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Public Inquiry into application for: mixed-use development

including a new football stadium, retail, residential and leisure

uses on land in Kirkby

Closing Submissions of KEIOC Campaign

February 2009
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In this first section I shall attempt to give an overview of KEIOC’s position.

1.0 Objections by The Keep Everton In Our City campaign to this application are centred on

the proposed relocation of Everton Football Club from the City of Liverpool to the township of

Kirkby some nine miles from the region’s main centre1.

2.0 Whilst it has been convenient for some to present KEIOC’s objection to this application

as one based on fanaticism and nostalgic emotion, the reality could not be further from

this position. KEIOC believe that this application is not in accordance with the

development plan and represents an unacceptable departure from existing planning

policies, namely:

• PPS1

• PPS6

• PPG13

• PPG17

• The Development Plan

3.0 In addition to these departures KEIOC are of the opinion that Everton has failed to
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demonstrate a physical need for a 50,000-seat stadium in Kirkby or the financial

capacity to generate their contribution of £78m 3, or the ability to sustain a stadium in

Kirkby meaning that the disruption to the lives of residents of Kirkby and the loss of their

communal greenspace will have been sacrificed to no avail.

4.0 It has also become clear that the applicant seeks permission for the stadium so as to

justify the quantum of retail space required to deliver a cross-subsidy from a development by

Tesco Stores Ltd, a private company, to Everton Football Club, another private company,

through public land sold at current use value by Knowsley Council to Tesco Stores Ltd.
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5.0 The inquiry has heard that Everton are one of England’s greatest and most famous

football clubs. The inspectors will have noted Everton’s large and fanatical following; their

historic and atmospheric stadium and listened to their CEO, Mr. Robert Elstone, explain the

reasons behind why Everton must be facility - led and attract capacity crowds to a new stadium.

6.0 KEIOC are fully supportive of Everton’s objectives but, whilst we accept that the

sentiment is sincere, we cannot agree that a 50,000-seat stadium belongs in a town of 40,000

inhabitants nor can we agree that this stadium will deliver the level of revenue required to

compete in the premier league. The disruption on matchdays will affect the lives of the ordinary

people of Kirkby and the surrounding areas. The inconvenience to Everton supporters, due to

the gross inadequacy of the transport infrastructure, ill equipped to accommodate an estimated

influx of up to 50,000 people, cannot be underestimated.

7.0 The inquiry has not been presented with any significant material representing the views

of those supporters expected to travel to Kirkby. Once again Everton has failed to supply any

positive information supporting this view; yet it is those supporters and their willingness to

accept a trailblazing transport management plan that will be an essential factor in influencing the

likelihood of success or failure of achieving the desired attendance levels at any proposed

stadium. Further, in terms of sustainability, the wisdom of asking supporters from a club with the

largest walk-up catchment to travel, largely by motorised transport, to a different location

altogether, is at best questionable.

8.0 The inquiry has heard that Everton Football Club have a desperate need for a bigger

and better stadium. A stadium that will deliver higher revenue streams that will enable them to

continue to compete in the English premiership league. So what? Should the planning system

be subjugated to Everton’s desire? Should the livelihoods of thousands of people in Liverpool,

Sefton, West Lancashire, St Helens and, ironically, other towns in Knowsley, be disrupted and

jeopardized for the needs of private business? There are only two possibilities:
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a) Everton is a club whose history and local supporter base is a major cultural and historic

asset to Liverpool. If so, the wholesale removal of the club represents a planning

detriment which weighs in the balance;

b) Everton is a commercial brand. If they are no more than that, then its survival or

otherwise is a matter of indifference to the land-use planning system; it should locate

where it can do so without environmental or other planning detriment.

9.0 KEIOC has submitted an extensive amount of documentation to this inquiry in a bid to

prevent the delivery of an unwanted football stadium, unwanted by a significant proportion of

Everton supporters4 and unwanted by a significant number of those residents of Kirkby

responding to “Our Kirkby Our Future”5.

1. KEIOC/P/4 - Appendix 7

2. KEIOC/P/4 – 5.1.3 & 5.1.5 & 5.1.6 & 5.1.7

3. Despite numerous requests Everton have declined to provide this information citing commercial

sensitivities.

