’s only option, do not sell us down the river - 5
• Service area by new road between stadium/coach park cut disturbance - 5

• A smaller scheme would be adequate for Kirkby - without a stadium - 1
• Town centre does need development - 7
• Access to retail park should be off valley road - 1
Transport:
• More work needed avoid traffic problems present at other stadia - 3

• Scheme will cause decreased access for emergency services - 1
• Size of stadium should be reduced - 1
Page 129
Representations
• Alternative sites for a stadium better served by infrastructure - 3

• What else will the stadium be used for, what are the restrictions - 1
• Scheme doesn't provide sustainable transport infrastructure - 1
• Will provide needed infrastructure improvements - 1
Urban greenspace, Public Open Space, Sport and Recreation:
• Land is being given away - sale of any land should go to the

community/subsidise council tax - 2
• Without stadium the greenspace could be retained - 1
• Leisure facilities for young and old should be included - 2
Site Design and Heritage:
• Scheme is not of a high quality design - 1

• Could bring significant advantages if issues addressed - 1
• Petrol Filling Station should be relocated to Cherryfield Drive - 5
Housing:
• Affordable housing should be included in the scheme - 1

• Housing of poor quality and design - 1
Implementation and Phasing:
• Scheme is being rushed, don't make rash decisions - 1

• Development in the North should be given to someone else - start work
sooner than proposed phases - 1
Stadium:
• The community don't want Everton to leave so it can't be bad to have them
there - 1
• Objectors have double standards - 1
• Everton should stay in Liverpool - 3
Other:
• Council should not decide, govt should 'call it in’ - 5

• Should be a referendum on the proposal - 3
• Concern that the scheme is a "done deal" - 5
• Prefer the 'Asda' scheme - 9
• Why isn’t the ‘Asda’ scheme being given the same publicity - 1
• Schemes supporting reports are flawed/inadequate - 3
• Tesco representatives state they are being paid by the council - 1
Page 130
Representations
• Object to community created pre-filled in objection Council comment forms,

they are misleading - 3
• The town centre does need regeneration - 1
• Goodison be improved or extended - 1
• The real issues lie with what football club objectors support - 3
• I will have my vote in May - 1
• Object to Tesco outside a hospital drumming up support - 1
• Insufficient concern for residents by the council - 5
• Council/government do not care/listen to its people – 5
The proportion of individual representations received indicating objection to the

scheme as against support is shown in the following pie chart.
4%
15 %
S u pp or t
Ob je ct
Mix e d Comme nt
81 %
The proportion of individual representations received against major elements of the

scheme is shown in the pie chart below.
Object to Stadium
8% Object to Superstore
6%
Support Stadium
Support Superstore
52%
34%
Page 131
0
50
100
150
200
250
300
350
400
450
0
20
40
60
80
100
120
Economic,
Economic, Regeneration
Regeneration Town centre,
Retail
Transport
Town centre,
Retail Greenspace,
Open Space,
Environmental
Protection,
Transport
Residential
Amenity
Greenspace,
Site Design,
Page 132
Layout,
Representations
Open Space,
Nature
Recreation Conservation,
grounds of support are shown in the bar chart below.

Site Design, Health
grounds of objection are shown in the bar chart below.
Layout,
Crime, Public
Heritage order, Personal
Environmental Housing
Protection,
Sustainability Implementation,
phasing
Stadium
Other
Other
The number of individual representations making comments relating to the various
Representations
1753 ‘circular’ letters have been received from local residents. Objections to the
application are made on the following grounds:
• the development would lead to a massive increase in traffic, which would

result in congestion, increased on-street parking, reduction in air quality,
injuries and possible death of pedestrians, and disruption and loss of amenity
for local residents;
• loss of a greenfield site used by local residents for recreation, and irrevocable
harm to wildlife and vegetation;
• contrary to PPS6 and UDP as the application fails the sequential test;
• a consequence of the development is the loss of one of Kirkby’s three
secondary schools, resulting in larger class sizes and a diminution in the
quality of education;
• no additional rail infrastructure provision is to be made for the 30,000 football
fans expected to arrive by train;
• football fans walking through residential areas will cause anti-social behaviour
and detrimental effects on local residents;
• no timescale or guarantee of regeneration for the town centre, resulting in its
further decline;
• regeneration and redevelopment of the town centre as per the UDP should be
a priority. The application fails to do this and will lead to wholesale closures of
local shops and businesses;
• inadequate provision has been made for the hundreds of lorries needed to
service the Tesco store, with a detrimental effect of having large lorries on
local roads, noise and air pollution;
• the assumptions that 1,000 football fans will cycle to the stadium is ludicrous,
and thus the traffic figures in the application are wildly inaccurate;
• in view of the far-reaching effects of the proposal, the Council should ask
GONW to ‘call-in’ the application and a public inquiry be held.
• the application is a departure form the UDP which allocates the greater part of
the site as urban greenspace, and it further conflicts with Kirkby Town Centre
regeneration policy;
• the application conflicts with national and regional planning policies relating to
retail development. The retail element is inappropriate for the role and function
of Kirkby town centre, and would result in it becoming a competing (rather
than a complementary centre) to established centres including Liverpool, St
Helens, Southport and Ormskirk;
• the application fails the PPS6 sequential test. Tesco own a Kirkby Town
Centre site and fail to justify why a greenfield site is being developed in
preference;
• the development would lead to a massive increase in traffic and has
inadequate parking, resulting in local road congestion, increased on-street
parking, nuisance and loss of amenity to local residents;
Page 133
Representations
• the application only details a stadium and Tesco store and fails to provide a
mechanism for wider improvement of Kirkby Town Centre and local
community / social infrastructure;
• the EIA does not adequately assess the environmental effects of the
development and thus does not comply with legal requirements.
• In view of the Council’s land ownership interest in the site, the Secretary of
State is urged to call-in the application and a Public Inquiry held.
264 ‘circular’ letters have been received from local residents. The Letter asks the
respondent to indicate whether they want a minimum 55,401 (sic) seat football
stadium to be built on greenspace to the south of Cherryfield Drive, Kirkby. The
respondents have indicated as follows:
• 410 are strongly opposed;

