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KEIOC’s Position Explained
The Keep Everton In Our City campaign group, formed in early 2007 by a concerned and disillusioned
faction of matchgoing Evertonians who had sat through and watched as the debacles of the Kings Dock, NTL
and Fortress Sports Fund schemes unravelled before them, has evolved significantly since those early days
but has steadfastly stood by their initial concerns:

• That the club’s involvement in a development scheme, that was so clearly against local, regional and
national planning policy, represented a significant risk to the future aspirations of the club.

• That due to these departures, the Secretary of State would call in the planning application.

• That the finances surrounding the then £150M stadium appeared flawed.

• That the signing of an exclusivity deal effectively prevented the emergence of alternative proposals.

• That many identifiable matchgoing Evertonians were being excluded from the then proposed ballot.

Today, initial concerns well founded, supporters of KEIOC are embroiled in a public inquiry (1) into a
development that is 320% greater than that allowed for the whole of Knowsley under current planning
policies (2); the stadium, now valued at £130M (3), continues to baffle the collective minds of those QC’s at
the inquiry that are attempting to understand firstly Everton’s ability to generate their £78M contribution (4)
and, secondly, exactly where Tesco’s £52M contribution is actually coming from (5).

A cursory look at the quality and sheer quantity of evidence presented to the public inquiry by KEIOC (6)
gives an indication that the group are perhaps something more than an Everton supporting collection of
fanatical, passionate and emotional butchers, bakers and candlestick makers. Within their rank and file they
can call on solicitors, barristers, engineers, architects, councillors, council officers, planners, Members of
Parliament and transport experts to name but a few. Remarkably, this group, from such a diverse
background, sit comfortably together due to their belief in a common cause; simply that Everton do not
belong in Kirkby.

The campaign to date, funded through donations from matchgoing Evertonians, has seen planes flying over
Goodison, leafleting, billboard advertising, funding and support for the establishment of a political party, the
lobbying of shareholders, bringing together the two shareholders associations at meetings and, most
recently, funding and conducting the campaign to deliver an EGM on the question of Kirkby.

To some, KEIOC represents a so called luddites view, a group opposed to change and in favour of
maintaining the status quo; the reality couldn’t be different; supporters of KEIOC embrace evolutionary and
revolutionary concepts to advance the club, and today they are just as capable of discussing the nuances of
the Regional Spatial Strategy, Unitary Development Plans and elements of the North West Retail Hierarchy
as they are debating what Arteta’s best position is or whom David Moyes should play in the back four.
KEIOC’s Position Explained

At the inquiry KEIOC supporters happily discuss matters with Everton’s acting CEO, Robert Elstone, for
whom they have a healthy respect. KEIOC’s argument isn’t with individuals within the club it’s simply a
difference of opinion as to what is best for the future prosperity of the club and, importantly, its supporters.

At this moment, there are essentially two major aims to the KEIOC campaign. Firstly, preventing the
relocation of the club to Kirkby and secondly the promotion of two specific sites, within Liverpool, that KEIOC
believe will enable Everton to progress as a major premiership club.

There appears to be quite a lot of confusion surrounding the first aim; for KEIOC it’s not simply an emotional
objection to Everton setting up home outside the City of Liverpool; save for some arbitrary civic boundary
Kirkby is, after all, as much a part of Liverpool as Walton or Anfield. The primary objection surrounds the
business case put forward by the club, the secondary objection concerns the future consequences for the
club and its supporters and the tertiary objection involves the ability of the proposed stadium to deliver what
is required for a top-flight premiership club.

Kirkby is in desperate need of appropriate regeneration yet many, even within Kirkby, are oblivious to the
sheer scale of what is being proposed by the proponents. This retail development is half the size of the
Trafford Centre and the Liverpool One developments and, due to this, comes into conflict with a whole host
of local, regional and national planning policies, hence the objections from all neighbouring authorities.

