Statement (2 of 2) to Liverpool Local Plan Examination by Save Sefton Park Meadows Campaign Group

Matter 4 - Kenneth Aspinall

Matter 4: Green Belt, green infrastructure and open spaces

Issue 3: Are the Plan’s policies in relation to Open Spaces justified, effective and consistent with national policy?

Q4.9 Having regard to Paragraph 73 of NPPF2012 is there an up-to-date open space study / assessment that confirms the proposed extent of the open space designation on the Policies Map? Does Document CD16 – Open Spaces Review Report 2017 - fulfil this function?

Answer. Document CD16 – Open Spaces Review Report 2017 does fulfil this function. However, the Save Sefton Park Meadows (SSPM) campaign group strongly assert that Sefton Park Meadows should not be designated as ‘Amenity Greenspace’ in the LCC Open Space Assessment Report & Standards – April 2017, pages 40 to 43, Site I.D. 345, Site Name – Land between Mossley Hill Drive / Aighburth Vale, Low Quality score, High Value score, when it should rightly be designated as a Park in Part 4: Parks & Gardens in that document as it is an integral part of Sefton Park, and as previously designated in the 2005 Open Space Study. See answer to Q4.12 below for details.

Note – The Open Space Assessment Report & Standards – April 2017 was not published for public reference until January 2018. The quality/value of a Green Space/Open Space can be subjective. There has been no consultation opportunity for members of the public to make representation about, or provide input to, the LCC Open Space Assessment Report & Standards – April 2017, until it was published in January 2018 as a Supporting Document to the Liverpool Local Plan 2013 -2033 Pre-submission draft January 2018.

Q4.11 Since plan submission, are there any factual amendments needed to the open space designation on the Policies Map?

Answer. Sefton Park Meadows are currently shaded green, designated as Open Space on the Liverpool Plan 2013 -2033 Policies Map, when it should in addition have diagonal red hatching designating Local Wildlife Site as is the rest of Sefton Park designated together with ‘H’ for Historic Park, as Sefton Park Meadows are an integral part of Sefton Park.

In the Liverpool Open Space Study Volume 1: Strategic Open Space Assessment Final Report November 2005 by Atkins Consultants, Sefton Park Meadows are clearly identified on 7 detailed maps at the end of that document as an integral part of Sefton Park which is designated as a City Park of High Quality/High Value.

We have a copy of a Liverpool City Council map, dated April 2004, which delineate Liverpool’s English Heritage Registered Parks. The Sefton Park boundary shown incorporates Sefton Park Meadows.

Figure 1 in the Strategy Topic Paper [CD20.4] referred to in MIQs Q2.3 clearly shows Sefton Park Meadows as Open Space integral with Sefton Park.

We have a copy of the Land Registry Official copy of Register of Title number MS544423, Edition date 19.11.2013, including a map of Sefton Park Meadows, which states – 1. The Freehold land shown edged with red on the plan of the above title filed at the Registry and being Sefton Park, Liverpool.

Q4.12 Is the submitted plan sound in identifying Sefton Park Meadows as open space under Policies GI1 and GI3?

Answer. The submitted plan would be sound in identifying Sefton Park Meadows as open space under Policies GI1 and GI3 if it actually clearly did that. However, Sefton Park Meadows are not named anywhere in the Liverpool Local Plan Pre-submission draft, January 2018.

The map key of the Local Plan Policies Map designates Sefton Park Meadows only by green shading as ‘Open Space (Policies GI1 & GI3)’ and shows it integral to Sefton Park. It is not labelled as ‘Sefton Park Meadows’ on the Local Plan Policies Map. Therefore, the Local Plan is not sound.

The following information will detail why and how Sefton Park Meadows should be identified in the Local Plan, on the Local Plan Policies Map, in the Sustainability Appraisal document CD8.1 and in the LCC Open Space Assessment Report & Standards – April 2017 document CD16.

We, the Sefton park Meadows Campaign Group query why the Inspector is asking this leading question now? Why is Sefton Park Meadows the only site in the Local Plan being singled out for this scrutiny? What is the motive? Has the Inspector ever visited Sefton Park Meadows? Is the Inspector aware of the last 7 years Save Sefton Park Meadows campaign?