• 34 are against;
• 0 are in favour;
• 2 are strongly in favour;
• 6 are unsure.
200 e-mails have been received from local residents stating that they do not support
the move of EFC to Kirkby.
A petition of objection to the application, signed by 77 people, cites the retail park
and stadium will destroy the town centre and have a detrimental effect on local and
family run businesses in Kirkby and surrounding areas. The out of town
development will harm the local environment, increase traffic on our roads, and
destroy a local green space and wildlife habitat. The council is urged to reject the
application.
A petition of objection to the application, signed by 124 people, cites the detrimental
effect on local and family run businesses in Kirkby and surrounding areas and will
ultimately destroy Kirkby town centre. It will also destroy local wildlife, cause
environmental damage, increase traffic and pollution, destroy greenspace and is
contrary to he UDP. The application should be refused planning permission and, if
not, the Secretary of State should call it in.
2,103 pre-printed postcards have been received stating support for the move of
Everton Football Club to Kirkby.
92 adapted pre-printed and similar postcards have been received stating opposition
to the move of Everton Football Club to Kirkby.
A petition of support for the application, signed by 739, cites support for the
application and regeneration of Kirkby.
Page 134
Representations
The number of persons signing petitions / circular letters making comments relating
to various grounds of objection are shown in the bar chart below.
3000
2500
2000
1500
1000
500
0
n
n
e
ou
e
n
t
l
io
ai
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ov
io
ac
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to various grounds of support are shown in the bar chart below.
2500
2000
1500
1000
500
0
Stadium / EFC move Regeneration
Page 135
Representations
The proportion of all first round consultation representations received indicating

objection to the scheme as against support is shown in the following pie chart.
Object
42%
Support
58%
Comments from Interested Individuals – First Revised Submission
It should be noted that the letter inviting comments on the revised application
advised that all comments on the original application would be reported to the
Planning Committee; there only being a need to make additional comments should a
respondent’s view on the revised scheme be different from that on the original
submission. The responses received are summarised below. The content of
individual letters is reported first, followed by that of ‘circular’ letters (i.e. pre-printed,
but individually signed, letters), petitions, the comments of local groups / societies,
and finally those of local businesses / landowners.
43 individually written representations have been received from local residents.

There were 2 in support for the application; 40 in objection and 1 were of a mixed
opinion. Specifically, 36 object to a stadium; 1 supported a stadium; 17 object to a
superstore and 1 supported a superstore.
Comments on the application have been made on the following grounds:
Grounds of objection
• Gain from additional low paid jobs/other benefits are not worth other
disadvantages - 3
• Operates unfair practices breaks laws / will not support a greedy Tesco - 3
• Tesco not interested in regeneration - 1
• Concern about local traders losing businesses - 2
Page 136
Representations
Town centre and Retail:
• No need for such a large foodstore, 24 hour trading store - 2

• Existing town will lose vitality/viability as focus moves South - 4
• Development should follow the UDP policies/allocation - 1
• Contrary to National, regional and UDP Town Centre/Retail policies - 3
• Need a supermarket but not a 24 hours store - 1
Transport:
• Inadequate infrastructure lead to traffic congestion – general - 15

• Traffic congestion associated with retail development - 10
• Traffic congestion associated with stadium development - 19
• Car parking provision inadequate (general comment) - 5
• Road accidents/deaths will increase in Kirkby, the road will be unsafe for
children - 2
• Infrastructure improvements are minor - there will be increased traffic all over
Kirkby - 2
• Transport scheme is incomplete there are outstanding reports/research to be
completed - 1
• Park and ride/walk sites will increase vehicle and foot traffic along County and
Valley road, Field lane - will negatively effect quality of life - 2
• Figures used to support park & walk/ride sites are theory not realistic of
problems with football crowds - 1
• Evidence that football fans prefer to park in residential areas not park and
walk sites - 1
• Town centre congestion from football fans / visitors to Kirkby on match days -
1
• Should not be access/exit off Bewley Drive for lorries, football fans, retail
scheme; the noise will be detrimental to residents close by - 1
• Loss of well-used and amenity greenspace - 15

• Kirkby Leisure centre is not enhanced by these plans - 1
• More trees / greenspace needed in scheme – 1
• Adverse effect on environment (general comment) - 5

• Air pollution - 11
• Water pollution - 1
Page 137
Representations

• Light pollution – retail - 2
• Light pollution – stadium - 4
• Noise & disturbance from 24 hour retail service traffic near to housing - 9
• Scheme will increase the carbon footprint in Kirkby - 1
• Too much land used for parking - car, bus, retail parks - 2
• Impact on landscape and townscape of area - 3

• Potential damage to St Chad’s Church - 1
• Insufficient consideration on effects on St Chad’s, will cause
unacceptable/unworkable disruption - 2
• Negative impact on quality of Old Hall Lane Conservation area/ less
sustainable - 2
• Disruption to events at church will threaten family life and commitment in
relationships - 2
• Stadium be out of town away from residential areas - 1
• Petrol station should be included in the scheme -1
• Petrol station will increase congestion and danger to local residents - 1
• CABE comments negative on the overall design said it should be refused - 1
Nature Conservation and Ecology :
• Loss of flora, fauna and their habitats - 3
Health:
• Will cause health side effects to residents - 4

• Would not be in the interests of Kirkby residents - 2
• Decrease quality of life / take away Kirkby's lifestyle and individual community
spirit - 2
• Unacceptable disruption to residents - 3
• Unacceptable increase in living expenses due to the development - 1
• Elderly people who require care from home might not receive care due to
traffic congestion - 1
• Inadequate policing for the scheme - 2
Page 138
Representations
• Anti social behaviour problems associated with 24 hour stores - 2

• Anti social behaviour problems associated with stadium - 14
• Children / elderly will have to be sheltered by football crowds - 2
• Application does not address how to keep anti social behaviour brought by the
stadium out of Kirkby - 1
Housing:
• Demolition of buildings paid for by tax payer / no need to replace them - 1

• Removal of civic profile of Kirkby should only be authorised by secretary of
state - 1
• Any new debt from this development must not be paid for by the tax payer - 1
• Difficulty in selling / loss of property value - 1
• Council housing opposite private housing is unfair and will effects house
prices - 2
Stadium:
• Would hold more people than live in Kirkby - Too many people for Kirkby - 2
Other:
• Oppose amendments to the application - 1

• Application has insufficient consideration of the community, voluntary sector
organisations/activities - which are important in regeneration - 1
• Revisions only minor - still object to proposal – 1
• Gifting land to Everton - 1
Grounds for support
• Support for whole scheme no reasons specified - 2

