There is no need to put housing on Liverpool’s Green Spaces – Official!!


For 5+ years Lib Dems and campaign groups have said that there is no need to build on green spaces to provide homes. Now that the Council’s own figures prove this why haven’t the proposals for Sefton and Calderstones Park been removed?

Next Wednesday Liverpool City Council will be voting on one of our most important strategic documents – the Local Development Framework. Although this sounds a very dry and dusty document it is a very important one. It sets out land use in Liverpool for the next 20 years and will partly become largely effective from Wednesday although there is a long-drawn approval process which will lead to final approval hopefully by the end of the year or by the middle of 2019 at the latest.

The Lib Dems have made a preliminary review of the document (it is more than 1,000 pages long) and will be supporting its adoption next week. We don’t agree with absolutely everything in it and will take the opportunity during the statutory consultation process to deal with the fairly minor items of disagreement. Our concern for a long time has been that this document is badly overdue and badly needed. It should have been submitted in 2011. We are one of just 15 councils in the Country where the Government has had to threaten to intervene because of the lateness of our processes. The lateness of the approval has led to the council through its planning committee not being able to respond adequately when some planning applications, especially those about student accommodation and houses in multiple occupation come in.

We learned a staggering fact last night that there is planning approval for 26,000 units of accommodation which have yet to be built and that there is land available for another 9,000 units. This will create living accommodation for 50/60,000 people. This with the efforts that need to be made to fill the 9,000 empty properties in this city are enough to cope with population growth over the period of the LDF and beyond.

There are three key reasons why we will support the Framework:

  1. It accepts that for the foreseeable future there is no need to build on green spaces in the city to provide the anticipated housing growth. We have long argued this with the council not listening although the evidence was obvious.
  2. We will be able to control better the massive numbers of student accommodation in the City. We will be able to insist through the planning process that blocks built for student accommodation should be capable of being adapted to general needs accommodation if the student numbers dry up.
  3. It will enable us to control better the ‘Houses in Multiple Occupation’ that have caused major problems in the City.

To the minds of Lib Dems there are three big unanswered questions:

  1. If the Council now accepts the case made by us and every campaign group in the city, that green space land is not needed for housing why is the Council still intending to build on part of Calderstones Park and Sefton Park Meadowlands. We are now calling on the Mayor to drop these proposals in the light of the policy and evidence which he will introduce at Council.
  2. Will most of the 26,000 units of housing which have received planning consent actually be built? The fractional investment technique which has caused the debacle in China Town and other sites is largely discredited. Many of the 9,000 units which are currently empty are city centre apartments looking for purchasers either for owner occupation or for tenants as they have been built using the factional investment technique. The Council needs to work with those developers and land owners to make proposals which will better meet the needs of the objectives of the Council.

These proposals still have changes to go through and we would urge every community group; amenity group; Friends of Parks, conservation groups etc to go through the document with a fine-tooth comb and submit evidence within the consultation process to the Council. The Council has to tell the Planning Inspector who will publicly review the Framework what responses have been received and what he council’s response is to these reviews.

I now attach a very handy set of responses to the Questions that the Council is anticipating will be asked. Rest assured that I will be reading all 1,000+ pages and that the Lib Dems will be putting in our thoughts to this final stage of the process.

Local Plan Frequently Asked Questions

What is a Local Plan?

All councils (Local Planning Authorities) must prepare a local plan.  A local plan sets out local planning policies and identifies how land will be used, determining what will be built where. Typically local plans cover a 15 to 20 year period (the ‘plan period’).

A Local Plan must be legally compliant and found ‘sound’ (see below for further details).

How long will the Local Plan last?

The Local Plan covers a 15-20 year period.

Why do we need an up-to-date Local Plan?

The government requires all local authorities to have an up to date Local Plan.  Without an up-to-date Local Plan Local Authorities are at risk of speculative development proposals that may not help deliver the aims of the Council or be acceptable to local communities.  Failure to have an up-to-date plan would also risk government intervention, resulting in a loss of control of the planning and development process.

What does up to date mean?

There is no single meaning of up to date, however to be effective plans need to be kept up-to-date. Policies will age at different rates depending on local circumstances, and the City Council should review the relevance of the Local Plan at regular intervals to assess whether some or all of it may need updating. Government considers that most Local Plans are likely to require updating in whole or in part at least every 5 years.

