3.2 After the Right of Way Claim was submitted, further documentary evidence became available. This was submitted to the City Council (as 'Annexes 11-23') in January 2017. Annex 11 was the LCC Planning Committee Agenda Report on application 99P/1289 (for what became Byron Court), Annex 12 was the associated Landscaping Layout Plan, and Annex 13 was the 'Site Plan Existing' submitted as part of previous application 98P/1647. Annex 14 was the Glenacres 'Revised Layout' (1967), Annex 15 was a further Ordnance Survey map (1971) and Annex 16 was a Site Ownership map (1992).
3.3 The remaining Annexes (18-23) consisted of miscellaneous correspondence which was referred to in the Gateacre Society's Letter of Support for the Order. This comprised exchanges of letters (2002) with Brian Mason (the City Council's former Rights of Way Officer), exchanges of emails with Merseyside Police (2016) and an anonymous letter received by Glenacres residents (January 2017). All of our Annexes have, we are told, been forwarded to the Planning Inspectorate by Liverpool City Council. However, the copy we received from the City Council omitted part of Annex 21 and the whole of Annex 22, so duplicates of these Annexes are appended to this Statement of Case.
3.4 The Ordnance Survey maps (Annexes 1-6 & 15) confirm that the pedestrian route, which is the subject of this Modification Order, follows the driveway of Highfield - the home in the late 19th century of Henry Tate the prominent sugar refiner. In the 1920s the house was given by the Tate family to Liverpool Corporation as a children's hospital, which became known as Highfield Hospital or the Royal Liverpool Babies Hospital. In the 1960s, Council flats (Glenacres) and a residential care home (Acrefield Bank) were built in the grounds by Liverpool Corporation, and the old house was converted to a Children's Admission Unit.
3.5 Annex 14 is the 'Revised Layout' plan (Application No. D23322, to build the flats that became Glenacres) dated August 1967. This plan makes clear that there was no wall between the Glenacres roadway and the grounds of Acrefield Bank (marked on the plan as 'OAP Hostel'). The wording alongside the boundary reads: "3 courses granite setts".
3.6 Annex 15 is the Ordnance Survey Edition of 1971. This map confirms that the main route from Acrefield Road to Woolton Park used to run along Glenacres and then through part of what is now Woolton Park Close. However, it also indicates a flight of steps allowing pedestrian access between Acrefield Bank (and hence Woolton Park) and Glenacres.