• Issues with the scheme can always be worked out - 1
• Improve quality of life – 1
Statements / Suggestions
• Will leave Kirkby if the stadium comes - 1

• Regeneration not always about retail/jobs can be degeneration cause/effect
on other areas - 1
• Focus should be on regeneration of existing town centre - for Kirkby people -
2
Page 139
Representations
• Should use vacant site for foodstore in town centre - 2

Transport:
• Scheme will cause decreased access for emergency services - 1

• Alternative sites for a stadium better served by infrastructure - 1
• Rail infrastructure upgraded to provide better access to other areas in the
country - 1
• Urban Greenspace, Public Open Space, Sport and Recreation
• Land is being given away - sale of land should go to the community -
subsidise council tax - 1
Stadium:
• Everton should stay in Liverpool / Goodison be improved/extended - 1
Other:
• Council should not decide, govt should 'call it in' - 2

• Should be a referendum on the proposal - 1
• Prefer the 'Asda' scheme - 1
• Should be compensation for the people who want to move - 1
• I will have my vote in May - 1
• Council does not promote Kirkby road signs even say Knowsley - 1

2% 5%
Comment mainly in
Support
Comment mainly in
Objection
Comment of Mixed
opinion
93%
Page 140
Representations

2%
31%
Object to Stadium
Supports Stadium
Objects to Superstore
Supports Superstore
65%
2%

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70
60
50
40
30
20
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Page 141
Representations

1.2
0.8
0.6
0.4
0.2
0
Put Kirkby on the Improve quality of Support for whole Scheme will
map life scheme no enable
reasons specified regeneration
• the application is a departure from the UDP which allocates the greater part of
the site as urban greenspace, and it further conflicts with Kirkby Town Centre
regeneration policy;
• the application conflicts with national and regional planning policies relating to
retail development. The retail element is inappropriate for the role and function
of Kirkby town centre, and would result in it becoming a competing (rather
than a complementary centre) to established centres including Liverpool, St
Helens, Southport and Ormskirk;
• the application fails the PPS6 sequential test. Tesco own a Kirkby Town
Centre site and fail to justify why a greenfield site is being developed in
preference;
• the development would lead to a massive increase in traffic and has
inadequate parking, resulting in local road congestion, increased on-street
parking, nuisance and loss of amenity to local residents;
• the application only details a stadium and Tesco store and fails to provide a
mechanism for wider improvement of Kirkby Town Centre and local
community / social infrastructure;
• the EIA does not adequately assess the environmental effects of the
development and thus does not comply with legal requirements.
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Representations
• In view of the Council’s land ownership interest in the site, the Secretary of
State is urged to call-in the application and a Public Inquiry held.

further decline;
• introduction of Park and Walk sites around Kirkby for stadium attendees;
• movements of supporters to and from the stadium;
• dispersal times for pedestrian supporters and cars from Park and Walk sites;
• increase in traffic congestion, environmental damage, air pollution, noise
pollution, blighting the area, and compulsory purchase of homes;
• increase in traffic;
• destruction of trees and wildlife, loss of greenspace, loss of a recreational
amenity;
• development not included in the UDP;
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Representations
• loss of a school, anti social behaviour, difficulty of travelling on match days,

lack of appropriate transport for fans, fans travelling through residential areas;
• no guarantee of regeneration of existing town centre, degeneration of existing
• and support for:
• deletion of the petrol station from the scheme.
• In view of the far-reaching effects of the proposal, the Council should ask
I wish to object to the Kirkby Town Centre Draft IPS for the following reasons:
• The proposed IPS is contrary to the adopted Unitary Development Plan (UDP)
and Regional Spatial Strategy Policy (RSS)
• The unplanned movement of Kirkby up the retail hierarchy is contrary to the
adopted UDP and RSS policy
• The inclusion of a major leisure use (football stadium) is contrary to the
adopted UDP and RSS policy
• The town centre and country planning acts (as amended) 1990 require
development proposals to be determined in accordance with the development
plan. This proposal is not and there are no material considerations (including
the IPS) which would overcome this departure.
• The IPS has no statutory weight.
Such a proposal would
• Have an adverse effect on the life of local residents

• Increased pollution
• Put an increased demand on road networks not built to sustain the traffic likely
to be generated by fans visiting a 55,000 seater stadium
• Destroy the landscape on Valley Road. The irreversible loss of green space
is unacceptable. The proposed site was recognised as green space by virtue
of a Planning Inspectors decision in 1998 and remained green open space
through the formation of the UDP and up the plans adoption in 2006.
• The council have failed to allow an even handed approach on land issues in
Kirkby.
• Other areas of the Borough have seen the protection and enhancement of
green open spaces located within residential areas.
• Bring the threat of anti-social behaviour characteristic of football crowed,
Such incidents are well publicised and require high level planning and
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Representations
deployment of Police resources which leads to disruption and inconvenience

of the local community
• To locate a stadium in the middle of a residential area is wholly inappropriate
• It is unacceptable to demolish perfectly sound and modern homes for
commercial purpose. The compulsory purchase of dwellings houses is a
breach of the Human Rights Act 1998, Article 8 – “Right to respect for private
and family life” for those forcibly effected by such action.
A petition of objection to the application, signed by 104 people, cites the detrimental
effect on local and family run businesses in Kirkby and surrounding areas and will
ultimately destroy Kirkby town centre. It will also destroy local wildlife, cause
environmental damage, increase traffic and pollution, destroy greenspace and is
contrary to he UDP. The application should be refused planning permission and, if
not, the Secretary of State should call it in.
27 pre-printed postcards have been received stating support for the move of Everton
Football Club to Kirkby.
A petition of support for the application, signed by 186 people, cites support for the
regeneration of Kirkby town centre, including up to 50 new shops, a new Tesco
store, a new home for EFC and the creation of more than 2,000 jobs for local people.
to various grounds of objection are shown in the bar chart below.
450
400
350
300
250
200
150
100
50
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Page 145
Representations
to various grounds of support are shown in the bar chart below.
200
180
160
140
120
100
80
60
40
20
0
General Regeneration Retail Jobs
The proportion of all second round representations received indicating objection to