Local Plan Representations submitted by the Save Sefton Park Meadows Campaign Group in February/March 2018, Unique reference SLP8 (plus Unique references SLP115, 196, 202, 205, 219, 230, 21, 234, 112, 113, 13, 114, 31, and 22) have irrefutably proved that Sefton Park Meadows have always been an integral part of Sefton Park, confirmed by Land Registry Title Deeds documents, Liverpool City Council Park Bye-Laws and Council maps and Sefton Park Meadows are within the Sefton Park Conservation Area and significant setting of Grade I designated Sefton Park.

In January 2020, Liverpool Mayor Anderson announced Liverpool’s parks could be put in trust, as a Fields in Trust Deed of Dedication that will protect our parks for future

2 generations. The Fields in Trust partnership will now go ahead and the first ten large parks will go into trust followed by more some months later. Which will protect Sefton Park Meadows from any development as it is an integral part of Sefton Park.

NPPF2012 paragraph 157. States ‘Crucially, Local Plans should:

●identify land where development would be inappropriate, for instance because of its environmental or historic significance;’

During the Liverpool Local Plan Initial Consultation - Dec 2013 - March 2014 and the Draft Liverpool Local Plan Consultation September/October 2016, Call For Sites Forms were issued stating the Local Plan would allocate sites for development, and identify land to be protected from development. If you wished to propose a site to be allocated for a particular type of development OR a site to be protected from development, these Forms were to be used.

In 2014 and 2016 numerous Save Sefton Park Meadows Campaign Group members and supporters submitted those Forms to the Consultations calling for Sefton Park Meadows to be protected from development.

We note from the Sustainability Appraisal incorporating Equality Impact Assessment and Health Impact Assessment of the Submission Draft Liverpool Local Plan, Appendices, Final Report, January 2018 [CD8.1], Appendix 4, Maps, Figure 2: Proposed Site Allocations, Figure 3: Alternative Residential Site Allocations Proposed by Landowners / Developers and Figure 4: Proposed Site Allocations- Residential, that Sefton Park Meadows are not identified on any of those three maps.

Therefore, in recognition of the large number of Save Sefton Park Meadows Campaign Group members and supporters who submitted Call For Sites Forms to the 2014 and 2016 Local Plan Consultations calling for Sefton Park Meadows to be protected from development, there should be a map in Appendix 4 of the above Sustainability Appraisal document to clearly identify Sefton Park Meadows as being a site Protected From Development to comply with NPPF2012 paragraphs 150 and 157. In addition this fact should be recorded in the Liverpool Local Plan.

150. Local Plans are the key to delivering sustainable development that reflects the vision and aspirations of local communities.

157. Crucially, Local Plans should:  identify land where development would be inappropriate, for instance because of its environmental or historic significance;

Sefton Park Meadows should be designated in the Local Plan as Local Green Space as it fulfils all the criteria of NPPF1012 Paragraphs 76 and 77.

LCC Open Space Assessment Report & Standards – April 2017 (Page 28/129) Note – The Open Space Assessment Report & Standards – April 2017 was not published for public reference until January 2018. The quality/value of a Green Space/Open Space can be subjective. There has been no consultation opportunity for members of the public to make representation about, or provide input to, the LCC Open Space Assessment Report & Standards – April 2017, until it was published in January 2018 as a Supporting Document to the Liverpool Local Plan 2013 -2033 Pre-submission draft January 2018.

Paragraph 86 states -

86. At the time of the survey some Friends of Parks groups were concerned about the potential sale or part sale of parks and open spaces. The topic was also noted in the returns from the Parks and Green Space Survey. Since the surveys were undertaken, the City Council has made it clear that Parks will not be subject to development.

The 30 page Council & Cabinet Report No. EDR/80/17, January 2018, introducing the Liverpool Local Plan Pre-Submission Draft has several references stating ‘Greenfield sites are not currently needed to meet the housing requirement’, ‘the Local Plan is able to meet the requirement without the need to review the provision of designated open or green space’ and ‘There is no need to allocate open space to meet the City’s housing requirement.’

The Save Sefton Park Meadows (SSPM) campaign group strongly assert that Sefton Park Meadows should not be designated as ‘Amenity Greenspace’ in the LCC Open Space Assessment Report & Standards – April 2017, when it should rightly be designated as a Park in Part 4: Parks & Gardens in that document and as previously designated in the 2005 Open Space Study.

Sefton Park Meadows are currently shaded green, designated as Open Space on the Liverpool Plan 2013 -2033 Policies Map, when it should in addition have diagonal red hatching designating Local Wildlife Site as is the rest of Sefton Park designated, together with ‘H’ for Historic Park, as Sefton Park Meadows are an integral part of Sefton Park.