The National Planning Policy Framework makes clear that relevant policies for the supply of housing should not be considered up-to-date if the authority cannot demonstrate a 5-year supply of deliverable housing sites.  New evidence may also come forward that should be taken into account and could require a review of Local Plan policy, The government identifies plan making activity by other authorities nearby as well as by Combined Authorities.

Why has the Council prepared a Submission Draft Local Plan?

In accordance with national planning policy and guidance the Council has prepared a Submission draft Local Plan for final consultation.  This enables individuals and organisations to make comments on whether the Local Plan has been correctly prepared and is ‘sound’.

Following this consultation, the Council will consider the comments, and if it believes that the local Plan is still ready for submission to the Secretary of State for the purposes of Examination in Public, will submit the Plan together with all relevant information including all the representations that have been received.  The independent Inspector appointed to examine the Liverpool Local Plan is required to consider all the representations.


What are the key stages involved in preparing a Local Plan for Liverpool?

Local Plan Stages Indicative Dates 
PREVIOUS STAGE: – Consultation on the Draft Local Plan – The City Council must consider the representations received at this stage and show how they have been taken into account in preparing the final version of the Local Plan September  – October 2016
THIS STAGE: Publication of the final version of the Local Plan & Invitation to make representations. The City Council must send the representations received at this stage to the independent inspector.    Jan/March 2018
NEXT STAGE: Submission and Independent Examination.  The Inspector must consider the representations made at the previous stage when examining the Local Plan. April – Dec 2018
FINAL STAGE: City Council adopts Local Plan and legal challenge period commences. Dec 2018/Jan 2019


Have views made on previous consultations been taken into account?

Yes, responses to previous consultations have been considered and along with other evidence and national policy, have informed the policies and site selections in the Local Plan.  Information about this was included in the January 19th Cabinet Report.

How will my views at this stage of the local plan be considered?

During the previous two consultation periods any comments made and/or issues identified were considered in the preparation of the subsequent stage of the Local plan.

At this stage the community is invited to share their views through the making of formal representations.  These representations will be submitted alongside the Local plan for independent examination.  The independent inspector appointed to undertake the examination will take all comments into account as part of his/her examination into the plan.

Can a petition be submitted?

Yes, a petition will be considered as a single representation and the number of signatories will be noted. Petitions should include a covering letter with a point of contact.

What does the Local Plan include?

The Local Plan sets out a long-term spatial vision, strategic priorities and policies for future development in the City up to 2033.  Additionally, it sets out:

  • Development management policies that will guide the delivery of development in the City and will be used to determine planning applications. These policies provide detailed advice to developers and others on the scale, design, accessibility, sustainability etc. of proposals;
  • Site allocations for residential, other land uses across the City, shown on a Policies Map; and
  • Designations where land is proposed to be safeguarded or where specific policies apply, such as for District and Local Centres, these are also shown on the Policies Map.

What do the policies cover?

The policies will cover various aspects, including

  • The City Centre
  • Employment Land and the Economy
  • Housing Provision
  • Shopping Centres and Community Facilities
  • Urban Design
  • Heritage
  • Green Infrastructure
  • Environmental Resources
  • Sustainable Transport and Accessibility
  • Infrastructure and Developer Contributions

Are planning applications refused if they conflict with Policies in the Local Plan?

The British planning system does not zone land uses which means that when a planning application is made the City Council first establishes whether its development plan policies are material to that application.  If so the decision to approve or refuse must be taken in accordance with the development plan unless there are material considerations that indicate otherwise.

The National Planning Policy Framework stresses where a proposal accords with an up-to-date development plan it should be approved without delay, as required by the presumption in favour of sustainable development at paragraph 14 of the National Planning Policy Framework.

Where the development plan is absent, silent or the relevant policies are out of date, paragraph 14 of the National Planning Policy Framework requires the application to be determined in accordance with the presumption in favour of sustainable development unless otherwise specified.

A material planning consideration is one which is relevant to making the planning decision in question.  The scope of what can constitute a material consideration is very wide and the courts often do not indicate what cannot be a material consideration.

Whether a particular consideration is material will depend on the circumstances of the case and is ultimately a decision for the courts. Provided it has regard to all material considerations, it is for the City Council to decide what weight is to be given to the material considerations in each case.

The National Planning Policy Framework also requires planning policies to be flexibly written so that if circumstances change the development needed in the City will not be held up.


Why do we need more houses and how many do we need?

We need more homes because both the population of Liverpool and the number of households in it is expected to grow.  It is essential that the City has enough homes to meet the needs of both new and existing households.