4. KEIOC/A/4 – Galaxy Survey results

5. CD 3.3.2
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In this next section I shall attempt to clarify our position on location, design, planning and finance.

10.0 KEIOC would suggest that the aggressive attempt to move a cultural landmark from one

local authority to another is just as much a planning matter as the attempt to force changes in

the regional shopping hierarchy6, and we respectfully ask the planning inspector to consider this

issue when reporting to the secretary of state.

11.0 During the inquiry we have witnessed the baffling contradiction of statements emanating

from the respective Members of Parliament for Walton and Knowsley North; one claims that

Everton’s proposed relocation will have little affect on the economy of Walton7, whilst the other

claims that Everton moving to Kirkby will be beneficial to the local economy of the town. The

inquiry has heard that Kirkby’s economy will increase by £13.6m8 due to the presence of

Everton9, if accurate this must represent the pro rata figure of loss to the Walton economy. The

disbenefit to Walton was confirmed by evidence presented by the applicant’s witness Mr. Hollis

when he explained that job losses in the area of Walton would be 137 to 301; unfortunately Mr.

Hollis didn’t have the figures relating to loss of trade at that time. Despite Mr. Lancaster’s clear

request at the time we are as yet unable to locate this information10. One community’s gain will

be another community’s loss and we would, once again, respectfully ask this to be given due

consideration. In other words, the economic benefits and detriments, in footballing terms, are

largely self-cancelling.

12.0 Planning should also consider long-term social and cultural matters as well as short-

term economic concerns. We have heard from Mr. Elstone that football is an emotional

business and the club is closely associated not only with the City of Liverpool but, more

specifically, with its historic roots North of the city centre.

6.CD 2.1

7. TEV-INQ-18

8. Evidence of Mr. Graham Tulley

9. Evidence of Mr. Graham Tulley

10. Request before contacting the secretary of state at the conclusion of Mr Lancaster’s cross-examination.
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13.0 Potential sites have been presented11 such as the Scotland Rd Loop location, Everton

Park and the Central Docks area that would reinforce this vital connection, as would an

expansion of Goodison Park or even a joint stadium with Liverpool Football Club.

14.0 Rightly or wrongly the boundary between Liverpool and Knowsley exists; they are

separate communities with separate identities that should be improved and encouraged not

demolished and abandoned.

15.0 When considering the movement of large numbers of people, Merseyrail is the central

nervous system of the Liverpool conurbation12. With access through Kirkdale station, it has been

seen that Goodison Park is much better placed on this network than Kirkby. The Scotland Rd

Loop site, adjacent to the City Centre is best placed of all, providing direct access to regional

and national routes. An important aspect of the Loop site is this accessibility. Unlike Kirkby, it

would essentially be an integral part of the City Centre, the infrastructure of which, again unlike

Kirkby, has the ability to handle much larger numbers of people than the stadium capacity, and

includes car parks, regional links and national connections, such as Lime Street Station, which

is just 15 minutes walk from the site 13 coupled with direct road, rail and bus links to Wirral and

beyond.

16.0 Despite attempts to claim otherwise, the assumed stadium capacity for the Loop site is

55,000; the world-renowned stadia designers HOK Sport Architecture confirm this in a

report14. Although this 55,000 capacity does meet Everton Football Club’s current

requirements KEIOC has explained, that by utilising adjoining land, it may be possible

to expand this capacity in subsequent phases. This site does not and has never met the

requirements of Liverpool Football Club and KEIOC would ask that the misinformation

on this subject that was presented to the inquiry be disregarded in favour of the more

accurate information that has been subsequently provided through Trevor Skempton15.

11. KEIOC/S/1

12. KEIOC/S/1

13. KEIOC/INQ/1

14. KEIOC/INQ/1

15. KEIOC/INQ/19
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17.0 One of the more practical alternatives to Kirkby is a shared stadium, with the most likely

sites being either Stanley Park or the Central Docks. Many public bodies favour this and

many supporters understand the rationale if not the practicalities. Despite this, neither

football club, Everton or Liverpool, has been prepared to put forward this most obvious,

cost-effective and environmentally acceptable scenario as an alternative to their current

planning applications.