the scheme as against support is shown in the following pie chart.
33%
Object Support
67%
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Representations
Comments from Interested Individuals – Second Revised Submission
On receipt of the second revision to the application the Council carried out a further
consultation exercise, with a view to raising awareness of the revised development
proposals and seeking community views. The exercise included a letter drop to all
20,000 plus Kirkby households (and all other persons who made comments on the
original submission).
It should be noted that the letter inviting comments on the revised application
advised that all comments on the original application would be reported to the
Planning Committee; there only being a need to make additional comments should a
respondent’s view on the revised scheme be different from that on the original
submission. The responses received are summarised below. The content of
individual letters is reported first, followed by that of ‘circular’ letters (i.e. pre-printed,
but individually signed, letters), petitions, the comments of local groups / societies,
and finally those of local businesses / landowners.
42 individually written letters have been received from local residents. There were 5
in support for the application; 33 in objection and 4 were of a mixed opinion.
Specifically, 30 object to a stadium; 4 supported a stadium; 28 object to a superstore
and 3 supported a superstore. Any further comments received, after the date of
writing this report, will be reported to the Committee at its meeting.
Grounds of objection
• Gain from additional low paid jobs / other advantages are not worth other
disadvantages - 1
• Tesco is not interested in regenerating Kirkby town centre - it wants a
monopoly - 1
• Concerns about local traders losing businesses and consequential loss of jobs
-4
• No need for a large foodstore / or a 24 hour trading store - 1

• Existing town will lose vitality/viability as the focus moves South - 1
• Negative impact on neighbouring areas - 5
• Contrary to National, Regional and UDP Town Centre / Retail policies, fails
the sequential test - 1
• The sneaky removal of floorspace is only temporary, to try to get other
councils to withdraw their objections - 5
• Tesco's amendment letter admits floorspace may go back in – 2
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Representations
Transport:
• Traffic congestion associated with use of the retail scheme - 6

• Traffic congestion associated with use of the stadium - 8
• Rail infrastructure in Kirkby is inadequate for this proposal - 1
• Road accidents/deaths will increase in Kirkby / it will not be safe for children -
1
• Inadequate match day transport scheme; this will cause congestion in Kirkby -
1
• Transport infrastructure and match day scheme inadequate to get fans to and
from stadium efficiently - 7
• Park and ride system will not work, owners will not give permission – 1
• Loss of well-used accessible and amenity greenspace - 5
• Adverse effect on the environment (general comment) - 3

• Increased air pollution and carbon emissions - 2
• Noise & disturbance from retail service traffic too close to housing - 1
• Negative impact on the Brook – 3
• Too much land used for parking i.e. bus and coach parks, retail car parks
• Loss of privacy, overlooking/over-dominance from the development – 1
• Negative impact on landscape and townscape of area - 2

• Tesco/Retail park not in a residential area - 1
• Stadium be out of town away from residential areas - 2
Nature Conservation and Ecology:
• Loss of flora and fauna habitat - 3
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Representations
Health:
• This scheme is not suited to / in the best interests of Kirkby residents - 1

• Take away Kirkby's lifestyle, it's individual community spirit and decrease
quality of life for residents - 1
• scheme will increase geographical and social exclusion - 3
• Will cause unacceptable disruption to residents - 1
• Anti social behaviour problems associated with 24 hour trading stores - 5

• Anti social behaviour problems associated with stadium use - 7
Housing:
• Unacceptable to demolish schools, order CPO's on homes; detrimental to

quality of life and children’s education - 1
• A 'bund' is not sufficient to mitigate noise effects from this proposal - 1
Stadium:
• I will not re-new my season ticket – 7

Other:
• Gifting land to Everton is wrong, the land should be sold if going to be

developed on - 2
Grounds for support
• Area declining, no first class clothes shops - 2

• Kirkby is in need of a shopping complex / retail park - 1
• Enable Kirkby to move forwards - 3
• Will provide employment - 2
• Needed recreational and leisure uses - 1
• Need a cinema - 1
• Objectors are a noisy minority / most residents are in favour - 1
• Put Kirkby on the map / Enhance Region - 1
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Representations

10% 12%
Comment mainly in
Support
Comment mainly in
Objection
Comment of Mixed
opinion
78%

5%
Object to Stadium
46% Supports Stadium
43% Objects to Superstore
Supports Superstore
6%
Page 150
0
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Page 151
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Page 152
Representations
further decline;
• introduction of Park and Walk sites around Kirkby for stadium attendees;
• movements of supporters to and from the stadium;
• dispersal times for pedestrian supporters and cars from Park and Walk sites;
• increase in traffic congestion, environmental damage, air pollution, noise
pollution, blighting the area, and compulsory purchase of homes;
• increase in traffic;
• destruction of trees and wildlife, loss of greenspace, loss of a recreational
amenity;
• development not included in the UDP;
• loss of a school, anti social behaviour, difficulty of travelling on match days,
lack of appropriate transport for fans, fans travelling through residential areas;
• no guarantee of regeneration of existing town centre, degeneration of existing
• and support for:
• deletion of the petrol station from the scheme.
• In view of the far-reaching effects of the proposal, the Council should ask
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Representations
370 pre printed postcards have been received stating support for the project.
The proportion of all third round representations received indicating objection to the
8%
Object
Support
92%
Comments from Local Groups / Societies – Original Submission
A summary of responses received from local groups / societies is provided below.
Brook Residents Action Group:
Holding response received stating that objections to be made around the topics of
traffic, pollution, parking, environment, anti-social behaviour, degeneration of existing
town centre, quality of life, non-compliance with the UDP and RSS.
Burscough Parish Council:
Object on the grounds of poor transport links into West Lancashire.
Melling Parish Council:
Object on the grounds of:
Impact of parking of supporters’ vehicles in residential roads throughout Melling;