KEIOC’s case against Kirkby is that readily available evidence would appear to indicate that the stadium
would simply fail to deliver not only what was promised to the supporters in 2007 but also those revenue
streams, estimated by Deloitte (7), that are essential for the future viability of the club. The following points
should not be considered in isolation as representing a killer blow to the stadium project, their impact is
derived from their collective application:

• Everton already know that at least 40% of their fanbase are against this relocation.

• Everton’s business plan for the new stadium is heavily reliant on increasing the average attendance
level to 47,000, yet they have failed to survey their supporters on their views now that the truth is
known about the stadium being only mid-range at best, the emergence of significant concerns over
the transport plans and confirmation that the move will fail to generate £10M per season for the
manager as promised by Keith Wyness (8).

• Everton cannot demonstrate a need for a 50,000-seat stadium in Kirkby; last season Everton’s
average attendance was 37,000 (9) and, unlike those clubs considering relocation or having
relocated, Everton does not have a season ticket waiting list. That LFC and Spurs can demonstrate
substantial waiting lists would appear to indicate that they would easily fill their proposed stadia. (10)
KEIOC’s Position Explained
• Information provided by Deloitte (9) appears to indicate that the vast majority of new stadia are ill
conceived and fail to live up to expectations, as can be seen below:

Average Number of Unsold Seats at Matches During Season
18,000 Old Stadia New Stadia









Source Deloitte 2008

The only new stadia that function near capacity are those of Arsenal and Reading. One of the
reasons behind this is that both clubs built stadia of a size appropriate to their need; Arsenal, with
near maximum attendance levels at Highbury and with a 20,000 season ticket waiting list built a
60,000-seat stadium and Reading, located in a small town, built a 24,000-seat stadium. At the other
end of the spectrum is Sunderland; having built a 49,000-seat stadium they have, according to
Deloitte, over 16,000 empty seats at every game. An investigation into attendance levels at all new
stadia built since 1994 reveals that average attendances, at those stadia, represent 77% of capacity
(11). Deloitte issue a warning over getting this wrong in their letter concerning the Everton move (7).

• The transport plan is fraught with difficulty. The transport infrastructure of a town of 40,000 is ill
equipped to accommodate a temporary surge in use by an additional 30,000 to 50,000 visitors. In
the absence of any tangible improvements to that infrastructure, a reluctance by Knowsley Council to
accommodate additional vehicles in the town and a national policy to discourage car journeys, a
range of measures, that have been described by the applicants transport expert as “trailblazing” and
“not used by any other football club”, will be put in place to manage visitors to the Kirkby stadium. A
two-mile car exclusion zone, extending beyond Kirkby, will be in operation around the stadium on
matchdays which means that, in the absence of any third party car parks and the council prohibiting
parking on any school or council property, the anticipated 24,000 supporters arriving by car (12) will
have to make use of the park & walk and park & ride facilities, some supporters will have to endure a
forty-five minute walk. Those 4,300 (13) travelling by train back to Liverpool will have to tolerate
being held in “queuing reservoirs” by officials for up to 90 minutes and the prospect of being “crush
loaded” (14) onto trains due to the single track configuration which allows only one train every fifteen
KEIOC’s Position Explained
minutes (15). Whilst the arrival of supporters can be somewhat self-determined and staggered, the
departure will be as a collective mass and this is where, due to the volume of supporters moving
mainly in one direction, towards Liverpool and beyond, dissatisfaction with the chosen location will

• The failure, by Everton, to promote public transport in preference to car use will result in a reduction
of capacity from 50,000 to 40,000 (16). The current car use by Evertonians has been calculated at
72%, the target reduction is 55% by season three or the cap will be come into force.