18.0 A modern stadium should be seen as a mixed-use building, contributing to the life of the

surrounding urban area seven days a week. This accords with the urban design approach

encapsulated in CABE’s document ‘By Design’16 with its emphasis on active frontages and

urban enclosure. We’ve heard that the days of the stadium as an out-of-town ‘space-eater’ only

active on match days have gone. The mixed-use alternative is more attractive, sustainable and

would fit perfectly with Everton’s need to be facility led.

19.0 The traditional design of Goodison Park is multi-tiered, with spectators very close to the

pitch. Reproducing this theatrical arrangement in a modern stadium is more expensive than a

single-tier option like Kirkby. The Kirkby stadium will have more of the atmosphere of a multiplex

cinema than the atmosphere of ‘grand theatre’ that is present in the best of the tightly

constrained inner-city grounds such as Goodison, Anfield, St James Park or the Millennium

stadium.

20.0 We have heard that the applicant’s transport plan is intended to move people out of

their cars and on to public transport; this proposal has to accommodate a restriction in

train capacity, due to the physical limitations of Kirkby railway station and its track 17,

coupled with the capability of an ad hoc bus station, that during the post-match period

will become Britain’s busiest bus station by a margin of 50%, requiring a bus departure

every 14.5 seconds for an hour18. We would suggest that the potential success of this

plan would appear unrealistic at best.

16. KEIOC/S/1 – Design policy Requirements

17. CD 1.5.1 SDG Transport Plan

18. Evidence Mr. Ellis.
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21.0 No survey evidence has been presented to the inquiry by the applicants to indicate

Everton supporters’ acceptance of queuing for up to an hour or more at both the bus and

railway station. The witness on behalf of the applicant 19 stated that football supporters don't mind

being cold and wet; apparently it’s part of the experience. We are unable to present any

supporter with this point of view, which is at best disrespectful and at worst totally unrealistic. A

very basic observation indicates that supporters with children, older supporters and the infirm,

who are all less mobile, will take longer to get to these departure points or would need to leave

the game they have paid to see up to fifteen minutes before its end if they are to avoid being at

the back of these lengthy queues. The plan indicates that the bus station will have multiple

routes from each stand controlled by signage. In order to meet the efficiency required, buses

have to be filled to capacity from the queuing reservoir; this could mean passengers being

brought to the front ahead of others to access buses departing for their required destination.

Surely this is a potential recipe for disaster, chaos and unrest. Is this what was meant when

Everton fans were told that the stadium would have the best transport facilities in the North20?

21.0 Moving on to the matter of congestion, and in a bid to refute claims to the contrary, Mr.

Sapiro, for the applicants, in his proof of evidence21 states, “Even where significant

queuing is predicted, the assessments may underestimate the extent of this – for

example, a large queue is expected on the Cherryfield Drive approach to the Valley

Road roundabout post-match – however, ARCADY assumes that the full width of the

give way line can be used – but if much of this traffic wishes to make one movement at

the junction (most will want to turn left to access M57), then the true capacity will be

less than the ARCADY assessment predicts (as the right hand part of the give way line

will be under utilised), so queues can be expected to be significantly greater than

predicted.

19. Evidence of Mr. Hollis.

20. KEIOC/P/4

21.SUP/KMBC/P/4 - 5.113 (page 41)
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23.0 Somewhat surprisingly in his rebuttal of our evidence22, “There are suggestions (see

para 6.6 and 6.9 of KEIOC's transport proof) the congestion will be more severe and longer

lasting than Goodison Park. I do not agree with this conclusion, nor do I believe that any

evidence has been put forward to substantiate this. The ARCADY analysis (for example) for the

Cherryfield Drive/Valley Road roundabout, as cited by KEIOC in para 66 of their transport

evidence, presents very much a worst case analysis - it, in effect, assumes that football fans

make no attempt to stagger their leaving times and it assumes that non-football traffic remains

at close to its non match day levels.

24.0 The assumption that football fans wish to stagger their leaving times is nonsense and

easily dismissed by observing the crowd dynamics at Goodison Park. Whilst the old and infirm

may be forced to leave through the existence of a poorly thought out transport plan, 90% will

attempt to depart within minutes of the final whistle. If non-football traffic were to drop

significantly on matchdays, as suggested by the applicant’s witness, shouldn’t the whole

rationale behind the synergy between a stadium and a retail park be brought into question?

