1.6 Accordingly, our comments now are much the same as those which were submitted to Turley in December 2014. We have grouped them under three headings - Green Space, Housing Need and Transport/Accessibility - which we regard as the key issues to be addressed.
2. Green Space issues.
2.1 The whole of the former School site (including the footprint of the buildings) is designated as Green Space in the Liverpool UDP. This means that the value of the Green Space, in terms of recreation, visual amenity (including vistas) and nature conservation needs to be assessed before planning permission is granted for redevelopment.
2.2 The past recreational value of the site was as playing fields for the School. Now that the School has moved to Belle Vale, alternative provision has been made adjacent to the new site. We are told that the City Council granted itself Deemed Section 77 Consent for disposal of the old school site, thus obviating the need for public consultation. The applicant claims (Planning Statement, para.8.12) that "the site clearly does not have a recreational function". However, the site is defined by the Liverpool UDP as falling within a Park Deficiency Area (see Figure 1, which is a map supplied to us by Helen Breen of LCC's Planning Policy Team in December 2014). This means that every effort should be made to incorporate an area of recreational open space within the new development.
2.3 The UDP states (paras 8.151-8.152) that "An area of open space deficiency can be determined by assessing both outdoor playing pitch and park deficiencies" and that it is Council policy that all residents should live within a quarter of a mile of a Park. SPG10 (para 47) states that "Where sites are located within a park deficiency area the Council will require developers to consider on-site provision as a priority". In an email dated 9th April 2015, Michael Clare of Turley told us that there are "a number of playing pitches ... within 1 mile" and that "the introduction of [an] open space would render the site unviable". However, the viability or otherwise of incorporating an open space - on the basis of 50 sq.metres per dwelling, in accordance with UDP policy - is surely dependent on the price which Countryside Properties pay the City Council for the land.
2.4 The submitted Design & Access Statement includes a map (on page 11) indicating that part of the Liverpool Loop Line footpath/cycleway is within the crucial 400 metre radius. However, we would point out that there are not in fact any access points along this particular stretch. Furthermore the open space labelled 'Closest Recreation Ground' is Larchwood Neighbourhood Park, which - along with Alderman John Village Garden to the north-west - is on the City Council's list of proposed closures (this being an implication of the Physical Assets Department's bid to have it redesignated as 'Residential land' in the forthcoming Liverpool Local Plan).