• As can be seen below this planned relocation will take Everton further away from the local
conurbation than any other premiership club. Kirkby is 9 miles from Liverpool City centre; the
average distance for a premiership club being 2.6 miles (17)

Distance from Major Centre
Kirkby 9 Charlton
Bolton 8 New castle
Everton 6 Sheffield Utd
Liverpool 3 Tottenham Hotspur
Aston Villa 1 Watford

Reading Portsmouth

Man Utd Middlesbrough

Man City Wigan
Blackburn Chelsea
West Ham Fulham

Source: RAC Distance From Stadium to Local Centre

• The finances behind the proposed move, even after Everton and Tesco had presented their evidence
at the inquiry, remain unclear and as confusing as ever. Everton failed to supply any firm detail in
support of their finance options (18), citing commercial sensitivities. Equally, Tesco were unable to
explain the origin of the £52m subsidy (19). KEIOC’s case has always been that Everton are
essentially getting what they’re paying for, save for a £10m grant from the NWDA, applied for by
Tesco, and a possible, but not stated, construction discount benefit from their association with Tesco.
In our opinion the increase from an £90m cost (20) to a £130m value is derived from the increased
value of the land if planning permission were to be granted.

• The restrictions already placed upon the stadium will limit the opportunities for Everton to generate
non-football revenue. Knowsley Council will have free use of the facility on 100 occasions throughout
KEIOC’s Position Explained
the year, almost a third of the year, and the council have already stipulated that no music concerts
will be allowed.

As previously described, it is the collective effect of the aforementioned concerns that KEIOC are highlighting
as potential dangers to the future well being of Everton Football Club. KEIOC’s case against the proposed
relocation of Everton Football Club to Kirkby can be encapsulated in the following statement:

“KEIOC’s initial concerns, surrounding the pursuit of a stadium development that appeared too good
to be true, the financing of which appeared flawed and the development of which represented such a
significant departure from current planning policies that the secretary of state would jeopardize the
project by calling in the application, were all proven to be legitimate. The fans have now seen that
the stadium is far from effectively free, will not generate £10m a season for the manager and the
public inquiry has been sitting since November.

It may well be the case, as some believe, that a new stadium for £80m still represents value for
money and in the absence of any viable alternative represents Everton’s only option. However, such
a stadium in a location that fails to attract the level of interest from fans, the corporate hospitality
sector and the conference and banqueting market is of little use as a revenue generator or as an aid
to the future aspirations of a top flight premiership club.

Using known factors such as the 40% opposition to the move, trailblazing transport and travel
restrictions, limitations on use of the stadium already in place and research using data provided by
Deloitte, KEIOC predict that attendance levels, once the new stadium effect has subsided, will be in
the region of 38,000 and that the financial benefit of relocation will be negated. Some, not all, of
these problems may be addressed through the implementation of an aggressive marketing and
discounting policy, but this again will reduce the level of contribution for on pitch activities and
KEIOC believe that the collective impact of these factors will prove to be overwhelming.

Irrespective of the arguments for and against the relocation, there remains the presence of a £52m
cross-subsidy from Tesco that for many is the decisive factor in accepting the move. KEIOC aren’t
expecting to see Sir Terry Leahy presenting Bill Kenwright with a giant cheque for £52m on the pitch
at Goodison any time soon. Despite the best endeavours by top QC’s at the inquiry to get to the
bottom of where this £52m is coming from, the confusion between cost and value remains. KEIOC
believe the explanation has always been in the public realm. In 2007, in response to claims by
Everton directors that Everton were to receive £50m (sic) from Tesco, Mr Tony Fletcher of Tesco
stated "Reports in a number of news outlets today have stated that Tesco will fund £50m towards the
cost of a new stadium for Everton FC. Tesco wish to point out that the intention would be for the
proposed stadium funding package to be derived from the value generated by the overall retail led
development scheme not as a result of direct funding from Tesco.” KEIOC maintain that the
stadium’s cost and value are separate issues.”
KEIOC’s Position Explained

Whether the application is approved or declined KEIOC’s position and resolve will remain the same. If
approved, the pressure will be on for Everton to finance the construction cost and it has been admitted
during the inquiry that Everton have, to date, no finance available from their stated option list (21). If the
application is declined the pressure will be on Everton to develop an alternative plan, either a redeveloped
Goodison or a new build on another site.

Whilst Everton have been restricted under the terms of their exclusivity agreement with Tesco and Knowsley
Council, KEIOC have persevered with building good relationships with Liverpool City Council and the owners
of the land, known as the loop site, on Scotland Rd.