Have the applicant’s informed their potential tenants that they are likely to experience a

decrease in footfall when the stadium is in operation?

25.0 Mr. Ellis of SDG stated that the stadium is an “edge of centre” development, whereas

Goodison is an “out of centre' stadium. This might work if the majority of spectators attending

were from Kirkby, but, of course, they are from Liverpool and the season ticket holder

distribution map23 clearly shows that the new development is an 'out of centre' – that is out of

Liverpool City Centre development from that aspect. In addition the distribution map confirms

that the vast majority of supporters will be attempting to travel in the same direction, towards

Liverpool. Everton has failed to provide any information on non-season ticket matchgoing

Evertonians.

26.0 That there are no clear plans for the segregation of away supporters who may wish to

take the train or a taxi back to Liverpool City Centre is surprising. There is clearly potential for

great disruption at the station, and to state that management of the away supporters is a police

matter24 is unsatisfactory. There will be many away supporters who travel independently,
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perhaps staying in Liverpool overnight, who will be outside of police control, but who still have

the capacity to generate problems, whether or not at their own instigation. The process of

managing rival sets of supporters and transport modes is likely to create serious amenity and

recreational issues for Kirkby residents on match-days.

27.0 We have seen that the demand for rail has been underestimated; many fans already

travel by rail from Wirral and South Liverpool. In the future when developments such as Halton

Curve (allowing access from Chester to Liverpool) and the electrification of the Wrexham line

(direct access from Wrexham to Liverpool) are completed, the demand for the rail service is

likely to increase because of convenience. There has been no case put forward by the applicant

for how it will deter fans from travelling by train and to encourage them to travel by bus or

coach. If demand for the train were greater than the capacity, fans would be left disappointed,

could miss the beginning of the stadium event, the last train home during a night game or worst

of all decide not to attend.

28.0 When Headbolt Lane railway station in Kirkby is built, the time available to load up to

960 people onto the train will reduce 25. This potentially could reduce capacity because it may

not be physically possible to load 960 people in the allotted time due to the constraints of the

single rail track which would also lead to longer waiting times for those in the queuing reservoir.

Everton seemingly have two surveys relating to how the fan’s travel to Goodison Park. In 1996,

JMP surveyed 547 fans and at the time of surveying there was no residents parking zone nor

was the ‘Soccerbus scheme’ implemented, both of which can deter car usage.

29.0 In November 2007, the club contacted fans and requested that they complete a survey

on the Internet (National Fans Survey). This survey is referred to in both Mr Elstone’s

and Mr Sapiro’s proof of evidence. In total 1,549 Everton supporters completed this

survey. The National Fans Survey document states that nearly 4,000 of the 32,847 total

respondents “never go to matches”, this along with Table 6.3 of Mr Sapiro’s proof of

evidence, which suggests that some fans walk to the game from as far as London and

Scotland, clearly undermine the accuracy of the results. In both cases, such a small

random sample cannot be used to establish how 36,000+ fans choose to travel to

stadium events. Due to these obvious flaws, KEIOC respectfully ask the planning
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inspector to afford these surveys no weight when writing the inquiry report for the

secretary of state.

30.0 However, there appears to be no need for a survey of the travel intentions of Everton

supporters because the Transport Plan makes no attempt to address how they actually

want to travel. The basis for the plan was to conform to the requirements needed to

meet planning policy, it did not respond to the actual inclination of the supporters. The

'carrot and stick' method proposed will serve to discourage attendance, not encourage

people to switch from their cars to buses, particularly since so many more matches are

now televised and/or streamed on the internet. Ultimately, these difficulties will act to

discourage attendance, and it should be remembered that a key element of Everton’s

desire to relocate is to increase their attendance level by 10,000 supporters26.

31.0 Prior to this public inquiry, KEIOC were of the opinion that a move to a stadium located

some nine miles from the centre of Liverpool represented a potentially hazardous and

ill-informed business decision for Everton Football Club. As we approach the conclusion

of this inquiry this contention has not changed, we continue to believe that this move

represents an extremely risky strategy for a club so desperately in need of a successful

stadium plan and that the finances surrounding the ability to fund and the likely returns

are at best unclear and at worst misleading.

