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Inquiry Reports

Wednesday, February 4, 2009

Day 35 – The day KEIOC had been patiently waiting for


Before and throughout the inquiry KEIOC had been taking advice from a barrister. It had been explained that the importance of the summing up document, on which the planning inspectors would base their report, could not be over estimated.

The day had arrived when the Keep Everton In Our City pressure group could speak without interruption, when the proponents of this scheme would have to sit and listen to the many reasons why this proposal was an inappropriate gamble for Everton Football Club to take, and when Evertonians everywhere could listen to the facts and not the spin and misinformation.

Mr. Tom Norman presented the closing arguments for the Kirkby Traders Association; you can read Tom's closing argument here.

Mr. Peter Fisher presented the closing arguments for the Knowsley Constituency Liberal Democrats; you can read Peter's argument here.

Mr. Colin Fitzpatrick presented the closing arguments for KEIOC:

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

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.

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

In addition to these departures KEIOC are of the opinion that Everton has failed to demonstrate a physical need for a 50,000-seat stadium in Kirkby 2 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.

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.

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.

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 overestimated.

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.

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:

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.

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

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

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.

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.

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.


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.

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.

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 site13 coupled with direct road, rail and bus links to Wirral and beyond.

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

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.

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.

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.

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 track17, 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.

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 applicant19 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?
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)

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.
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?
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.
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, 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.
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.
When Headbolt Lane railway station in Kirkby is built, the time available to load up to 960 people onto the train will reduce25. 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.

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 inspector to afford these surveys no weight when writing the inquiry report for the secretary of state.

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.

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.

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 Everton's financial information unless they provide indisputable proof of their ability to generate this £80m contribution.

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.

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.

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.

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
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

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.

Unlike Everton, KEIOC has attempted to substantiate their alternative funding proposals for a redeveloped Goodison or at the site in Scotland Rd31. 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 £200m32 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.

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.

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 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


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.

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.


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 meet the local needs of Kirkby and is therefore not in accordance with Policy LCR3 of the RSS.

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;

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

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.”

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.

Policy OS2 - there is a presumption within this policy against comprehensive new development on land designated as “Urban Green Space and / or Educational Land”

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 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.

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.

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.

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.'

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.

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.

The scale and function of the proposed stadium is inappropriate and disproportionate to the role and function of Kirkby in the Regional Spatial Framework.

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.

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.

Mr. Tony Barton presented the closing arguments for Kirkby Residents Action Group (KRAG); you can read Tony's closing argument here.

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