Impact of increased through traffic particularly in Waddicar Lane and Prescot Road.
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Representations
Kirkby Residents’ Action Group:
Object on the following grounds:
• traffic – major increase in traffic, including large wagons; increased congestion

and on-street parking; number of parking spaces do not match the number
required on match days; TA assumes large number so fans will cycle to the
stadium, calling into question its integrity; loss of amenity for local residents;
• pollution / health and safety – poor air quality from increased traffic and
increased risk of traffic accidents;
• loss of green space – site is used by local residents for recreation;
development will cause loss of wildlife and vegetation and impact on the
health and well-being of local residents;
• regeneration – regeneration of town centre does not feature, being only in
outline and at phase 4 there is no guarantee it will ever happen; trebling of
existing centre’s floorspace is disproportionate; loss of trade for existing shops
that they will be unable to sustain;
• quality of life – pollution. Loss of green space, increased anti-social behaviour,
traffic congestion, parking problems and degeneration of existing shops and
businesses;
• UDP – does not confirm to UDP or RSS. Development is totally inappropriate
for Kirkby. Unacceptable to demolish homes for a scheme that people are
opposed to;
• consultation – that undertaken by Tesco has been inadequate;
• summary – the lack of compliance with policy should result in a refusal or at
least it being referred for independent review.
Old Hall Estate Residents’ Action Group:
• traffic – major increase in traffic, including large wagons; increased congestion

and on-street parking; number of parking spaces do not match the number
required on match days; TA assumes large number so fans will cycle to the
stadium, calling into question its integrity; loss of amenity for local residents;
• pollution / health and safety – poor air quality from increased traffic and
increased risk of traffic accidents;
• loss of green space – site is used by local residents for recreation;
development will cause loss of wildlife and vegetation and impact on the
health and well-being of local residents;
• regeneration – regeneration of town centre does not feature, being only in
outline and at phase 4 there is no guarantee it will ever happen; trebling of
existing centre’s floorspace is disproportionate; loss of trade for existing shops
that they will be unable to sustain;
• quality of life – pollution. Loss of green space, increased anti-social behaviour,
traffic congestion, parking problems and degeneration of existing shops and
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Representations
businesses;
• UDP – does not confirm to UDP or RSS. Development is totally inappropriate
for Kirkby. Unacceptable to demolish homes for a scheme that people are
opposed to;
• consultation – that undertaken by Tesco has been inadequate;
• summary – the lack of compliance with policy should result in a refusal or at
least it being referred for independent review.
Comments from Local Groups / Societies – First Revised Submission:

Kirkby Residents’ Action Group:
Reiterate their previous objections.
Old Hall Estate Residents’ Action Group:
Reiterate their previous objections.
CPRE Lancashire Branch:
• Ecological mitigation timetable for the brook needs adjusting. The bat survey
seems to have been carried out at a late date in the year. It is suggested that
such as an oak tree is planted. It is suspected that the interest from retailers is
in visitors to the stadium and not the people of Knowsley. Concerns about the
increased traffic levels and implications for safety. Question what measures
there will be top prevent construction vehicles using whatever routes they
wish. Questions whether there is any evidence of a stadium helping to
transform a town centre. Point to conflicting statements about whether
stadium spectators will be encouraged to remain in the area after the event or
will leave promptly. The proposal involves the loss of the area’s largest
accessible greenspace.
Comments from Local Groups / Societies – Second Revised Submission
Any comments received will be reported to the Committee at its meeting.
Comments from Business Interests – Original Submission
A summary of responses received from business interests is provided below.
31 ‘circular’ letters have been received from Kirkby Market stallholders. Objections to
the application are made on the following grounds:
• conflict with local, regional and national planning policy on retail development;
• the development is ‘out of town’ and not a regeneration of the current town
centre;
• the “largest Tesco in England” will destroy local businesses, many of which
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Representations
are independent and family run;

• Tesco’s own figures (which, elsewhere, have been downplayed) show that
£25m worth of sales would be taken out of the existing town centre, including
27% of the centre’s existing convenience goods spend and 30% of the
comparison spend. Kirkby town centre could not sustain this loss;
• the development would compete with rather than be complementary to
established regional and sub-regional centres, including Liverpool, St Helens
and Ormskirk;
• the ‘out of town’ development would be three times Kirkby’s existing retail
provision;
• the majority of the new retail development would be on greenfield land;
• anti social behaviour, noise disturbance and transport congestion on match
days with an increased risk of violence towards market traders / workers;
• parking for shoppers will be taken by match-goers;
• the Council should ask GONW to call-in the application and a public inquiry
held.
33 ‘circular’ letters have been received from local businesses / employees of local
businesses. Objections to the application are made on the following grounds:
• the application conflicts with council, regional and national planning polices on
retail development;
• the largest Tesco in England will destroy local businesses;
• the majority (three times that in the existing town centre) of the development
will be on green fields to the south of Cherryfield Drive;
• Tesco’s figures show that the development will take 27% of grocery trade and
30% of non-grocery trade from the existing town centre, amounting to a total
sales loss of £25m. Kirkby Town Centre cannot sustain this loss;
• In view of the far-reaching effects of the development and the policy issues,
the Secretary of State is urged to call-in the application and a Public Inquiry
held.
Beauty Bargains:
A shop in St Chad’s Parade object on the following grounds:
• the retail development will take trade away from the town centre. Evidence of
this is available elsewhere (e.g. Prescot);
• account should be taken that a town centre is more than just a shopping area;
• there is ample space for new retail development within the existing town
centre;
• loss of greenspace;
• conflict with UDP and PPS6;
• increased traffic, congestion, environmental damage, air pollution, noise
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Representations
pollution;
• blighting of the area and compulsory purchase of homes and businesses;
• Tesco jobs will be part time and thus employment numbers claimed should be
divided by three;
• plans for development beyond the town centre should only be considered
once the town centre has been regenerated. Regeneration of the town centre
is a stated aim of the UDP;
• a stadium would result in anti-social behaviour, noise pollution and difficulty in
travelling on match days, with detrimental effects on local residents and
shoppers. Residents and workers will be exposed to a higher risk of attack
and theft;
• inadequate parking provision has been made for match-goers and thus
parking for shoppers will be taken.
• In view of the far-reaching effects of the development, the Secretary of State

is urged to call-in the application and a Public Inquiry held.
Development Securities plc:
• Development Securities plc, a major landowner in Kirby town centre, has

submitted a holding objection. It has significant concern over the nature,
content, detail, scale and implementability of the proposals and objects on the
following points.
Conflict with Regional and Local Planning Policy:
• The UDP supports development within the town centre Area Action Plan only.
It does not seek development of a regional leisure facility on greenfield land to
the south of Cherryfield Drive and a doubling of retail floorspace outside of the
town centre.
• The IPS seeks to introduce a new strategy for the town centre, but has no
statutory weight, is flawed and subject to significant valid objection.
• Whatever the final RSS retail hierarchy may be, it is certain not to endorse a
strategic alteration to the role and function of Kirkby town centre as proposed
by the current application.
• The application should be refused as contrary to the core policies of the UDP
and RSS.
• Lack of Robust Implementable Regeneration Strategy for Kirkby Town Centre
• The clear distinction between the detailed and outline elements of the
application signify that development aspirations for the existing town centre
are given limited or no weight. The stated community and town centre
‘regeneration benefits’ are not detailed and are not to be carried out by the
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Representations
applicant, with no financial mechanism to implement these proposals.
• The application should be refused as the mitigation required to offset the