32.0 It would appear that the only firm proof Everton offer to the inquiry, regarding their ability

to fund their contribution to the project, is a letter27 from their advisors, Deloitte,

confirming that Everton would be unable to raise more than £80m. A list of funding

options has been provided but not elaborated on; one option has unfortunately been

recently denied by the decision of another planning inspector. The list appears more of

a wish list than a cohesive business strategy. As yet there is no confirmation regarding

who will fund the £6m increase in cost, caused through the delay to the project. The

inquiry has heard Everton’s CEO confirm that not a single penny is yet to be secured

from this options list and in line with the comments made at the second pre – inquiry

meeting regarding unsubstantiated information we would ask the inspector to disregard
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Everton’s financial information unless they provide indisputable proof of their ability to

generate this £80m contribution.

33.0 This inability to provide proof of their capacity to fund their contribution is surpassed

only by their failure to demonstrate a need for a 50,000-seat stadium in Kirkby.

34.0 It has been confirmed that Everton has a current average attendance level of 37,00028.

The inquiry has been told that by increasing this to an average of 47,000 it will generate an

additional £6m and enhance their ability to compete in the English premier league; a sentiment

that KEIOC are in total agreement with but an aspiration that Everton has once again failed to

substantiate.

35.0 It has been established that unlike other football clubs that have moved, or are

contemplating a move, Everton are unable to demonstrate any demand whatsoever for

additional ticket sales; the current stadium rarely sells out and there is no season ticket waiting

list, unlike their peers in the premier league such as Liverpool, Arsenal and Spurs to name but a

few.

36.0 We have heard that, uniquely, Everton know that 40% of the fanbase, their customers,

which they selected to ballot in 2007, were against their vision of a stadium in Kirkby.

This was a selection of supporters that, at the time, appeared to be misled, through the

combination of an extensive media campaign that inaccurately proclaimed the stadium

to be an effectively free, best-served and world-class facility. It was also an exclusive

ballot that failed to take into account the opinions of the non–season ticket owning

matchgoing Evertonians, a group that constitutes a significant percentage of the 90,000

fans identified by the club through their database. It that way, Everton have effectively

disenfranchised a significant percentage of their customers. It should be noted that not

one Everton supporter in favour of this relocation has addressed this inquiry, ask

yourself why?

22 SUP/KMBC/R/4 - 1.19

23 TEV/INQ/39
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24 Statement during presentation of Evidence by Mr. D. Thompson – KEIOC/P/2

25 Cross-examination of Mr. Sapiro by Mr. Thompson of KEIOC

26 TEV/P/8 – 8.4.2

27 KEIOC/P/4 – Appendix 5

28 Deloitte Annual Review of Football Finance 2008

37.0 KEIOC has submitted to this inquiry information gleaned from the 2008 Deloitte report

that raises significant doubt as to the ability of new football stadia to deliver their

expected levels of attendance. Appendix 8 of KEIOC/P/4 graphically illustrates that the

vast majority of new stadia identified by Everton, when compared to existing

premiership grounds fail to meet expectations. The exceptions are Arsenal and Reading

who built stadia to meet an identifiable demand and are of an appropriate size

respectively. Deloitte would appear to confirm that new stadia have an average

occupancy level of 77%29 and the inquiry has heard further concerns from Deloitte30

surrounding the danger of getting stadium relocations wrong.

These important factors, namely:

• At least 40% against the relocation

• Nine miles from the centre of Liverpool, a greater distance than any other football club

in the top flight of English football

• Major concerns surrounding the transport to and from the stadium

• The inability of Everton to demonstrate demand or appetite for a stadium in Kirkby

• The absence of any qualitative or quantitative survey information by Everton regarding

their supporters actual requirements for a new stadium

• An analysis of the ability of new stadia to deliver their forecast attendance levels

lead KEIOC to fear that a potential combination of these factors will have a detrimental effect on

the stadiums ability to generate its forecast attendance level of 47,000. From this information,