During many meetings with the leader of the Council and his opposite number in the Labour group, the
councillors have repeatedly confirmed that they would be prepared to assist Everton to redevelop Goodison
or develop the Scotland Rd site; in fact this assistance is a matter of public record under Council resolution
538 (22). These leaders have spoken at KEIOC meetings and have been encouraged by KEIOC to speak at
Council planning meetings and the 2008 EGM held at Goodison where Warren Bradley questioned Everton’s
version of events surrounding working with the Council and Joe Anderson delivered a rousing speech in
favour of a redeveloped Goodison Park that was well received by the vast majority of people in the room on
the night (23).

KEIOC has encouraged the owner of the Scotland Rd loop site (24) to maintain interest in the possibility of
developing the site with Everton and the Council. Everton’s insistence that a retail enabling development of
500,000 sq feet, the size of Destination Kirkby, is the only method of financing available to deliver a football
stadium is, in the opinion of KEIOC, little more than a device to prevent meaningful discussions taking place;
this size of retail would never receive planning permission in Liverpool so another plan, more applicable and
suitable to a top flight football club should be developed as a matter of urgency.

To secure a new or redeveloped stadium KEIOC advocate the use of established yet innovative financing
methods coupled with the appropriate options already highlighted by Everton. The use of asset disposal,
stadium naming rights, syndicated debt finance and equity funding could be utilised in conjunction with
funding from Equity Seat Right (25), a product that has been used in the United States to finance the
complete construction cost of stadia without placing debt on the club, and, in line with the people’s club ethic,
a supporters trust (26) should be established to finance a specific section of the stadium.

KEIOC have continued to campaign for an affordable stadium, in a suitable location that is acceptable to the
supporters and one that will provide the maximum opportunity for Everton Football Club to generate the
revenue streams essential for success in the premier league. KEIOC believe that two locations meet these
criteria and the criteria laid down by the club, namely that any site must be available, suitable, viable,
KEIOC’s Position Explained
accessible and deliverable. KEIOC would add sustainable to this list, as long-term success of the location is

With the aforementioned in mind KEIOC propose that the two sites for consideration should be Goodison
Park and the Scotland Road Loop Site. Whilst both have their individual challenges, physical and financial,
both could meet the future needs of Everton Football Club.

KEIOC’s support for these sites can be condensed into the following statement:

“As an alternative to Destination Kirkby KEIOC support the phased redevelopment of Goodison Park
or the relocation to a site on Scotland Road. Both sites have advantages and disadvantages yet both
meet the qualifying criteria by being acceptable, available, suitable, viable, accessible, deliverable
and sustainable.

Whilst construction difficulties and land requirements can all be solved through cooperation with
engineers, architects and the council, the financing behind these schemes remains the greatest

A suitable method of financing the construction costs must be identified. In addition to established
methods identified by the club, KEIOC advocate the establishment of a supporters trust to provide
capital for the construction of a section of the stadium and the use of an innovative American
financial product known as Equity Seat Right (ESR) to provide the main element of the financial
package; this methodology has the desirable effect of placing no additional debt on the club. The
negative effect of some loss of income due to the use of ESR can be offset by increased income
derived from enhanced onsite hotel, conference, banqueting and leisure facilities.

The redevelopment of Goodison Park would see the fusion of the historic elements of Goodison, the
first purpose built football stadium in England, with modern facilities offering unobstructed views,
wide concourses and first class corporate facilities. The addition, at the Park end, of a hotel complex
enhances the stadiums ability to attract non-matchday events.

A stadium on the Scotland Road site would be of an iconic and futuristic design suitable to take
Everton into an exciting future. Incorporating features such as a sliding roof and sliding pitch
technology, a twenty-five-story apartment, hotel, conference and banqueting complex, including
additional restaurant and leisure facilities, means that this stadium would enable Everton to derive
the maximum additional revenue from non-matchday events. Its close proximity to Liverpool’s City
centre ensures transport and parking requirements are more than adequately met and will be an aid
to the securing major events such as concerts, conferences, exhibitions and trade shows. KEIOC
will shortly release a 3D fly by animation by Black Widow Internet promoting the Fusion & Vision
aspects of what could be achieved at both sites.
KEIOC’s Position Explained

Whichever way the decision on the public inquiry is given, it may well be the case that Everton need to have
a deliverable contingency plan in place. It would be advantageous if that plan promoted a scheme that the
vast majority of Evertonians could embrace.


