The City of Liverpool Local Development Framework Core Strategy Development Plan Document Sustainability Appraisal Scoping Report

Comments offered on behalf of

Liverpool Environment Network and Merseyside Civic Society by Dr Peter Brown,

University of Liverpool, Department of Civic Design

We welcome the opportunity to offer comments on the Sustainability Appraisal Scoping Report. The report provides a useful overview of the process to which the sustainability appraisal is to contribute and identifies a wide range of issues that should be given consideration as part of this process. It goes on to set out some objectives of the overall plan that have been, in part, prompted by reflection on the issues and an attempt to articulate ways of addressing the issues identified. In the limited time it has been possible to find to scrutinise the Scoping Report, we have noted a few, narrowly focused points that are discussed under the three headings below. We hope that these comments will prove helpful. However, we recognise that there are probably many more points on which we really should be commenting at this critical stage and hope that there will be a further opportunity to shape the process and debate how issues can be better/best addressed when we have had more time to digest the content of what has been produced to date. 1. Objectives We have no fundamental quarrel with the specific objectives identified. However, we feel that something has been lost of the sense in which city residents could identify with two of the priorities adopted in the Community Strategy – in seeking to make Liverpool an ‘inclusive city’ and ‘a good place to be’. The only current objective that comes close is B – To Build and Support Strong Communities – but this does not have the same appeal to the city’s populace in convincing them that the LDF is going to make the city a place in which they wish to remain, in which to ‘live, work and play’, and to help to create a community of which they can feel a part. The objectives seem to be almost exclusively ‘physical’ without giving enough of a feeling of being adopted for the benefit of people and the creation and/or improvement of the localities and places in which they can live their daily lives. In that sense we believe there needs to be a more explicit recognition, in the sustainability appraisal process, of the very different communities and localities that the overall framework is intended to serve. A good attempt has been made to do this in Section 7 – in noting how certain issues are described as Strategic/Citywide as opposed to Local. However, the ‘local’ may relate to a particular locality, such as the city centre, or to a specific sectoral interest in that locality, such as business, retailers, publicans, residents. Some issues and objectives might be better expressed more explicitly as relating to a particular sectoral interest and locality in which they are found.

2. Baseline Data, Issues and Objectives It is helpful that the baseline data identified in the report builds on the 8 sustainability themes adopted in the Community Strategy and that these are taken forward into the sustainability appraisal framework. However, the link between these themes and the subsequent identification of issues and then objectives, currently fails to pick up what seem to be obvious linkages between what is discussed in relation to the themes and the ultimate objectives. One example here concerns the elaboration of the baseline information relating to Efficient Use of Resources, Energy and Waste theme (p.11) where attention is drawn to Liverpool having ‘one of the lowest rates of recycling (especially household waste) and composting in the country and one of the highest rates of waste going to landfill’ and UKSSD measures are advocated for use as sustainability indicators (p.18). Then there is reference made (p. 22) to the need for ‘substantial changes in waste management practice’. Logic and consistency suggest that this should be reflected in an explicit statement about the high degree of commitment to dramatically increasing recycling and composting rates and to achieving a major reduction in landfill dependency. 3. Sustainability Appraisal Framework – Proposed Indicators It is recognised that many of the issues identified are complex and can only be addressed effectively through the coordination of policies that affect different sectors. This prompts a suggestion, again in consideration of the Efficient Use of Resources theme, where reference is made to high rates of use of ‘previously developed land’ and higher average densities that are, in many respects, ‘encouraging’. However, these two ‘trends’ together are likely to be most effective in contributing to sustainability if the sites so developed are well served by public transport. To this end, with the aid of readily accessible GIS software, it would be more informative if monitoring of change could identify the amount/ proportion of new housing development that is taking place (on brownfield sites, at particular densities) within 200/400/800 metres of specified public transport routes (e.g. Merseyrail stations, Merseytram lines or bus routes – although the latter can be more volatile). This would make is possible to track more explicitly whether new development is in fact taking place in the most appropriate locations that are consistent with improving operating conditions for public transport. PJBB 23 December 2004 (edited 29/12 !!)_