(which can be seen in KEIOC/P/4), KEIOC forecast attendance levels in the region of 38,000

once the new stadium effect31 has subsided, possibly after just one season.
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38.0 Unlike Everton, KEIOC has attempted to substantiate their alternative funding proposals

for a redeveloped Goodison or at the site in Scotland Rd 31. The inquiry has heard that

using a combination of selected sources identified by Everton in combination with

Stadium Capital Financing Group’s Equity Seat Right (ESR) methodology and the

establishment and organisation of a supporters trust, all proven methods of stadium

financing, a debt free amount in excess of £200m 32 could be raised to fund a stadium

project without the assistance of Tesco. This would be real money, not value; real

money for a real premiership standard stadium in a fit and proper location.

39.0 And that is what it’s all about, LOCATION, LOCATION, LOCATION; the right location for

the fans, the right location for the residents of Kirkby and the right location for Everton

Football Club. For Tesco it appears that the right location is one that enables them to

achieve the maximum amount of retail despite the apparent unsuitability of Kirkby and

for the neighbouring authorities. The applicant has successfully used this tactic of

providing a sports stadium on at least two occasions in local towns. A stadium for

Warrington Wolves was built on a brown field site and more recently a proposed

stadium was given planning permission in St Helens on another brown field site. Apart

from the use of Urban Green space, the difference between these and Destination

Kirkby is that at St Helens, a town with a population of over 100,000, they’re building an

18,000-seat stadium and at Warrington, a town with a population of over 190,000 Tesco

built a 14,000-seat stadium. Common sense tells you that a 50,000-seat stadium

doesn’t belong in a town of 40,000; it is likely to overwhelm the centre and the local

residents, many of whom will have no interest in football, let alone Everton. To that

extent the stadium will be a most unwelcome interloper.

In this final sector we shall list the policies that we believe this application comes into conflict with.

40.0 KEIOC believes that there is a major conflict with the North West Regional Spatial

Strategy. Regional Spatial Framework - Policy RDF1 – Specifies that the priority for

growth and development should be the regional centres of Manchester and

Liverpool; the second priority should be the inner areas surrounding these regional

centres. The attempt to remove a world-renowned sporting and cultural institution from
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an Inner Area [North Liverpool] of the Regional Centre [Liverpool] is in direct conflict

with the ‘cornerstone’ of the RSS, that is Policy RDF1.

29 KEIOC/P/4 – 5.1.3

30 Cross-examination of Everton CEO Robert Elstone.

31 KEIOC/S/1

32 KEIOC/P/4 – 6.1.3

41.0 Policy LCR1 – its function is to promote urban renaissance and social inclusion within

the Regional Centre and its surrounding Inner Areas. Everton Football Club and Goodison Park

has been intrinsically embedded into the social fabric of North Liverpool perhaps more than any

other single entity for over 130 years. With the loss of such an important, historical institution to

North Liverpool and the City, the detrimental effect that would have on civic pride, the identity

and self-respect of the area and its communities, can only lead one to conclude that the

attempted relocation of Everton Football Club to Kirkby is in direct conflict with Policy LCR1.

42.0 Policy LCR2 - the Regional Centre is the primary economic driver - plans and strategies

should support and enhance this role by focusing appropriate commercial, retail, leisure, cultural

and tourism development within the Regional Centre. The displacement of Everton Football

Club to Kirkby, some nine miles from this centre, would have a direct and harmful effect on the

economic stability of both the Inner Area of North Liverpool and the Regional Centre of

Liverpool. Therefore the proposal for the relocation for Everton Football Club to Kirkby is in

conflict with Policy LCR2 of the Regional Spatial Strategy.

43.0 Policy LCR3 - Kirkby is part of the Liverpool Outer Area and is subject to Policy LCR3. It

should provide a complementary function to Liverpool City Centre and the Inner Areas,

reflecting its individual character, location and meet local needs. The removal of Everton

Football Club from a Inner Area of the Regional Centre would neither provide a complementary

function to Liverpool City Centre; the Inner Area of Walton nor reflect the individual character or
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meet the local needs of Kirkby and is therefore not in accordance with Policy LCR3 of the RSS.