We have a copy of a Liverpool City Council map, dated April 2004, which delineate Liverpool’s English Heritage Registered Parks. The Sefton Park boundary shown incorporates Sefton Park Meadows.

The English Heritage 2013 map and Historic England 2015 map delineate Grade I Registered Sefton Park but these maps exclude Sefton Park Meadows. We deem this to be incorrect as we understand the Sefton Park boundary as shown on these maps relate to the area of Sefton Park that was included in the 2006 £6.6 million Heritage Lottery Fund grant.

As Sefton Park Meadows did not form part of the grant application restoration area, because restoration was not deemed necessary at Sefton Park Meadows as this land did not have any water courses needing repair and the features of Sefton Park Meadows remained true to the original design of Sefton Park, for expediency and/or in error it was not included on those maps. We have challenged English Heritage and continue to challenge Historic England on this obvious error.

The Strategic Green and Open Spaces Review Board (SGOSRB) Final Report 2016 Sections 4. Health & Wellbeing and Section 5. Environmental Factors make an irrefutable case for not building on public green spaces such as Sefton Park Meadows. The SGOSRB Chair’s Comments on pages 78 to 81 and Concluding Thoughts on pages 121 to 123 of the SGOSRB Final Report confirm that the temptation to sell off Parks and public green spaces is folly, there will never be an excuse for building on public green space and all public green space should be legally protected in perpetuity.

A Council Press release of 16 September 2016 states, based on the Strategic Green & Open Spaces Review Board Final Report, the Local Plan will not just protect parks but will also respond to the findings and recommendation of the Review.

Sefton Park Meadows are part of our city’s historic public green space within the Title Deeds of Sefton Park, and are in the Sefton Park Conservation Area. The site is one of the last undeveloped remaining areas of the former Royal Ancient Park of Toxteth (a once vast medieval hunting park). They give the Park its landscape character at this location, with unique views in, out and across Sefton Park. They have important physical features, specifically their beautiful mature large protected trees and open grasslands. Sefton Park Meadows are within the significant setting of Sefton Park, a Grade I Registered Park and Garden. They provide a grand entrance to Sefton Park and are in the style of the original Park designer Edouard André. Historic plans and evidence available can show that the Meadows was never intended for Victorian housing, and the site has never been built on since its completion. They are a unique part of the heritage open space at this edge of Sefton Park that has evolved over 140 years.

The importance of opportunities for being outdoors, in green open spaces, is now well accepted, regarding its value for mental health and wellbeing, as well as physical fitness. Plus the benefits green open spaces bring to air quality and mitigate climate change. In Liverpool we need every green open space we have.

Therefore, the precise modifications/wording that we are seeking to make the plan sound are detailed in the following five paragraphs. As without such modifications/wording the Local Plan is not justified. a) In recognition of the large number of Save Sefton Park Meadows Campaign Group members and supporters who submitted Call For Sites Forms to the 2014 and 2016 Local Plan Consultations calling for Sefton Park Meadows to be protected from development, there should be a map in Appendix 4 of the Sustainability Appraisal incorporating Equality Impact Assessment and Health Impact Assessment of the Submission Draft Liverpool Local

Plan, Appendices, Final Report, January 2018 [CD8.1] document to clearly identify Sefton Park Meadows as being a site Protected From Development to comply with NPPF2012 paragraphs 150 and 157. b) Sefton Park Meadows should be recorded in the Liverpool Local Plan as being a site Protected From Development to comply with NPPF2012 paragraphs 150 and 157. c) Sefton Park Meadows should be designated in the Local Plan as Local Green Space as it fulfils all the criteria of NPPF1012 Paragraphs 76 and 77. d) Sefton Park Meadows should not be designated as ‘Amenity Greenspace’ in the LCC Open Space Assessment Report & Standards – April 2017, when it should rightly be designated as a Park in Part 4: Parks & Gardens in that document and as previously designated in the 2005 Open Space Study. e) Sefton Park Meadows are currently shaded green, designated as Open Space on the Liverpool Plan 2013 -2033 Policies Map, when it should in addition have diagonal red hatching designating Local Wildlife Site as is the rest of Sefton Park designated, together with ‘H’ for Historic Park, as Sefton Park Meadows are an integral part of Sefton Park.

Kenneth Aspinall

Chair of Save Sefton Park Meadows Campaign Group

29 June 2020