Town And Country Planning (inquiries Procedure) (england) Rules 2000 Keep

TOWN AND COUNTRY PLANNING (INQUIRIES PROCEDURE) (ENGLAND) RULES 2000 KEEP EVERTON IN OUR CITY

APPLICATION BY TESCO STORES LTD FOR MIXED USE DEVELOPMENT, INCLUDING NEW FOOTBALL STADIUM, CONVENIENCE AND COMPARISON RETAIL, RESIDENTIAL AND LEISURE USES, KIRKBY TOWN CENTRE AND LAND TO THE SOUTH OF CHERRYFIELD DRIVE, KIRKBY PLANNING APPLICATION: 08/00001/HYB PLANNING INSPECTORATE Ref: APP/V4305/V/08/1203375

STATEMENT OF KEIOC

1. Introduction

1.1 This short statement from KEIOC briefly outlines the group's case in respect of the above application and subsequent call in by the Secretary of State. The statement addresses the key matters as outlined in the Secretary of State's call in letter to Knowsley Council dated 6th August 2008.

1.2 This statement is produced in response to the Inspector's request to ensure the

smooth running of the inquiry. A full detailed proof will be submitted by the 18th of December 2008.

1.3 The statement also lists some of the people KEIOC would wish to cross examine and outlines some of the key material that will be called on. 2. Secretary of State Questions 2.2 In respect of a number of questions asked by the Secretary of State, KEIOC sets out a short summary of the evidence it intends to produce. Whether there are any more central sites capable of accommodating the proposed development as a whole or in disaggregated form:

The applicants Tesco/Everton have failed to adequately demonstrate that alternative sites are available and viable for a new stadium to house Everton FC while at the same time they fail to demonstrate that their existing home (Goodison Park) can be re-modelled to meet modern day requirements. The application also fails to look at alternative funding methods for stadia which could be applied to the numerous sites detailed in the application. Whether the application would deliver a sustainable form of development, as outlined in PPS1: Delivering Sustainable Development, and respect the need for appropriate standards of design in relation to the individual elements of the scheme, and the spatial relationship between the different components of the development; KEIOC feel that the design of the proposed stadium and surrounding area fails to meet the design requirements as set out in PPS1: Delivering Sustainable Development. Whether the application promotes sustainable transport choices and reduces the need to travel by private transport as identified in PPG 13: Transport; KEIOC feel that the application fails to adequately promote sustainable transport choices as the transport plan is deeply flawed in relation to stadium spectators' travel patterns. Also a development of this size will not reduce the need to travel. Any other relevant matters; As a group KEIOC feel the financial information used throughout the application in relation to Everton FC is deeply flawed and has a fundamental effect on the deliverability of the project. The group also has serious concerns with the ballot results of Everton FC’s proposed stadium move that is referred to in the application on a number of instances. 3 KEIOC Proof 3.1 It is proposed the following issues will make up KEIOC main evidence to be presented at the inquiry. • • • •

•

Alternative Sites for the proposed Stadium; Transport Issues Specific to the Stadium; The Design of the Stadium; The Finances of Everton FC as detailed in the planning application The 2007 Ground Move Ballot conducted by the Electoral Reform Services on behalf of Everton FC.

3.2 The case against the application will be outlined in full through KEIOC proof and at the public inquiry.

4. Cross-examination 4.1 KEIOC are proposing to cross-examine a number of parties in relation to the application. It is proposed the following will be called up for cross-examination: • • • • •

Chris Potts Robert Elstone David Kierle Joe Ellis Philip Sapiro

4.2 KEIOC reserves the right to cross-examine any other interested parties at the appropriate time 5. Relevant Documents 5.1 We will rely on the following: • •

• • • •

• • • •

HOK Report relating to Loop Site CABE Design Review Response Planning Policy Statement 1: Delivering Sustainable Development Liverpool Unitary Development Plan November 2002 Croke Park interview Belfast City Stadium report 2008 EGM transcript Wigan programme last season (Keith Wyness Q and A) Robert Earl's interview in the Liverpool Echo Liverpool City Council Resolution 538

5.2 As necessary, KEIOC reserves the right to refer to and produce any other relevant documents, in addition to those set out above, within its evidence.