impact of the detailed elements is unacceptable, there being no delivery
package and cannot be regarded as integral to the proposal.
Conflict with PPS6:
• The location, layout and orientation of the Tesco store and a substantial
proportion of the comparison goods floorspace are such that it would act as
an ‘out of centre’ destination, with little incentive for linked shopping and other
trips with Kirkby’s established shopping centre.
• The ‘out of centre’ proposals are three times the size of Kirkby’s existing retail
floorspace and would make Kirkby the same size as St Helens and close to
the size of Warrington and Wigan (and half the size of Liverpool). Such an
adjustment of the retail hierarchy is inappropriate through the planning
application process and contrary to PPS6. This scale of development should
be located within or on the edge of a regional or sub-regional town centre, not
a township such as Kirkby.
• There would be an unacceptable impact on Kirkby town centre, with £7.5m or

27% of existing convenience spend and £15m or 30% of comparison goods
spend being lost from the town centre to the new development. The stadium
would compound the impact as it is acknowledged by the applicant’s traffic
assessment that shoppers will not drive to the retail facilities on match days.
• DPP’s sequential assessment to site selection is flawed, as it has not

separated the retail and stadium elements, contrary to PPS6. Comparison
shop units could be accommodated within the existing town centre on
available sites.
Flawed Transport Assessment:
• The Transport Assessment is regarded as unsound and wildly optimistic. The

55% of stadium spectators expected to arrive by bus or train has no regard to
the stadium’s location or implementable facilities. A further indication of
absurd assumptions is the anticipated 1,045 spectators that will cycle to the
stadium on match days.
• It is suggested that 5,000 parking spaces would be required to accommodate

match day demand, whereas only 1,050 are proposed. This indicates a clear
discrepancy between supply and demand.
• Some of the assumptions made are on the basis of 10-year old data from
Goodison Park and, thus, are not robust.
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Representations
Failure to Consult the Public:
• The Statement of Community Involvement submitted with the application does

not comply with national guidance. The actions detailed relate primarily to
meetings with the local Housing Association and not the general public. The
IPS consultation referred to was a Council event and not part of the Tesco
pre-application process. The only public event was held in mid-November
2007 after the Statement was written.
• It is stated that Development Securities, as principal private landowner in

Kirkby, has not been consulted on the content of the planning application
despite its interests falling within the application boundary.
Lack of Integral Master Planning and Design:
• There are a number of functional and qualitative shortcomings in the

masterplan and design exercises. In particular, an incomplete analysis of
context; failure to express a vision for the form and design of the
development; delivery of later phases is not discussed; the justification of the
loss of open space and impacts on amenity, ecology and hydrology are not
sufficiently explored; low quality of environment dominated by the car; lack of
connectivity between the new development and the town centre; awkward
built form with visually prominent ‘backs’ and ill considered public realm. It is
also noted that CABE have previously raised objections to the form of the
scheme, none of which have been addressed.
Inadequate Assessment of Environmental Impacts:
• The ES fails to assess the significant environmental effects of the

development and is thus unsound. Planning permission should not be granted
until all significant environmental effects are assessed.
Flood Risk:
• Realignment of the river seems to be an extreme measure and alternative

development layouts could remove this requirement. The more widespread
use of SUDS should be considered.
Renewable Energy – Clarifications Sought:
• The Renewable Energy Report reviews a range of options to be considered at

the detailed design stage. However, this is generic with no indication of
specific proposals the applicant is committed to achieve.
• The proposal for ground source heat pumps involves 18 boreholes that may
affect the local hydro-geological environment. A detailed assessment would
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Representations
be required prior to planning permission being granted.
Independent Assessment Required:
• The scale of development and its regional significance are such that it should
be ‘called-in’ and considered by an independent body.
Grosvenor Ltd:
Grosvenor is the developer responsible for the retail-led ‘Liverpool One’ project,
which will open this year.
• No objection is made to the Council or its partners seeking to regenerate

Kirkby town centre, or the provision of a new football stadium. However, they
do object to the scale of the comparison retail development, which is not
considered appropriate or acceptable in this location. Nor are there
considered to be sufficient material considerations that would justify this form
of unacceptable development. It is suggested that the application be revised
to significantly reduce the level of comparison floorspace proposed.
The objections made focus on four grounds.
Conflict with Policy:
• Neither the UDP nor the RSS envisage the scale of comparison retail
development proposed and would be in direct conflict with a number of key
policy objectives.
• The RSS promotes the two regional poles of Liverpool City Centre and
Manchester / Salford as the first priority for development and resources.
Kirkby falls outside of the definition of Liverpool and the surrounding inner
area in Policy SD1. Likewise, Kirkby is not referred to in other areas identified
in Policy SD1 or Policy SD2. Rather, Kirkby would be covered by paragraph
3.15, which states that development in the remaining urban area will be more
modest and should be of an appropriate scale, nature and environmental
quality to create and conserve attractive neighbourhoods which will meet local
housing, employment and service needs and discourage commuting. Policy
EC8 supports the sequential approach to new retail development.
• Objective 5 of the UDP encourages shopping and other town centre uses
consistent with local needs. Here and in Policies CP1 and S1 it states that
developments be of a scale appropriate to the role of the centre in question.
Policy S1 also refers to the need to protect the vitality and viability of existing
centres and, in respect of Kirkby, identifies a need for 9,000 m2 gross of food
retailing and a minimum of 7,000m2 additional comparison floorspace split
between Kirby, Huyton and Prescot. At paragraph 7.14 mention is made that
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Representations
the catchment area for proposed development should generally not be

significantly larger than the centre within which it is located. The principles are
echoed in Policy S4 with the supporting text referring to the need for a 9,000
m2 foodstore and at least 2,000 m2 of non-food shopping. The proposals,
though, are clearly substantially in excess of the additional comparison retail
floorspace envisaged in the UDP.
• While the development plan supports regeneration and a modest