To identify how many homes are needed over the whole plan-period (2013 – 2033) the City Council is currently required to produce a Strategic Housing Market Assessment (SHMA). The SHMA calculates:

  • The Full Objectively Assessed Need (FOAN) for, and
  • The size and type of homes required.

If it does not do this the Local Plan cannot be taken forward and used to guide future development. The SHMA, following an update in December 2017 has identified an overall housing requirement of just under 35,000 new homes between 2013 and 2033.  This is a net figure excluding any homes lost to demolition or conversion.

Through a combination of completed homes since 2013, outstanding planning permissions and the proposed site allocations, and allowance for unexpected housing completions (windfall sites) it has been possible to meet this requirement through the use of sites which are brownfield.

What is a five-year supply of housing land and why is it important?

The five year figure is calculated by dividing the total number of homes the City needs during the Local Plan period (34,780) by the number of years in the plan–period (20) to give the annual requirement (1,739), multiplying that by 5 (8,695) and then applying the 5% or 20% buffer (9,130 – 10,434). The 20% buffer has to be added if there has been persistent under-delivery of homes in the City compared with the annual requirement of 1,739, otherwise 5% is applied.

Under- delivery (which is also known as ‘Backlog’) is the difference between the number of homes actually built in any one year and the annual requirement for that year. If there is a backlog this number must be added to the annual requirement for the following five years on a rolling basis. Liverpool does not have a ‘backlog’

If however Liverpool does not have a five years supply of land for house building and particularly if it had built up a backlog Developers would argue that any site should be built on.

Our assessment of 5 year supply at April 2017 is that City Council has a have a five year supply of 16,678 homes expected to be completed within five years.  This compares with the 5 year requirement of 9,130 (Annual requirement 1,729 x 5 years plus a 5% buffer) or in other words is a surplus of 83%.  However it must be stressed that this calculation must be kept up to date at least annually and will be subject to change.  If the surplus falls below 20% the City Council may need to consider a local plan review to ensure there is enough housing land to meet the City’s needs.

How much land is required to provide the housing which is needed?

Through a combination of completed homes since 2013, outstanding planning permissions which are still to be built, windfalls and the proposed site allocations in the Local Plan it has been possible to meet this requirement through the use of sites which are brownfield.  There are 23 allocated sites which are expected to produce some 2,320 new homes.

Where are the people going to come from to occupy this new housing?

The SHMA shows that Liverpool experiences a relatively high proportion of people/households moving into the City to live and that new households are also likely to form from within the existing population.  These trends are expected to continue and so lead to the need for more homes.

What type of housing needs to be provided?

The SHMA (2016) update December 2018 recommends as a range, the following dwelling size mix for market and affordable housing, on a city wide basis for the period 2013-2033:

Mix of Affordable and Market Homes

  1-bed 2-bed 3-bed 4+ bed
Market 0-5% 25-30% 45-50% 20-25%
Low-cost home ownership 15-20% 40-45% 30-35% 5-10%
Affordable housing (rented) 20-25% 35-40% 30-35% 5-10%

Based on the evidence, it is expected that the focus of new market housing provision will be on two- and three-bed properties. Continued demand for family housing can be expected from newly forming households. There may also be some demand for medium-sized properties (2- and 3-beds) from older households downsizing and looking to release equity in existing homes, but still retain flexibility for friends and family to come and stay.

When will new housing be built?

The new homes will be built over the Local Plan period – with different types of development completing at different rates.  For example an apartment scheme will build all the units at once while a lower density estate of detached, semi-detached or terraced homes will be completed more slowly.  Larger schemes may take several years to complete.

How does the Local Plan deal with the issue of there being too many homes in multiple occupation (HMOs) in some parts of the City?

The Local Plan contains a new policy to help deal with this issue. This policy provides a basis for refusing applications for change of use as small HMOs in specifically identified areas, which already currently have more than 10% HMO dwellings within the area.  This is achieved by withdrawing permitted development rights, via an Article 4 Direction and is a separate procedure to the Local Plan. The process of identifying these areas forms part of the evidence base which supports the Local Plan.  It is possible that at the Examination stage the independent Inspector may not allow the new policy to be included in the Local Plan or require modification of the policy.

What is the Local Plan doing about Affordable Housing?