44.0 Conflict with KRUDP: Similarly, as highlighted by the conflict with the Regional Spatial

Strategy, the negative impact of the removal of Everton Football Club and their Premier

League stadium on North Liverpool and Liverpool [as the designated Regional Centre]

is not in accordance with the following policies;

45.0 Policy S1 - states that proposals for retail development and other town centre uses

must protect or enhance the vitality and viability of existing town centres

46.0 Policy S2 - allows development within town centres for (amongst others) D2 (Assembly

and Leisure). But only if the proposals are, and I quote, “compatible with the scale and role of

the town centre and would not harm the retail function or the character of the centre, would not

have detrimental impacts on amenity or environment and would not exacerbate parking or traffic

problems.”

47.0 Policy S4 - states that ‘Kirkby town centre is designated on the Proposals Map as an

Action Area within which comprehensive development or redevelopment shall be permitted.'

The proposed stadium would be built on 'Urban Green Space and Educational Land’ South of

Cherryfield Drive and not within the designated action area map.

48.0 Policy OS2 - there is a presumption within this policy against comprehensive new

development on land designated as “Urban Green Space and / or Educational Land”

49.0 For the reasons set out above, the proposed removal of Everton Football Club from

North Liverpool is not in accordance with the Knowsley MBC Local Development Plan

(recently approved RSS and KRUDP (2006), as it would undermine the vitality and

viability of North Liverpool/Liverpool City Centre and the claimed material
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considerations/benefits of a stadium sited on the edge of Kirkby town centre by the

applicant, are outweighed by diverse and direct conflicts with Development Plan Policy.

Conflict with PPS 6: Planning for Town Centres.

50.0 Paragraph 2.41 of PPS6 states: ‘In selecting suitable sites for development, local

planning authorities should ensure that the scale of opportunities identified are directly

related to the role and function of the centre and its catchment. Uses, which attract a

large number of people, should therefore be located in centres that reflect the scale and

the catchment of the development proposed. The scale of development should relate to

the role and function of the centre within the wider hierarchy and the catchment served.

The aim should be to locate the appropriate type of development in the right type of

centre, to ensure that it fits into that centre and that its complements its role and

function.’ Clearly, a Premier League Football Club and a 50,000 capacity stadium has

no relation to a township of the size of Kirkby , with a population of just over 40,000,

with it’s infrastructure, role and function of Kirkby.

51.0 Paragraph 2.42 of PPS6 - continues ‘…local centres will generally be inappropriate

locations for large-scale new development.’ Obviously, a Premier League Football Club and a

50,000 capacity stadium would significantly change the role and function of Kirkby. Again, due to

the Tesco proposal being promoted not through the Development Plan process but through a

planning application, this is in conflict with both the Regional Spatial Strategy and also PPS6.

52.0 Notwithstanding claims to the contrary Paragraph 2.10 of PPS6 – ‘…any significant

change in role or function of centres, upward or downward, should come through the

development plan process, rather than through planning applications. Changes to the status of

existing centres or the identification of new centres that are of more than local importance

should be addressed initially at the regional level through regional spatial strategies.’

53.0 In conclusion, the proposed stadium on an out-of-centre Kirkby site does not accord

and is in conflict with the Local Development Plan (approved RSS (CD 2.2a) and adopted

KRUDP (CD 3.1) for Knowsley.
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All other material considerations / benefits considered relevant to the proposed removal

of Everton Football Club from Walton/Liverpool and its relocation to an out-of-centre Kirkby site,

are outweighed by the detrimental impact on Walton/Liverpool and the conflicts with

Development Plan Policy.

54.0 The scale and function of the proposed stadium is inappropriate and disproportionate to

the role and function of Kirkby in the Regional Spatial Framework.

55.0 As there can be no doubt that a proposal to develop a 50,000 capacity stadium to

house a Premier League Club in Kirkby would change the role, status and function of the town

as set out in the RSS, and as such should have come through the development plan process,

rather than through a planning application, the proposed stadium is also in conflict with

significant policies of PPS6.

As a result, the Secretary of State is requested to refuse the application.

56.0 In closing the Keep Everton In Our City campaign group would like to thank the

planning inspectors and the officials at the inquiry for their support, assistance and courtesy

shown to our group throughout this inquiry.