enhancement of the retail offer, it does not envisage the scale of development
proposed or the major extension of the town centre to the south. The scale of
development should be consistent with the maintenance of the role of the
centre in the shopping hierarchy. The proposed development clearly conflicts
with the development plan.
• Similarly the view is taken that the proposal does not conform to the emerging
RSS. It is noted that Kirkby is not listed in the draft RSS as a regional centre,
or as a regional town or city or Key Service Centre. Policy LCR3 specifically
mentions that Kirkby as a centre will be maintained and enhanced to provide
community facilities, services and employment. Again, the focus is on meeting
local needs.
• In relation to the IPS, it is noted that this is the only document that even
considers the scale of the development proposed. However, the IPS is in
draft, outside of the LDF process and not an appropriate route to introduce a
major policy change that would elevate Kirkby significantly in the retail
hierarchy.
• Conflicts with national policy are also highlighted. Specifically, PPS6 and a
requirement that the scale of development should be directly related to the
role and function of he centre to which it relates, as well as its catchment;
PPG13 seeks to encourage more sustainable development and reduce the
need for travel; and PPG17, which states that out of centre retail and leisure
uses associated with stadia should not be granted unless it complies with
national policy on retailing.
Scale of Comparison Retail:
• It is noted that approximately 80% of the proposed retail floorspace is located

south of Cherryfield Drive and outside of the existing town centre. Also, the
floorspace of the development is approximately three times that of the existing
town centre. This would result in Kirkby have a greater floorspace than Wigan,
Warrington and St Helens, with only Liverpool, Bolton and Southport having
more floorspace. This would have the effect of altering the retail hierarchy.
PPS6 states that the identification of new centres of more than local
importance should be addressed through the development plan system. The
proposal is, thus, contrary to government advice and new retail development
should be of an appropriate scale and in accordance with the RSS.
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Representations
Retail Methodology and Impact on Liverpool City Centre:
• It is noted that DPP’s November 2007 assessment of available retail

expenditure is based on a MapInfo report dated October 2006. It is unclear
why an out of date report as been used. Similarly, up to date data on internet
and other non-retail store expenditure is not utilised.
• Considerations of capacity have been based on trade draw from catchment

zones. This does not appear to be based on any empirical data, but rather on
some judgement by DPP.
• More importantly, the assessment is over-simplistic and does not place the
existing facilities within the context of the retail hierarchy and the need to
make allowance for trade that will inevitably flow to centre’s higher up the
hierarchy.
• On a matter of detail, the relationship of gross to net floorspace is not clear;

data is in some cases drawn from unpublished sources; and the divisions
between comparison and convenience floorspace in existing stores and their
turnover has been based on national averages rather than specific data for
the local area.
• Utilising a generalised approach to calculation of impacts, along with the

above methodology concerns, has the effect of producing questionable
results.
• However, even accepting the conclusions adverse impacts are obvious. The
overall impact on Kirkby town centre is 200% on convenience trade and 520%
on comparison trade (400% combined). This illustrates the huge nature of the
proposals in relation to the existing scale of Kirkby and further highlights the
conflict with PPS6 in terms of scale and alterations to the retail hierarchy by
way of a planning application rather than a plan-led approach. In relation to
Liverpool City Centre the net adverse impact is £129m (24%) compared to its
2012 (pre-Liverpool One development) turnover of £531m. With the scale of
the Kirby project, consideration should be given to the impacts on Liverpool
City Centre at such a sensitive time in its further development.
• To conclude, the scale of comparison floorspace proposed runs counter to

PPS6 and, even on DPP’s figures, has substantial adverse impacts on other
centres.
Impact on Developer Development Decisions:
• Grosvenor and its partners and occupiers are making a £1b investment in
Liverpool City Centre on the basis that it will remain the priority for major
comparison shopping development in the region, as per RSS and draft RSS
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Representations
policy.
• The scale of development is not envisaged by the development plan. It is not

appropriate to change the retail hierarchy through consideration of a planning
application and should only occur through a review of RSS.
Planet Sports:
• A shop in St Chad’s Parade object to the scale of the development (three

times that in the existing town centre) and that it would lead to the closure of
the existing town centre and loss of local businesses. Also, there is no
provision made to improve the existing town centre, to include a smaller
supermarket within it, or to incorporate the existing town centre into the new
development. In view of the far-reaching effects of the development and the
policy issues, the Secretary of State is urged to call-in the application and a
Public Inquiry held.
Primary Fluid Power:
• A company based on Knowsley Business Park, state that the project has
great greater benefits to the local community beyond the issues of football and
shops. The stadium is crucial not only to EFC but also the success of the
development and the continued inward investment and enterprise in the
Borough.
Royal Mail Group plc :
• Are considering the planning application, but at this stage consider the only
area of concern to be the highways impact and the effective operation of the
Delivery Office; free movement of delivery vehicles to and from the Delivery
Office being a key element of that operation. If the consultants engaged by the
Council find there to be an adverse impact on the effective operation of the
Delivery Office, Royal Mail is unable to support the development proposals.
Trevor’s Card Shop:
Object to the planning application as:
• the development would directly conflict with own and other local businesses;
• the loss of the town centre would take the heart out of Kirkby;
• conflicts with UDP and regional planning policies and PPS6;
• the development will compete with other local centres including Liverpool, St
Helens, Southport, Rainford, Skelmersdale and Ormskirk;
• the majority of the development (three times the scale of the existing town
centre) would be on green fields, and thus not be environmentally friendly
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Representations
(e.g. increase flooding and harm to local wildlife and vegetation);