The Local Plan will provide for a range of housing to meet housing needs, identified by the SHMA (2016) and will continue to support a range of initiatives to deliver affordable housing, including the Affordable Homes Programme and Council-led programmes and partnerships. The Local Plan also proposes a new policy requirement for viable sites, containing 10 or more dwellings, of the dwellings provided 20% should be affordable, either social / affordable rent or shared ownership.

What is the Local Plan doing to deliver more jobs?

To deliver more jobs the Local Plan makes provision for a supply of employment land to attract inward investment and to support existing businesses. Economic forecasts suggest the opportunity to create between 22,960 and 54,080 jobs over the Plan period.  To assess the need for and supply of employment land the Council commissioned evidence based studies to inform the Local Plan, including the Employment Land Study 2017 (ELS).  The ELS identified that the potential supply of land for industrial/business purposes is sufficient but that the balance is tight.  The Study therefore recommended that there should be a presumption against redevelopment of industrial/business land for other purposes.  In light of this, the Local Plan also includes policies which seek to protect employment land primarily for industrial/business purposes unless key criteria can be met to justify any such release.  The approach aims to achieve a balance between the different requirements of national planning policy where there is a requirement to provide sufficient land to meet employment land needs (and therefore provide opportunities for jobs to be delivered) while at the same time avoiding the long-term protection of sites identified for employment uses where there is no reasonable prospect of a site being used for such purposes.


What is employment land?

Employment land is land used by business activities which operate from office or industrial premises.


What is the need for additional employment land and how will this be met?

In addition to providing Liverpool with enough homes, the Local Plan is required to meet the need for a range of other land uses based on a robust and up to date evidence base.

To assess the City’s need for and supply of employment land the Council commissioned evidence based studies (including the Employment Land Study 2017 (ELS)) to inform the Local Plan.  The findings result in an overall requirement for 149.5 hectares of land for industrial and business purposes to meet the needs of the City and those arising from the planned development of the City Region’s SuperPort, over the plan period.

Where will these proposed new employment land and jobs be created?

The ELS identifies that the majority of the requirement will be met through industrial/business development which has already been completed or has planning permission. The remaining requirement (56.2 ha) will be met through the provision of land which has been designated or allocated for industrial/business purposes in the Local Plan (as shown in Schedule 7 and on the Policies Map(s)) which total just over 60 hectares.


What is the Local Plan doing to support local shopping areas?

The Local Plan includes policies which support the vitality and viability of centres by directing new investment into those centres e.g. supermarkets. The policies, which must follow national planning policy, seek to ensure that local residents in the City have day to day access to local shops and services. Development proposed outside centres will be required to demonstrate that there are no sites capable of accommodating the proposal in a centre and that there will be no adverse impacts on centres.

How much Retail and Leisure floorspace will be required?

The Retail and Leisure Needs study (2016 as updated 2017) has not identified the need for the provision of sites for retail or leisure needs in the Local Plan. The study estimates that there will be a surplus of convenience shopping floorspace until 2033 and comparison goods floorspace until 2025. At 2025 it is only the City Centre that has capacity for comparison goods.

What is the difference between convenience and comparison shopping?

Convenience shopping is mainly food and groceries while comparison goods include items such as clothing, furniture, carpets and electrical goods.

How does the Local Plan deal with the issue that there are too many hot food takeaways?

The Local Plan contains new policy to help deal with this issue – Policy SP4 Food and Drink Uses and Hot Food Take-Aways. This policy seeks to do 3 things:

  • Protect the vitality and viability of centres by setting thresholds for the number of hot food takeaways within District and Local Centres. Whilst these uses can fill vacant units, may add to the diversity of uses, and offer a popular facility for local communities, it is important that such uses do not harm the character of a centre or cause nuisance to local residents. These uses can undermine the retail function and general attractiveness of a centre and can lead to dead frontages during the daytime.
  • Contribute to addressing health issues in the City by proposing to restrict opening hours of new hot food takeaway proposals within 400m of a secondary school
  • Protect residential amenity by seeking to ensure that such uses for do not generate unacceptable levels of noise, vibrations, odours, traffic disturbance (including from both customers and delivery vehicles) and litter. The Policy sets a number of criteria which all proposals should be assessed against that deals with these issues

Policies CC8 “Non A1 uses in the City Centre MRA” and CC22 “Food and Drink Uses and Hot Food Takeaways in the City Centre and MRA” address the issue of hot food takeaways in the City Centre. These policies seek to protect the retail function of the Main Retail Area (MRA) and residential amenity.

What about Infrastructure – are there any gaps?