(1) Source: The Secretary of State - The public inquiry was announced in August 2008, it began in
November 2008.

(2) Source: KMBC - The Knowsley
UDP allows for 9,000 sq m of supermarket space and an additional 7,000 sq m of additional
comparison (non-food) retail, throughout the borough of Knowsley. Tesco have applied for
50,000 sq m in Kirkby alone

(3) Source: DTZ - In 2007,
Both Keith Wyness and Sir Terry Leahy repeatedly told the fans that the stadium was worth
£150m, when the DTZ, (KEIOC, Proof of Evidence, Appendix 5), report emerged as part of the
planning application it became a £130m stadium, possibly due to the reduction in capacity or
Everton’s ability to only raise £80m.

(4) Source: DTZ - £78m is
listed in the DTZ report and in Robert Elstone’s proof of evidence as Everton’s current
contribution towards the cost of the stadium, the public inquiry has added £6m to the cost of the
stadium but neither Everton nor Tesco will explain who is going to pay for this.

(5) Source: Tesco leave the inquiry baffled as to the origin of the £52m

(6) Source:

(7) Source: Deloitte - “New stadiums are not always successful; this is emphasised by the range of
increased turnover from 19 per cent at Stoke City to 146 per cent at Middlesbrough. Deloitte
warns that the 'new stadium effect' can quickly erode after one season, particularly if the club's
performance on the pitch fails to live up to the expectations of its recent converts. In such cases,
the 'feel good' factor associated with the move to a new stadium is quickly lost. Investment in the
stadium has to be matched by investment in the team.” – Deloitte – August 2007
KEIOC’s Position Explained

(8) Source: Keith Wyness -

(9) Source: Deloitte – Annual Review of Football Finance –May 2008

(10) Source - KEIOC cross-examination of Robert Elstone at the public inquiry: Day
10. “Other clubs have elected to follow the relocation route in a bid to increase their stadium
derived revenue, Arsenal have already relocated to a 60,000 seat stadium Ashburton Grove,
around the corner from their traditional Highbury home, Tottenham are building a 60,000 seat
stadium next door to White Hart Lane, West Ham are hoping to relocate to a new ground in the
east end of London and our nearest and dearest “across the park” Liverpool are attempting to
build a 60,000 seat stadium in Stanley Park next to their ground at Anfield. Can you tell me what
was Arsenals season ticket waiting list before their move? It was twenty thousand. What is
Tottenham’s waiting list? It’s twenty two thousand. What’s West Ham’s? It’s 8,000 and, finally,
have you any idea what Liverpool’s is? It’s 65,000. Could you tell me what Everton’s season
ticket waiting list is? None”

(11) Source: KEIOC and the Deloitte Annual Review of Football Finance (9)

(12) Source: applicants transport planners Steers Davies Gleave.

(13) Source: applicants transport planners Steers Davies Gleave

(14) Source: applicants transport planners Steers Davies Gleave

(15) Source: applicants transport planners Steers Davies Gleave

(16) Source:

(17) Source: KEIOC and an investigation using data provided by the RAC.

(18) Source: Robert Elstone’s Proof of Evidence:

(19) Source: The Public Inquiry -
KEIOC’s Position Explained
(20) Source: DTZ Report -

(21) Source: KEIOC Cross-examination of Robert Elstone Day 10

(22) Source: KEIOC -,cntnt01,detail,0&cntnt01articleid=19&cntnt01datefor

(23) Source: KEIOC -

(24) Bestway Holdings Ltd, 2, Abbey Rd, Park Royal, London. NW10 7BW

(25) Source: Stadium Capital Finance Group.

(26) Source: Supporters Direct