Ingrid Berry Team Leader, Planning Policy Magdalen House 30 Trinity Road , L20 3NJ

Mr Mike Eccles Telephone: 0151 934 3046 City Council, Email: [email protected] Liverpool Draft Local Plan Consultation, Date: 28th September 2016 Development Plans Team, Our Ref: 1.1.7 Planning and Building Control, Your Ref: Municipal Buildings, Dale Street, L2 2DH

Dear Mr Eccles,

Draft Liverpool Local Plan

Thank you for consulting Sefton Council on the draft Liverpool Local Plan.

Sefton Council and continue to be involved in a significant amount of sub-regional working in a variety of areas, including housing, employment, port related issues, gypsies and travellers and waste. It is considered by Sefton Council that the Duty to Co-operate in relation to Liverpool City Council and Sefton Council has been met. Sefton Council looks forward to continued cross-boundary working on strategic matters with Liverpool City Council.

Sefton Council has the following specific comments to make:

We appreciate that the plan is not complete and further work needs to be done. However Liverpool City Council should demonstrate how it will meet its objectively assessed housing and employment needs in order not to put further pressure on neighbouring Green Belt authorities, including Sefton. I note that 120ha of employment land has been identified as being Liverpool’s objectively assessed employment need and the sites for this have not yet been identified. I also understand that this figure could potentially change as a result of the sub-regional housing and employment study (SHELMA). The publication draft of the Liverpool Local Plan should identify how this need will be met within Liverpool without needing to be met by neighbouring Green Belt authorities.

References to the Port expansion (Liverpool2) and the access strategy are understandably made early in the plan (for example paragraphs 2.12 paragraph and 7.77). However it does not appear to be until paragraph 7.51 on page 94 that it is acknowledged that this is actually in Sefton. It should be made explicit earlier in the plan because whilst the Port expansion is sub-regionally important, many of the issues related to the expansion will inevitably impact upon Sefton and much of the infrastructure improvements and funding will need to be directed towards Sefton. Similarly, and has already been agreed, proposals associated with the redevelopment of the L5 area shown in the Port master plan emerging in Sefton will, in the main, have to be met within Liverpool as only 2.63ha of this requirement will be met in Sefton (see paragraph 4.17 of the Proposed Modifications to the Sefton Local Plan).

In the absence of an up to date Open Space Study, no reference is made to what might be considered ‘appropriate’ open space for new development. Neither is there mention of management arrangements for new open space in policy GI 7. This might be interpreted that no new space will be provided and existing open space may not be enhanced in the expectation that people would travel to use Countryside Recreation Areas in Sefton and the Sefton Coast (and elsewhere). More clarity is needed on how recreational pressures are to be managed locally. This was outlined in the Habitats Regulations Assessment (HRA) for Sefton in that recreational pressure on the Sefton Coast is sub-regional and needs to be managed.

Subject to the above, Sefton Council have no substantive objections to the draft Liverpool Local Plan at this stage.

I trust that this is of use to you.

Yours sincerely,

Stuart Barnes Head of Planning Services