The Local Plan is supported by an assessment of infrastructure requirements across the City and the plan period.  This is called the Infrastructure Delivery Programme (IDP).  The IDP is required amongst other things to identify whether there are any key infrastructure constraints in the first five years of the Local Plan period.

The overall conclusion of the work undertaken for this IDP is that there are no significant shortfalls in infrastructure provision which will prevent delivery of existing and Local Plan growth proposals in the short term (5 years).

In the post 5 years period there are indications that some key areas of infrastructure will need to be invested in these include electricity transmission, education and health facilities and telecommunications (including broadband/digital connectivity).

The Local Plan includes new policies on Infrastructure and Developer contributions which will be applied in combination with the IDP to address these matters especially where infrastructure providers own investment programmes may not be doing so.

What is the National Planning Policy Framework?

The National Planning Policy Framework (NPPF) is produced by the government and is the basis for all planning policy and requires Local Authorities to identify locations for a five year supply of housing land. Where Local Authorities cannot do this, the Local Plan can be considered to be out of date, and the NPPF contains a presumption in favour of proposals that are considered to be sustainable development.

What is the Habitats Regulations Assessment (HRA)?

The HRA assesses the likely impact of the policies and sites allocated in the Local Plan on important Natura 2000 sites (Sites of internationally recognised importance). The HRA identifies whether there will be any negative impacts on these sites and/or on protected species of plants or wildlife and whether those impacts can be mitigated against or whether alternative approaches should be taken.

What is a Sustainability Appraisal?

A Sustainability Appraisal is an assessment of the social, environmental and economic impacts of a plan. It forms part of the evidence base that the plan rests on and should demonstrate whether the plan is the most appropriate, when assessed against reasonable alternatives.

What does legally compliant mean?

A plan is legally compliant when it has been prepared in accordance with the Local Development Scheme and Statement of Community Involvement, has been subject to a Sustainability Appraisal and meets all other requirements set out in national legislation relating to planning including the procedural requirements of publicity, engagement and consultation.

The plan should also be compliant with the ‘Duty to Cooperate’ which requires local planning authorities to constructively engage with neighbouring local planning authorities and other designated bodies over a strategic cross-boundary matters.

What is the Local Development Scheme?

The Local Development Scheme sets out the Development Plan Documents that Liverpool City Council is proposing to produce as its Local Plan. The Scheme involves a timetable for the preparation of each document for the Plan, as well as, describing the Local Plan Documents that will be produced. The Local Development Scheme aims to help the community to understand the development plan process and how to get involved.

What is the Statement of Community Involvement?

The Statement of Community Involvement is a document which sets out how the community will be consulted on the Local Plan. It also includes consultation arrangements for planning applications.

What is the ‘Duty to Cooperate’?

The Duty to Co-operate was first set out in the Localism Act 2011 following the abolition of regional planning. Local planning authorities legally must engage helpfully and actively with other nearby Councils and relevant organisations to ensure that Local Plans are prepared.

What is a Sustainability Appraisal?

A Sustainability Appraisal is a statutory requirement of the Planning and Compulsory Purchase Act 2004. It is used to ensure that the Local Plan promotes sustainable development in Liverpool. The Sustainability Appraisal process involves assessing the social, economic, and environmental effects of the Local Plan.


What does ‘sound’ mean?

A Local Plan is found sound when it is:

  • Positively prepared: meeting objectively assessed development and infrastructure requirements;
  • Justified: based on credible evidence resulting in the most appropriate strategy when considered against other reasonable alternatives;
  • Effective: the plan is deliverable, flexible and can be monitored; and
  • Consistent with national policy: departures from national planning policy must be justified.

ves where these exist.


Where can I find out more about the Local Plan?


Telephone: 0151 233 3021


By Post:

Liverpool City Council


Submission Draft Local Plan Consultation

Development Plans Team

Planning and Building Control

Municipal Buildings, Dale Street, Liverpool L2 2DH

What happens next?

Following Submission by the end of March 2018, from April until December the Independent Examination of the Local Plan will take place.  Any representations made at the publication stage are considered by the Inspector. The City Council will then adopt the Local Plan and the legal challenge period will commence from December until January of 2019.


About richardkemp

Leader of the Liberal Democrats in Liverpool. Deputy Chair and Lib Dem Spokesperson on the LGA Community Wellbeing Board. Married to the lovely Cllr Erica Kemp CBE with three children and four grandchildren.
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