• cause traffic congestion, noise, light and air pollution;
• redevelopment of the existing town centre should be the priority;
• Tesco’s figures show that the development will take 27% of grocery trade and
30% of non-grocery trade from the existing town centre, amounting to a total
sales loss of £25m. Kirkby Town Centre cannot sustain this loss;
• In view of the far-reaching effects of the development and the policy issues,
the Secretary of State is urged to call-in the application and a Public Inquiry
held.
Comments from Business Interests – First Revised Submission
ING:
ING own The Strand Shopping Centre in Bootle.
• ING consider the application should be refused planning permission and

object on the grounds that:
• the scheme is contrary to the provisions of the RSS, DRSS and the UDP;
• the scale of the proposals is inappropriate and will fundamentally alter the
existing retail hierarchy of shopping centres in the sub-region; and
• the retail elements of the scheme will divert damaging levels of trade from,
and have an adverse impact on, established town centres including Bootle.
• Reference is made to the catchment area covering an extensive area,

overlapping and competing with Bootle town centre; serious concerns about
the methodology adopted for demonstrating need, as required by PPS6 and
has not taken account of outstanding superstore commitments at Great
Homer Street and Breck Road, Liverpool, at Litherland and at Bootle; the
sequential assessment is inadequate and does not comply with PPS6; and
the withholding of survey evidence, the lack of rigour of the retail assessment
a false assumption that market share of existing centres will remain the same,
and the failure to take account of existing commitments lead to the view that
levels of impact are considerably under estimated and do not provide an
accurate picture.
Grosvenor Ltd:
• The reduction in retail floorspace of 3,462m² is noted, However, the previous

comments are reiterated. Grosvenor considers that the application should be
revised further to significantly reduce the level of comparison floorspace
provided.
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Representations
Skelmersdale Limited Partnership:
• Object to the retail component of the above planning application and wishes to
add its support to the objection from West Lancashire District Council.
• The Partnership also wishes to object, in its own right, on the grounds that the
scheme is highly likely to have an adverse effect on the vitality and viability of
the Concourse Centre which, as far as comparison shopping is concerned, is
the core of Skelmersdale town centre. Any significant diversion of trade from
the Concourse Centre will directly threaten the vitality and viability of
Skelmersdale town centre as a whole.
• In addition, the proposals are considered likely to cause prejudice to the

proposals being pursued to secure the regeneration, expansion and
enhancement of Skelmersdale town centre. Given English Partnership’s
involvement in those proposals, and the identification in regional policy and
the Structure Plan of Skelmersdale town centre as a priority area for
regeneration, it is considered that the achievement of that regeneration is a
priority which is of more than local interest. Accordingly, the potential harm
which the application proposals in Kirkby might cause to that regeneration (by
diversion of existing and potential custom and expenditure) should be given
significant weight. It is recognised that there is a need for regeneration of
Kirkby town centre, but would suggest that this cannot and should not be
pursued at the cost of threatening other equally important regeneration
initiatives or at the risk of harming the vitality and viability of other town
centres such as Skelmersdale. It is added that the scale of the scheme is
inconsistent with role and function of Kirkby in the retail hierarchy and need for
the scale of retail development has not been demonstrated, contrary to PPS6.
St Modwen Properties plc:
St Modwen are progressing two schemes at Skelmersdale and at Great Homer

Street, Liverpool.
• St Modwen regard the scheme as being entirely at odds with the PPS6. A
detailed critique of the applicant’s submissions is provided and objections
made on the following specific grounds:
• the applicant has failed to demonstrate that there is a quantitative need for the
scale of retail floorspace proposed in the area to the south of Cherryfield Drive
and in particular the size and scale of the proposed Tesco store;
• the qualitative need for the amount of retail floorspace and the size of the
Tesco store has not been fully justified;
• the proposed amount of retail floorspace and the Tesco store in particular is
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Representations
not of an appropriate scale in relation to the existing town centre and nearby
centres;
• the amount of retail floorspace proposed and the Tesco store will have a
potential adverse impact on nearby centres; and
• the prejudicial impact that the scale of retail floorspace will have on the
viability of regeneration schemes in Skelmersdale town centre and Great
Homer Street district centre.
• It is submitted that the scheme should be refused planning permission.
Comments from Business Interests – Second Revised Submission
Any comments received will be reported to the Committee at its meeting.
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Representations

Comments from Interested Individuals – Original Submission

Comments on the application have been made on the following grounds:

Grounds for Objection

Economic and Regeneration:

Town Centre and Retail:

• No need for more retail / expansion of town centre - 3

• No need for a large foodstore / or 24 hour trading store - 53

• Inadequate infrastructure will lead to traffic congestion - 36

Urban Greenspace, Public Open Space, Sport and Recreation:

• Loss of well-used, accessible and amenity greenspace - 134

• Leisure facilities for young and old should be included - 1

Environmental Protection and Sustainability:

• Adverse effect on the environment (general comment) - 64

• Petrol Station is close to housing - 6

Site Layout, Design and Heritage:

• Negative impact on the landscape and townscape of the area - 14

Nature Conservation and Ecology:

• Loss of flora and fauna and it's habitat - 36

• Scheme will cause health side effects to residents - 22

Crime, Public Order and Personal Safety:

• Inadequate policing for the scheme - 22

• Need to include ways prevent: prostitution, drugs, crime - 2

• Unacceptable to demolish schools, order CPO on homes; detrimental to

Implementation and Phasing:

• Phasing needs review and to be planned better to minimise adverse effects

• Tesco site should be used to re-build a school learning centre or sports

Grounds for Support

Economic and Regeneration:

• Scheme will enable regeneration - 20

Town Centre and Retail:

• Kirkby is in need of a foodstore, shopping complex / retail park - 24

• More traffic once a fortnight will be fine - 3

Urban Greenspace, Public Open Space, Sport and Recreation:

• The green site does not get use by residents - 1

Environment and Sustainability:

• Areas of concern in the application can always be mitigated - 6

Economic and Regeneration:

• Will leave / think of leaving Kirkby if the stadium comes - 5

Town Centre and Retail:

• Service area by new road between stadium/coach park cut disturbance - 5

• More work needed avoid traffic problems present at other stadia - 3

• Alternative sites for a stadium better served by infrastructure - 3

Urban greenspace, Public Open Space, Sport and Recreation:

• Land is being given away - sale of any land should go to the

Site Design and Heritage:

• Scheme is not of a high quality design - 1

• Affordable housing should be included in the scheme - 1

Implementation and Phasing:

• Scheme is being rushed, don't make rash decisions - 1

• Council should not decide, govt should 'call it in’ - 5

• Object to community created pre-filled in objection Council comment forms,

The proportion of individual representations received indicating objection to the

The proportion of individual representations received against major elements of the

grounds of support are shown in the bar chart below.

• the development would lead to a massive increase in traffic, which would

• 410 are strongly opposed;

The proportion of all first round consultation representations received indicating

Comments from Interested Individuals – First Revised Submission

43 individually written representations have been received from local residents.

Comments on the application have been made on the following grounds:

Economic and Regeneration:

Town centre and Retail: