Statement in Response to the Waterford City Council Boundary

Comhairle Chontae Chill Chainnigh Kilkenny County Council

Statement of Response to the Waterford City Council Boundary Extension Proposal

2nd December 2005

SECTION PAGE

1 INTRODUCTION ...... 2

2 EXECUTIVE SUMMARY……………………………………………..……….………………………. 4

3 KILKENNY COUNTY COUNCIL REBUTTAL OF WATERFORD CITY

COUNCIL PROPOSAL….……………………………………………………………… 9

4 DESCRIPTION OF PROPOSED BOUNDARY EXTENSION ...... 16

5 REGIONAL DEVELOPMENT IMPLICATIONS ...... 20

6 DEVELOPMENT CAPACITY WITHIN WATERFORD CITY...... 42

7 FINANCIAL IMPLICATIONS...... 49

8 RESPONSE TO SPECIFIC POINTS IN THE WATERFORD CITY PROPOSAL...... 72

APPENDICES

RESOLUTION BY KILKENNY COUNTY COUNCIL

Local Government Act 1991

Resolution

Proposed by:

Seconded by:

It was resolved at a meeting of the Kilkenny County Council held on the 2nd of December, 2005 in the Council Chamber, County Hall, John Street, Kilkenny.

”That the County Council of the County of Kilkenny, having considered the proposal for a Borough Boundary Extension submitted by Waterford City Council, adopts and makes the Statement of Response herewith in relation to the proposal for a Borough Boundary Extension under the provisions of Section 29 of the Local Government Act, 1991 and, in accordance with the provisions of the Local Government Act, 1991 and the requirements of the Local Government (Boundary Alterations) Regulations, 1996 made under the Act and hereby proposes that there should be no extension of the Boundary of the County Borough of Waterford.

The Corporate Seal of the Council be affixed to this Statement of Response“.

Present when the Seal of the County Council of the County of Kilkenny was affixed hereto:

______Chairman/Nominated Member

______County Manager

______County Secretary

Section 1: Introduction

1.1 On, 25 July 2005 Kilkenny County Council received notice of a resolution passed by Waterford City Council adopting a proposal in accordance with the provisions of Part V of the Local Government Act 1991 to alter the boundary of Waterford City.

1.2 In accordance with Section 29(3) of the Local Government Act 1991, Kilkenny County Council is required to consider this proposal and make a statement of its response to the proposal within a period of six months from the date of receipt i.e. before 25 January 2006.

1.3 This document is the Statement of Response of Kilkenny County Council to Waterford City Council's proposal. It has been prepared having regard to the Local Government (Boundary Alteration) Regulations 1996 which prescribes the format for a statement of response as follows:

i. Setting out the observations of the respondent in relation to the proposal;

ii. Setting out the appropriate data relating to the following matters where different from that contained in the proposal:

° population: ° area in hectares ° rateable valuation ° number of commercial premises ° an estimate of the number of households ° estimated annual income generated from rates, charges and other sources;

iii. Setting out, in relation to each programme group, the estimated income and expenditure implications for the respondent;

iv. Where appropriate, suggesting any revisions to the proposal, including revision of the proposed boundary or in relation to financial, administrative or organisational matters; and

v. Where revision is suggested by the respondent to the proposed boundary, including a map showing the revised boundary.

1.4 The making of a Statement of Response is a reserved function of Kilkenny County Council. A copy of the resolution of Kilkenny County Council, which adopts this Statement of Response in rejection of the proposal to extend the Waterford City boundary, is included.

1.5 This Statement of Response:

i. Provides the response of Kilkenny County Council to the proposal made by Waterford City Council seeking an extension of the City's boundaries; and

ii. Shows the findings of independent assessments commissioned by the Council of the financial and planning implications of the City Council‘s proposals.

1.6 Mazars, in association with DTZ Pieda Consulting, were commissioned by Kilkenny County Council to assist with the preparation of this Statement of Response.

1.7 This Statement of Response is set out as follows:

Section 1: Introduction

Section 2: Executive Summary

Section 3: Kilkenny County Council‘s rebuttal of the key points made by Waterford City Council in seeking to support its proposal, the reasons why these points are not valid and why therefore the proposal should be rejected

Section 4: Describes the boundary extension proposed by Waterford City Council

Section 5: Reviews the regional development context and implications

Section 6: Presents the development potential within Waterford City at present

Section 7: Reviews the financial implications of the proposed boundary extension, and

Section 8: Contains the response of Kilkenny County Council to specific points raised in the City‘s proposal.

Appendices:-

A Figure 4.1 - Map of boundary extension proposed by Waterford City Council

B Figure 4.2 - History of Waterford City Boundary Extensions

C Figure 5.1 œ Waterford City Land Zoning

D Glossary

Section 2: Executive Summary of the Statement of Response by Kilkenny County Council

Having considered the proposal made by Waterford City, and having assessed all other relevant aspects, Kilkenny County Council now formally rejects the Waterford City boundary extension proposal.

The key objections held by Kilkenny County Council to the proposed boundary extension are that:- 1. The boundary extension proposed by Waterford City Council is not required to provide land for future development as the City already has substantial land available within its existing boundary.

In particular:- ° Within Waterford City‘s current boundaries, 1,599 ha (3,950 acres) or 38% of the City‘s land area, is zoned for agricultural use. Much of this agricultural land was incorporated into the City in 1980, when it was granted a boundary extension into County Waterford, on the basis that the City then required additional space for development; ° The new Outer Ring Road will provide much improved access to this undeveloped land, thereby eliminating any suggested barriers to its development. Recent press statements from Waterford City Council say that this new road will open up these lands and facilitate the construction of circa 6,000 houses as well as commercial development; ° In addition to its agricultural land, the City already has sufficient land zoned for residential use to accommodate its projected population growth to at least 2021 and possibly to 2030; ° Furthermore, 50% of the land currently zoned for industrial use within the City remains available for development, and ° If the City‘s proposal for a boundary extension were to be granted, Waterford City would have a much greater land area and a far smaller population than other Gateway cities. For example, at present Cork City has a population almost three times that of Waterford City, yet it has a land area smaller than that of Waterford. If the boundary extension were granted, Waterford‘s population density would then be 7.6 persons per hectare (or 3.0 persons per acre) whereas other Gateway cities typically have densities four times greater than this.

Waterford City clearly has ample space for planned development far into the future.

2. Key National and Regional Development Strategies currently in place promote the principle of co-operation between the relevant local authorities, not boundary changes, to achieve national, regional and local development objectives.

In particular:- ° The National Spatial Strategy (NSS) provides for a development framework in the South East region that is based on the —Waterford/Wexford/Kilkenny growth triangle“ that requires these centres to work together in —a co-ordinated and integrated approach that builds on their complementary strengths“; ° The Waterford Planning Land Use and Transportation Study (PLUTS), adopted in 2004 by Waterford City Council and Kilkenny and Waterford County Councils, specifically states that the three authorities —will agree on how best to co-operate on implementation issues, to agree on appropriate joint monitoring and review structures“; ° The South East Regional Planning Guidelines (SERPG) endorsed the PLUTS and went one step further by proposing that an implementation group be set up —to deliver a consistent approach across administrative boundaries“; ° One of the central arguments put forward by Waterford City in proposing the boundary extension involves the concept of developing a —compact city“. In this regard, the European Commission‘s European Spatial Dimension Perspective (ESDP) recommends that in order to achieve a compact city “co-operation between the city and the surrounding countryside must be intensified“; ° Inter-authority co-operation in the South-East region has already been demonstrated by activities such as the development and adoption of a regional waste management plan and regional planning guidelines and specifically between Waterford City and Kilkenny in the planning and development of the City‘s main drainage scheme.

Clearly the co-operative approach as sought consistently by Kilkenny County Council is the favoured approach at European, National and Regional levels. However, this level of co-operation has not been matched by Waterford City Council. Examples include its reluctance to engage in the development of Belview Port and also to engage on the implementation issues associated with PLUTS.

3. The National Spatial Strategy envisages that Waterford City‘s role as a Gateway be delivered through collaboration and co-operation with Kilkenny City and Wexford Town, not through an expansion of the City‘s boundary. The NSS designated Waterford as a Gateway City, and says —The strategies should focus on the practical realisation of the gateway or hub. In some cases, more than one local authority may be involved. However, provision has been made in the Planning and Development Act 2000 and in the Local Government Act 2001 for the preparation of joint plans and the use of joint committees between adjacent local authorities to address cross boundary issues, including transportation.“ (NSS pp123)

The NSS clearly supports a collaborative inter-authority approach.

4. The boundary extension proposal, if granted, would seriously undermine the financial position of Kilkenny County Council.

If the proposal were granted:- ° Kilkenny County Council would lose ⁄1.8 million annually of its income from commercial rates and other sources; ° Being an efficient Council, Kilkenny has only minimal opportunities to secure cost savings. Achievable savings are ⁄0.7 million per annum which is only a fraction of the costs of providing services in the area. These savings, combined with the income losses would result in an annual net loss to the County of ⁄1.1 million; ° Recovery of these losses would require an increase in the rates charge of over 20% for the remainder of Kilkenny County. ° In addition, Waterford City projects that the boundary extension would result in a net cost to it of ⁄0.7 million in year 1. The impact of the extension would be a 28% increase in rates for businesses in the proposed extension area œ arising solely from the City‘s higher rates charge œ plus a 5% increase in rates across the extended City to fund the ⁄0.7 million increase in annual costs.

Furthermore, in recent years Kilkenny County Council has invested substantial amounts of its own resources in developing the roads, water, waste water and other services in the area. The people of Kilkenny are entitled to benefit from this investment through new business and employment investment, with the associated income benefits, particularly in the Belview Port area.

It is evident that the City‘s assertion that a boundary extension would —assist in securing the long-term financial base for the City“ is contradicted by Kilkenny County Council‘s analysis. The proposal would result in greatly increased costs for both the City and Kilkenny County and provide no improvement in services to the people or businesses in the area.

Waterford City should address its financial issues through appropriate action within its existing boundaries and not by securing resources from a neighbouring County.

5. Kilkenny County Council has a strong vision for the future of the County as a whole, and is implementing its vision in individual areas such as the South of the County where it is:-

° Implementing good forward planning; ° Rezoning lands to support balanced residential, community, commercial and industrial development; ° Providing the infrastructure to enable these developments to take place; ° Implementing its policy of providing additional new community facilities;

° Co-operating with Belview Port in implementing its strategy for growth and providing it with the necessary services and infrastructure; and ° Consulting and co-operating widely with various agencies and the public.

In contrast to this approach, Waterford City has put forward no vision for the area, nor has it submitted any alternative approach to planning and development in the area.

6. Kilkenny County and its people have a unique and clear social, cultural and sporting identity.

Kilkenny has developed a successful economy based on developing the unique aspects of the county ranging from the built heritage of Kilkenny City, to the attractiveness of its countryside for tourists and to the development of the potential of Belview Port to attract investment and employment. To grant Waterford City‘s proposal would seriously alter the social and cultural structure of Kilkenny and its balanced development approach and replace it with an enlarged Waterford City whose proposal for a boundary extension has failed to demonstrate any benefit to the people in the area, the business and commercial interests in the region or the Country as a whole. The boundary extension proposal, if granted, would undermine the structure of the County, including South Kilkenny, as the boundary extension area is the second largest urban area in the County, after Kilkenny City. It would also see the area changing county and province and this would result in a very significant change to the area‘s community and social identity.

The boundary extension proposal contains a number of inaccuracies and inconsistencies.

In particular:

1. According to the proposal, the proposed boundary extension encompasses an area of 1,901 ha, equivalent to 4,695 acres. However, Kilkenny County Council has assessed the proposed boundary extension area as shown in maps contained in the proposal and finds that it actually contains a total of 2,359 ha (5,827 acres), an additional 458 ha (1132 acres) or 24% more than that presented in the text of Waterford City‘s proposal, and

2. The proposal states that the extension sought is made up of all or part of 20 townlands, whereas the map included with the proposal shows an area that covers all or part of 25 townlands. The five additional townlands are Granny, Dunkitt, Luffany, Ballymountain and Strangsmill.

Conclusion The proposal for a boundary extension by Waterford City: 1. Is not needed to provide development capacity in the City, 2. Runs contrary to the current regional, national and international best practice approaches to planning and development which are based on inter-authority cooperation, not boundary changes, 3. Makes no financial sense, 4. Demonstrates absolutely no vision or practical benefits for the people and businesses in the area, 5. Is based primarily on the City‘s financial interests, not on its potential contribution to developing the area in particular, or the South-East region as a whole. 6. Would alter the community, cultural and sporting identity of the area and the County, and 7. Would not provide for —convenient and effective local government“.

Waterford City Council should be willing to engage with the other local authorities to a much greater extent in the planning and development of the South-East region as a whole.

Kilkenny County Council therefore rejects the proposal for a boundary extension.

Section 3: Kilkenny County Council Rebuttal of Waterford City Council’s Proposal

3.1 The proposal for a City Boundary Extension made by Waterford City Council in July 2005 put forward certain arguments for such an extension. In this section, a rebuttal to each key point made in the Executive Summary of the City‘s Proposal is presented.

Effective and Convenient Maintenance and Planning of the City

3.2 The City‘s Proposal states that

”The division of this primary urban centre between two separate local authorities is contrary to the effective and convenient maintenance and promotion of the well being of the city and its region, and represents an inefficient use of resources‘ (the Proposal pp 2)

3.3 Kilkenny County Council refutes this assertion. The County Council has and continues to cooperate with Waterford City Council and other local authorities in delivering a range of local authority services in the region, for example:

i. The waste water treatment plant to service the Waterford City and its environs is being developed in County Kilkenny. The scheme is being procured by Waterford City Council on lands acquired by Kilkenny County Council;

ii. The County Council is delivering strategic road infrastructure to serve Waterford City and its Environs;

iii. In 1998 Kilkenny County Council worked in partnership with Waterford City and County Councils to prepare the Strategic Framework Plan for the City. The Strategic Framework Plan informed both the Kilkenny County Development Plan 2002 and the Waterford City Development Plan 2002.

iv. Kilkenny County Council has adopted a strategic approach to the development of the Port of Waterford at Belview in partnership with the Port and Waterford Chamber of Commerce. Waterford City Council‘s inclusion in the process has been sought at all times but the City has not displayed a willingness to be engaged;

v. Co-operation between local authorities to deliver the full range of council services is standard practice in County Kilkenny and throughout Ireland;

vi. Kilkenny County Council is the lead agency for issuing Waste Permits for the South East Region including the Waterford City Council‘s administrative area;

vii. A Homeless Strategy for the South East Region is currently being prepared. This will provide an integrated strategy to resettle homeless in the Region. Kilkenny County Council co-operated in its preparation. The implementation of the Homeless Strategy will require an integrated approach between the local authorities in the South East Region and the Health Services Executive;

viii. Kilkenny County Council has adopted a Development Plan for the Environs of Waterford and an Action Area Plan for Belview which seek to ensure that the full potential of the area can be harnessed in the interests of the proper planning and sustainable development of the area. These plans are consistent with the agreed 1998 Strategic Framework Plan for the City prepared in partnership by Kilkenny County Council and Waterford City and County Councils; and

ix. The financial and operations analysis shows that if the boundary extension was to be granted, both Councils would incur substantial additional costs and would provide no improvement in services to the area. Contrary to the City‘s assertion, it is the granting of a boundary extension that would represent an inefficient use of resources.

The Function as a Gateway

3.4 The City‘s Proposal suggests that the role of Waterford City as a designated Gateway:

”is best achieved by defining a balanced territory for the expanding urban area‘ (the Proposal pp2)

3.5 The Proposal does not accurately interpret what the strategic role and function of Gateways are intended to be as clearly promoted within the National Development Plan (NDP), National Spatial Strategy (NSS) or Regional Planning Guidelines for the South East Region (SERPG). For example:

i. As with all gateway cities, the area of influence of the Gateway extends beyond administrative boundaries, reflecting the concept of the City Region;

ii. According to the NSS, in the case of the South East Region, the potential of Waterford City is to be achieved by harnessing critical mass in education, infrastructure and services through the integrated development of the Waterford œ Kilkenny œ Wexford growth triangle. This recognises that the City on its own does not have the critical mass to achieve the planning, economic and development objectives for the Region as set out in the NSS or SERPG;

iii. The principle of achieving the objectives for the South East Region by cooperation is strongly emphasised throughout the NSS and the SERPG and this is sought to be achieved between the Gateway and the Hubs working with County Towns and Larger Towns and all of the local authorities within the Region; and

iv. The NSS and SERPG reiterate the concepts and mechanisms for inter-authority cooperation which are accommodated for in legislation.

The —Symbiotic Relationship“ with Port of Waterford at Belview

3.6 According to the City‘s Proposal

”As both the port and the city have a symbiotic relationship…..it would be more logical if the administrative responsibility of the port lay with Waterford City Council‘ (the Proposal pp 2)

3.7 The County Council refutes this assertion on the basis that:

i. Despite the apparent clarity of this statement no evidence whatsoever is provided in the City‘s proposal to support its assertion;

ii. The port facilities at Belview are administered by the Port of Waterford. In addition, the port authority provides pilot services to the electricity generation station at Great Island, County Wexford. Thus, the scope of influence of activities of the Port of Waterford spans three jurisdictions, not solely Waterford City but also counties Kilkenny and Wexford;

iii. From experience around the country, local authority administrative boundaries are incidental to the effective operation of ports. This is demonstrated by the Shannon Foynes Port Company operating predominantly out of Foynes in County Limerick from where it manages the operation of the Limerick docks, while the main facilities of the Port of Cork are located up river from the city centre and at Ringaskiddy in County Cork;

iv. The Port of Waterford commenced its relocation from Waterford City in the early 1990s. The relocation of port activities outside of the city is consistent with good practice in planning and development as it enables the strategic development of opportunity sites within the city. The relocation of the main activities of the Port of Waterford has enabled waterfront regeneration, development and environmental improvements along South Quays and opened up the potential to develop a high-profile mixed use scheme on North Quays;

v. Kilkenny County Council has worked in partnership with the Port of Waterford in planning and expanding of port activities at Belview. To ensure that this had a sound land use planning framework, a Local Area Plan was prepared for the area in consultation with the Port of Waterford and incorporated in the 2002 Kilkenny County Development Plan. This specified the type of investment that was suitable for the area and the manner in which this investment should take place. There was widespread local consultation on the proposed development of Belview which resulted in general support for the investment in the area;

vi. The Port of Waterford and Kilkenny County Council jointly purchased some 200 acres of land in the immediate vicinity of the port. Costs were shared between Kilkenny County Council and the Port of Waterford to provide internal road infrastructure and prepare an Environmental Impact Statement (EIS), that paved the way for the provision of a significant water supply as and when required. Kilkenny County Council and the Port of Waterford continues to work with other service providers to ensure that the area will have a satisfactory supply of electricity and natural gas;

vii. Kilkenny County Council and the Port of Waterford have worked together in partnership with Waterford Chamber of Commerce, local people and businesses and the IDA to develop Belview. Waterford City Council‘s involvement has been sought at all times in this partnership but, contrary to the symbiotic relationship purported in the Proposal, the City has not been willing to become involved, and

viii. The partnership and cooperative approach adopted between the County Council and the Port of Waterford is working very effectively to enhance the economic impact and importance of the facility locally, regionally and nationally.

Implementation of Waterford Planning Land Use and Transportation Study

3.8 The Proposal states that

”Waterford City Council has no effective control over the suitable location of land-uses, development and functions and services on lands north of the River Suir outside their administrative area. This mitigates against the implementation of the long term development strategy as outlined in the Waterford Planning, Land Use and Transportation Study‘ the (the Proposal pp2)

3.9 Kilkenny County Council refutes this assertion on the basis that:

i. The County Council worked in partnership with Waterford City Council and Waterford County Council in the preparation of the Waterford Planning, Land Use and Transportation Study (PLUTS). Kilkenny County Council was represented at senior level on the PLUTS Steering Committee;

ii. The area of influence of the PLUTS extends beyond the administrative area of Waterford City Council and well into the areas administered by Kilkenny County Council and Waterford County Council. It is noted that Waterford City Council does not seek a boundary extension for the entire study area of the Waterford PLUTS;

iii. The implementation of the PLUTS will require co-operation not just between local authorities but a range of state agencies and Government departments. This is recognised in the PLUTS; and

iv. In May 2004, Kilkenny County Council adopted the Waterford PLUTS. The recommendations of the study for the Environs of Waterford are reflected in the 2002 Kilkenny County Development Plan;

v. Kilkenny County Council has sought to work the implementation structures, but as yet Waterford City has failed to engage.

Development Capacity within Waterford City

3.10 The Proposal states that there has been considerable population growth within the City (4.8% in the period 1996 to 2002) and that:

”there is a need to facilitate balanced urban development by incorporating a more extensive area of land to the north of the River Suir into the administrative area of the City‘ (the Proposal pp 2)

3.11 Kilkenny County Council rejects this assertion based on the following:

i. There is more than sufficient land already zoned within Waterford City Council administrative area for residential use to at least 2021 and possibly to 2030;

ii. Waterford City Council has adopted a strategy of rural planning in a city administrative area. Some 46% of the City‘s administrative area is currently zoned for agricultural or open space uses. This is not the optimum use of land in an urban area;

iii. Waterford City Council made the same argument when seeking a boundary extension in 1980. Of the land provided under that boundary extension into County Waterford, some 39% remains zoned for agricultural purposes. The City Council has not utilised or zoned a significant part of the land it secured under the 1980 boundary extension for the purposes it sought the extension for;

iv. The development and recent opening of the Waterford City Outer Ring Road should facilitate development of a large area within the City which previously had access and servicing constraints. Contrary to the Proposal, this has been acknowledged by the City Council in recent public statements;

v. Kilkenny County Council has been progressive in ensuring that that the land use planning and policy framework is in place to achieve the proper planning and sustainable development of the parts of the Waterford Environs which are located within County Kilkenny. It has also been progressive and proactive in ensuring that land zoned for residential purposes is serviced and available and, as a direct consequence, large scale residential development is underway with some 2,700 of the 4,400 residential units planned for already benefiting from full planning permission; and

vi. The City Council does not present a development vision or objectives for the Environs of Waterford or the proposed boundary extension area. It merely states that the lands are required but does not indicate or illustrate if and how the City Council would do anything different to what is already happening under Kilkenny County Council‘s planning and administration other than that it will develop the Ferrybank area as a neighbourhood of the city. This contrasts with Kilkenny County Council‘s strategic approach to the development of the area which recognises the requirements of the significant population and businesses that are, and will be located in the area. Their needs are likely to be far greater than those of a neighbourhood, in both scale and concept;

vii. The proposal is not necessary given the lands that remain available for urban development within Waterford City Council‘s existing administrative area.

Franchise

3.12 The Proposal states that

”While a proportion of the population residing to the north of the river, yet outside the City Council administrative boundary, may consider themselves as residing in Waterford City, they have no voting rights or input to the governing, provisions and functions of Waterford city‘ (the Proposal pp2)

3.13 Kilkenny County Council rejects any statement that suggests that the population of the Environs of Waterford are disenfranchised. This is demonstrated by the following:

i. The people of the Environs of Waterford living within County Kilkenny are represented in Kilkenny County Council through the Piltown Electoral Area Committee;

ii. Kilkenny County Council provides a full range of Council services to people living within the Environs of Waterford;

iii. Whilst the Proposal for the boundary extension states that the people of the area will be represented through the electoral system of Waterford City Council, it does not present the detail of how this will be achieved;

iv. Around the country people are living within the suburbs of towns and cities where, due to their residence within another administrative area, they do not have voting rights or input to the governing, provisions and functions of the town or city. The position with the Waterford Environs north of the River Suir is, therefore, not unique and should not be treated as such as it will set a precedent which potentially has significant implications for local government administration in Ireland;

v. The Proposal ignores the very real historical, social, cultural and sporting ties of the people of the area to County Kilkenny and the province of Leinster.

Finance

3.14 According to Waterford City Council

”An extended urban boundary will assist in securing the long-term financial base for the city‘

3.15 The key conclusions from the financial review are that:-

1. After taking account of (a) the increase in net expenditure proposed by Waterford City in respect of the extension area; (b) the revenues that would be lost by Kilkenny County; (c) the potential for Kilkenny County to achieve savings in its operations and staff and (d) the increases in rates income that would derive from the City‘s higher rate plus the impact of commercial property revaluations, the outcome of the proposed boundary extension would be a net cost to Kilkenny County Council alone of ⁄1.04 million and a combined net cost to the two Councils of ⁄1.7 million in year 1. This would reduce to a net cost of ⁄1.2 million by year 11 as the City‘s higher rate on valuation comes into effect. These increased costs will lead to no improvement in the level or quality of services being provided in the proposed extension area.

2. To recover these increased costs in the event of a boundary extension being granted, commercial rates in the remainder of Kilkenny would have to increase by over 20%; ratepayers in the proposed extension area would face an increase of 28% to bring them in line with the remainder of the City plus all ratepayers in the extended City would face an increase of 5%. Alternatively, user charges or central Government funding would have to increase substantially. This does not represent an efficient use of local authority resources or national finances.

3. The proposed boundary extension would not —assist in securing the long- term financial base for the City“, nor does it provide for —convenient or effective local Government“.

CONCLUSION

3.16 The principle of cooperation between local authorities to deliver the potential of an area and region is accepted and well documented in European, national, regional and local policies, strategies and development plans including the 1999 European Spatial Perspective, the NSS, the SERPG and the PLUTS 2003. These policies are reviewed later in this report. It is important to note that while the 2002 Waterford City Development Plan states the City Council‘s objective of seeking a boundary extension north of the River Suir, the remainder of the text of the plan presents how Waterford City will work in cooperation with other local authorities, including Kilkenny County Council to deliver the full range of local authority services.

3.17 Kilkenny County Council is and seeks to continue to play a key role in the development of County Kilkenny, the Waterford Gateway and the South East Region. It is the policy of the County Council to effectively deliver its full range of Council services and harness the potential of Waterford City by cooperating, where necessary, with all relevant local and regional authorities, state agencies and Government departments.

3.18 There is strong evidence that the County Council has adopted a collaborative approach to development both in the past and currently within the Waterford Environs, the County and the Region. Kilkenny County Council seeks to continue to pursue this strategy to the future benefit of the Waterford Environs in County Kilkenny to the benefit of the people of County Kilkenny, Waterford City and the South East Region in the interests of the proper planning and sustainable development of the area.

Section 4 Description of the Proposed Boundary Extension

4.1 This section provides a description of the proposed boundary extension area under the following headings:

i. Overview of the Proposed Boundary Extension;

ii. Population of the Proposed Boundary Extension Area;

iii. Commercial Rate Valuation;

iv. Other Infrastructure;

v. Financial Aspects; and

vi. Previous Waterford City Boundary Extensions.

OVERVIEW OF PROPOSED BOUNDARY EXTENSION

4.2 Figure 4.1 in Appendix A reproduces the map presented as Map 4 in the Waterford City Proposal. It shows that the proposed boundary extension follows the route of the planned N25 Waterford Bypass which extends from the townland of Granny in the west in to Drumdowdy Upper in the east. It is made up of all or part of 25 townlands as follows:

° Granny (part)** ° Killaspy ° Luffany (part)**

° Part of Dunkitt** ° Rochshire ° Kilmurry

° Mullinabro (part) ° Ballynmona ° Rathpatrick

° Newrath ° Ballinvoher ° Strangsmill**

° Cloone ° Belmount ° Drumdowney Lower (part) ° Ballyrobin ° Kilmurry (part) ° Gorteens ° Mountsion ° Rathculliheen ° Drumdowney ° Mountmisery ° Christendom Upper (part)

° Ballymountain** ° Newtown

However, the text of the City‘s proposal (ref pp 41) lists only 20 townlands. The townlands affected and not included in the City‘s description of the proposal for the extension are marked with **.

4.3 These 25 townlands combine to make up all or part of the following four Electoral Divisions (ED): ° Aglish ° Dunkitt ° Kilculliheen (part of) ° Rathpatrick

4.4 According to Section B3 of the Waterford City Council Proposal, the boundary extension encompasses an area of 1,901 hectares (ha) (4,695 acres) and extends beyond the Environs of Waterford1 into the rural area of County Kilkenny, all of which is currently administered by Kilkenny County Council. The Proposal presents a list of the townlands and the area is presented diagrammatically in its Map 4. However, analysis of this map by Kilkenny County Council found that the proposed extension covers an area of 2,359 ha (5,827 acres) which is 24% or 458 ha (1,132 acres) more than that presented in the Proposal. Figure 4.1, which is presented in Appendix A following highlights the anomaly between the area described in the text of the Waterford City Proposal and that presented in its Map 4.

POPULATION

4.5 The area of the proposed boundary extension does not respect the boundaries of ED or townlands. Thus, the data census published by the Central Statistics Office (CSO) does not provide the detail required to accurately estimate the population of the area. Using data published by the CSO and geo-coded data of postal deliveries mapped by Kilkenny County Council, the level of housing completions and the average number of persons per private household2, the population of the area is estimated at 4,824 persons.

COMMERCIAL RATE VALUATION

4.6 The area included by Waterford City in its proposal is largely a rural area. The valuation of commercial properties in the area is ⁄28,458.

OTHER INFRASTRUCTURE

4.7 The assets and property of Kilkenny County Council that would be transferred if the boundary extension were to proceed are referred to in the financial analysis later. Property owned by Kilkenny County Council and funded from its own resources is valued at close to ⁄1 million.

1 The Environs of Waterford refer to the 555.23 ha of zoned land adjacent to Waterford City administered by Kilkenny County Council. 2 The average number of persons per private household in Waterford City in 2002 was 2.78

FINANCIAL

4.8 In its proposal Waterford City assessed that the boundary extension would have a net cost implication for the City of ⁄650,884 and a net cost implication for Kilkenny County of ⁄337,521 in year 1. These assessments have been reviewed independently and while the assessment for the City is accepted as being reasonably accurate, the proposal has underestimated the cost impact on Kilkenny County by a significant amount. The net cost impact on Kilkenny County is of ⁄1,035,586. The proposed boundary extension would therefore have a total net cost of ⁄1,686,470 for the two Councils in year 1. This would reduce to ⁄1.2 million per annum as the transition to the higher rate on valuation in Waterford City comes into effect.

PREVIOUS BOUNDARY EXTENSIONS - BACKGROUND

4.9 As outlined in the Proposal, Waterford City has had a number of boundary enlargements over the last 150 years. These are illustrated in Figure 4.2. The most recent boundary extension was granted to Waterford Corporation (now Waterford City Council) in 1980. The request for a boundary extension was presented to the Minister for the Local Government in the 1979 ”Corporation of Waterford Petition for Boundary Extension‘ (the Petition). The Petition requested an extension of the boundary into areas administered by both Kilkenny and Waterford County Councils as follows:

° Kilkenny County - 1,564ha

° Waterford County - 2,394ha.

4.10 Waterford Corporation‘s rationale for seeking the boundary extension as stated in that Petition was that:

”There is no available land inside the County Borough for acquisition for the Local Authority houses. All the land within the County Borough designated under the development plan for building is under private ownership and planning permission or applications for outline permission have been granted for private houses in by far the greater part of this land.‘ (Petition para 11)

4.11 The Petition was considered by the Minister for Local Government. Kilkenny County Council objected to the principle and detail of the proposed extension into its administrative area for the following reasons:

i. The removal of the area would upset the balance of the population of County Kilkenny;

ii. The area will become a major industrial node and therefore the exclusion of the area would influence the employment profile of the County;

iii. The Environs of Waterford represents the second largest urban area in County Kilkenny. The removal of the area would involve a major rethink of the development intentions which Kilkenny County Council considered would be to the detriment of the County as a whole and the south of the County in particular;

iv. The loss of an urban area would affect the competitiveness of County Kilkenny to attract industry; and

v. There was a range of interwoven political, social and historical factors that, whilst emotive, have major significance for the people of Kilkenny.

4.12 In its objection to the Petition, Kilkenny County Council stated that:

”A system of liaison has worked and been seen to work satisfactorily in the past and the Council cannot see why it cannot continue so to work in the future. Indeed, the Council would go further to say that such a system should be welcomed in that their common interests in and around the Waterford urban area have helped to bring the Councils concerned towards a close working relationship.‘

4.13 In light of the objection by the County Council, the Minister recommended that it would be desirable for further efforts be made to negotiate an agreed approach between Waterford Corporation and the County Council in relation to the delivery of services in the Environs of Waterford.

PREVIOUS BOUNDARY EXTENSIONS - RELEVANCE

4.14 Three key points in respect of the Petition, the Minister‘s response and the boundary extension which was granted in 1980 are relevant to the assessment of the current Proposal by Waterford City Council. These are:

° The basis of the County Council‘s objections to the 1980 boundary still hold true in 2005.

° The requirement for an agreed approach, as recommended by the then Minister for the Environment, is now reiterated and reinforced in a suite of European, national, regional and local policies.

° Waterford City Council has not fully utilised the land provided under the 1980 boundary extension. Some 39% of the boundary extension area is zoned for agricultural purposes, which does not optimise the use of that area. As such the objectives of the extension have not been met.

Section 5 Regional Development Implications

5.1 The development of Waterford City and its Environs is guided by a suite of policies, strategies and development plans that have been prepared and adopted at national, regional and local levels over recent years. These include:

i. European Spatial Perspective: Towards Balanced and Sustainable Development of the Territory of Europe, European Commission 1999;

ii. National Development Plan 2000 œ 2006, Government of Ireland, 1999;

iii. National Spatial Strategy 2002 œ 2020, Government of Ireland, 2002;

iv. Regional Planning Guidelines for the South East Region, South East Regional Authority, 2005;

v. Waterford Planning Land Use and Transportation Study, Waterford City Council, 2003;

vi. Kilkenny County Development Plan, Kilkenny County Council, 2002;

vii. Waterford City Development Plan, Waterford City Council, 2002; and

viii. A number of other strategies and background studies.

5.2 Founded on this land use and policy planning framework, the development potential and priorities for Waterford City and its Environs are well documented. The national, regional and local policies all reiterate the following two key strategic development objectives for Waterford and its Environs:

° To deliver the potential of Waterford as a Gateway City

° To ensure that the development of Waterford City can be sustained by adopting a ”compact city‘3 approach to its development.

5.3 The Proposal advocates the boundary extension based on the argument that a single administrative authority would more efficiently deliver these development objectives. This is reflected in particular by the following statement in the Proposal:

3 The European Spatial Development Perspective, European Commission, 1999 defines a compact city as a city of short distances. This refers to areas of high density with ease of access between people‘s homes and places of work.

”the partitioning of Waterford City and its administration by two separate local authorities is not an appropriate or effective way of managing the growth of the city, implementing the long term strategy or promoting the city as a regional Growth Centre‘ The Proposal pp17

5.4 In this section, we demonstrate that this statement is flawed as it fails to recognise that the policy frameworks under which the Proposal will be assessed all recommend close cooperation with other local authorities, state agencies and Government departments to enable Waterford City to realise its potential. Kilkenny County Council is committed to this approach to the development of the area. As illustrated later in this response, Kilkenny County Council, working in partnership with Waterford City Council, has already advanced many of strategic objectives stated for the Gateway.

5.5 These points and issues are examined under the following headings:

A. Status of Waterford œ A Gateway

B. Status of Environs of Waterford

C. Promotion of the Region

D. Inter-Authority Cooperation

A. Status of Waterford œ A Gateway City

5.6 The NDP designated Waterford as a Gateway city. This designation is confirmed by the NSS which defines the function of a Gateway as:

”(to ensure that) balanced national growth and development are secured with the support of a small number of nationally significant centres, whose location and scale support the achievement of the type of critical mass necessary to sustain strong levels of growth in the regions‘ NSS pp39.

5.7 The designation of Waterford as a Gateway is developed in the SERPG and Waterford PLUTS in a suite of more detailed projects and initiatives designed to deliver the Gateway status of Waterford. The paragraphs that follow summarise and examine what the NSS, SERPG and Waterford PLUTS determine are the characteristics, role and functions of a Gateway and specifically Waterford as a Gateway.

• Characteristics of a Gateway

5.8 The NSS provides further guidance on the characteristics of a Gateway as:

i. Having a strategic location;

ii. Providing national scale, social, economic infrastructure and support services;

iii. A large urban population (of the order of 100,000 and above) set in a large urban and rural hinterland;

iv. A focal point in transportation and communication and integrated public transport with facilities for pedestrians and cyclists;

v. Integrated land use and transport planning frameworks;

vi. Phased zoning and servicing of land banks in anticipation of needs associated with growth; and

vii. Presence/or development of a Strategic Development Zone.

• NSS Waterford Gateway œ Critical Mass

5.9 Focussing on the Gateway potential of Waterford, the NSS states that:

”In the South East, there is substantial potential of the enhancement of critical mass through the further expansion of the Gateway of Waterford, including the port at Belview. This could be supported by improved connections from Waterford to towns in the surrounding counties and from Waterford to cities such as Dublin, Cork and Limerick‘ (NSS pp45.)

5.10 The NSS provides a framework for the South East Region which reiterates the need for collaboration between the urban centres in the Region to achieve the desired critical mass for Waterford City and its Environs to function as a Gateway. Specific recommendations include:

° Kilkenny has a potential role in conjunction with Waterford City, indicated by the deepening economic relationship between South Kilkenny and Waterford City.

° Kilkenny has developed a highly successful tourism economy based on the built heritage of the City, the heritage and scenic attractiveness of other towns and rural parts of the County and improved accessibility to Dublin. These environmental and heritage resources, plus tourism success and the general quality of life in Kilkenny are yielding dividends in terms of attracting investment.

° Wexford with its cultural and built heritage has a pivotal role in the South East, in conjunction with Waterford City, given its importance for its own hinterland and relationship with Rosslare Port.

5.11 Acknowledging the important roles of Kilkenny and Wexford, they are designated in the NSS as ”Hubs‘. The function of a Hub is to deliver balanced patterns of growth in an area supported by towns that link the capabilities of the Gateways to other areas. Furthermore, the NSS recognises the need for Waterford, Wexford and Kilkenny to build on their complementary strengths to deliver the critical mass needed to deliver the full potential of the South East Region and it states that:

”The growth of a Waterford/Wexford/Kilkenny triangle needs to be supported by a co-ordinated and integrated approach that builds on their complementary strengths.‘ (NSS pp 47)

5.12 The NSS further promotes that these three together form a nationally strategic ”growth triangle‘. It identifies that Waterford, Kilkenny and Wexford will drive regional growth by providing a large and skilled population base, substantial capacity for additional residential and employment related functions and improving transport network. Thus, it was not envisaged in the NSS that Waterford City would deliver the sufficient level of critical mass required to effectively function as a Gateway, but it would in fact be delivered through collaboration and cooperation with Kilkenny City and Wexford Town.

• South East Regional Planning Guidelines & Waterford PLUTS

5.13 The necessity for key centres in the Region to cooperate in delivering the critical mass for the South East Region4 to achieve its potential is further reinforced in the South East Regional Planning Guidelines (SERPG). The SERPG were adopted by the South East Regional Authority (SERA) in May 2004 and each local authority in the South East Region is obliged to take cognisance of their recommendations when preparing their development plans.

4 The South East Region is made up of Counties Carlow, Kilkenny, South Tipperary, Waterford and Wexford

5.14 The Waterford PLUTS was commissioned by Waterford City Council in 2001 and completed in September 2003. The PLUTS study area comprised Waterford City and its immediate area of influence, which radiates out from the City and includes the satellite towns of Tramore in County Waterford, Carrick-on-Suir in South Tipperary and New Ross in County Wexford along with a number of smaller settlements including Dunmore East, Kilmacthomas, Portlaw and Passage East within County Waterford, together with Piltown, Mooncoin and Kilmacow within County Kilkenny. It presents the key challenges facing Waterford over a 20 year period. Those related to its Gateway status are summarised below with the additional key challenges pertinent to the development of Waterford as a compact city examined later in the submission. The key challenges are identified as including:

° Achieving Critical Mass: employment, services, housing, healthcare, education, transport, social and recreation facilities

° Harnessing Excellence of the Education Resource: a new university for the South East and creating positive industry and education cooperation

° Utilising Existing Key Assets: old urban settlement, riverside location, local, national and international links, Port of Waterford, Waterford Institute of Technology, industrial base and tourist destination.

5.15 Many of the recommendations of PLUTS are integrated into the SERPG and are hence not repeated. That stated, PLUTS presents a number of specific development objectives for Waterford City over the period of the strategy i.e. to 2020. Later we illustrate how inter-authority cooperation is required to deliver many of the strategic objectives.

B. Status of Environs of Waterford

5.16 While the proposed boundary extension encompasses the Environs of Waterford in County Kilkenny, Waterford City Council has not stated its vision or development objectives for the area, other than reference in the City Development Plan to develop the Ferrybank area as a neighbourhood of the city.

5.17 The success of the Kilkenny County Council development strategy for the area is reflected in the relative strong growth experienced in the Suburbs of Waterford as presented later in this report. The framework for the success has largely been achieved through the traditional land use planning mechanisms of the County Development Plan zonings and objectives. The County Council has built on this framework to provide a more holistic development strategy and vision for the area which will further improve the potential and development opportunities for Waterford and the South East Region, in accordance with the recommendations of the NSS, SERPG and PLUTS. This is summarised below.

• Vision

5.18 Kilkenny County Council‘s vision for the area is:

To ensure that the people of the Waterford City Environs in County Kilkenny enjoy a good quality of life with a high standard of education, excellent employment prospects and easy access to a full range of social, economic and cultural services. This will be achieved through integrated planning and cooperation with Waterford City Council, all the other authorities in the region and other agencies, ensuring that Waterford and its Environs can compete internationally and maximise its potential as a Gateway City serving the entire South East Region.

• Strategic Objectives

5.19 The County Council development objectives for the proposed boundary extension area are presented in Volume 2 of Kilkenny County Development Plan 2002 and are set out in:

° Waterford City Environs Development Plan

° Belview Area Action Plan.

5.20 Within these plans, the stated objectives of the County Council for the Environs of Waterford and Belview are:

i. To meet the infrastructure and development needs of the area;

ii. To ensure integration of land use and transportation planning;

iii. To establish a clear demarcation between urban and rural areas within the area;

iv. To provide for the planned expansion of Waterford City north of the river from the core area; and

v. To provide for the development of Belview Port Area and to seek the designation the area as a SDZ5 under the Planning and Development Act 2000.

5 SDZs were introduced by Part IX of the Planning and Development Act, 2000. The Government can designate sites as SDZs where in their opinion specified development on particular sites is of economic or social importance to the State. Designation as an SDZ will provides a streamlined system for such development, following the making of planning schemes by the local authorities, by requiring planning applications in compliance with the scheme to be granted within two months of receipt by the authority, with no leave to appeal to An Bord Pleanála. The concept thus aims to ensure a much greater degree of certainty both in relation to securing planning permission and the time horizon involved in relation to development that is of strategic economic and social importance to the State.

• Plan for Neighbourhoods and District Centres

5.21 The 2002 Waterford City Development Plan 2002 identifies that the area north of the River Suir comprises one neighbourhood within the context of the city and its suburbs. In contrast, the Kilkenny County Development Plan recognises that neighbourhoods are of a much smaller and intimate scale than envisaged in the City Development Plan and provides for necklace of six neighbourhoods based on the principle of providing a range of facilities and services within easy walking distance of a neighbourhood scale local centre. The County Development Plan identifies that most people are prepared to undertake a ten-minute walk for local facilities and thus prescribes a neighbourhood with a maximum radius of approximately half a mile or 800 metres. This is consistent with the spirit of the compact city approach to development.

5.22 The County Development Plan also identifies the need for a higher order District Centre in the Waterford Environs and has zoned a site within the Ferrybank area for this purpose. This reflects that the population of the Waterford Environs north of the River Suir will grow to a population of some 15,000 œ 16,000 which represents approximately 20% of the City and its environs population target under both the NSS and SERPG. This designation and zoning responds to the needs of this emerging and expanding population; needs that cannot be served by neighbourhood scale facilities alone. Kilkenny is pursuing an approach and principle that is again consistent with the concept of developing a compact city.

5.23 The primary objective of the development of a District Centre at Ferrybank is to reduce the need for residents to travel to centres in Waterford City and south of the City to meet the majority of their shopping and other local services needs. The principle of a District Centre scale of facility at Ferrybank being appropriate has been endorsed by An Bord Pleanála (the Board) in its 2004 decision letter.

• Land Uses

5.24 In addition to the neighbourhood and district centre framework summarised above, the Kilkenny County Development Plan 2002 provides for a mixed land use approach which will realise integrated development that is in the interests of the proper planning and sustainable development of the area. This takes due cognisance of the framework provided by the 1998 Waterford Framework Plan. The Proposal has not set out any issues in respect of this approach or how Waterford City Council would do anything that is radically different or better. This highlighted, the total area zoned for each use is detailed in Table 5.1.

Table 5.1 Environs of Waterford Land Use Zoning 2002 Zoning Area (ha) Area (acres) Agriculture 79.3 195.9 Community Facilities 7.2 17.8 General Business 7.4 18.3 Industrial 85.6 211.4 Open Space 100.8 249.0 Residential 213.9 528.3 Residential (Arcadian)* 61.1 150.9 Total Area 555.1 1,371.1 Note 1: * Residential Arcadian permits lower density residential development due to the relatively high amenity value of the areas Note 2: Rounding errors may occur Source: 2002 Kilkenny County Development Plan

5.25 Land availability and development capacity are addressed later in this report, however, the mix of uses proposed for the Environs of Waterford within County Kilkenny are consistent with the proposed development vision for the area.

• Belview œ A Strategic Approach

5.26 The key hub of the Port of Waterford‘s infrastructure and operations is located at Belview in County Kilkenny. The Belview infrastructure comprises: a fully serviced container terminal; bulk, break-bulk/general cargo; and, a dedicated cement importation facility. A roll on œ roll off facility, excluding passenger traffic, is envisaged.

5.27 Kilkenny County Council has stated the objective of developing Belview as a SDZ in the County Development Plan. This objective is consistent with the NSS and SERPG, both of which recommend the development of an SDZ at a Gateway and specifically recommend enhancing the potential of Belview. The objectives of the County Council in relation to the development of Belview using the SDZ approach are:

i. To facilitate the location and development of port related industries and activities6 and services through the identification and reservation of suitable lands;

ii. The County Development Plan zoned an additional 32ha (79 acres) of land for port and directly port related activities, bringing the total area zoned for this objective to 106ha (262 acres), an increase of 43% since the 1994 Development Plan. This is reserved solely for businesses whose function is dependent on locating adjacent to the port;

6 Port-related industries and activities are those which, by their nature, must be located in close proximity to the port or which would be at a serious disadvantage if not located immediately alongside the port area.

iii. To reserve lands for strategic industries through the identification and zoning of suitable landscape compartments within which strategic industry7 may locate. The County Council has zoned five designated compartments totalling 169ha (417 acres) for this purpose. These compartments vary in scale from 18ha œ 50ha (44 œ 124 acres), providing the flexibility to match the needs of a range of strategic industries;

iv. To facilitate the location and development of appropriate ancillary activities and services through the identification and zoning of suitable locations where such uses can cluster. For example, these would include service and supply activities such as container and vehicle maintenance, welding services, warehousing, catering, accommodation and fuelling for vehicles. The provision of these services at the port will ensure that associated businesses can function efficiently in the area; and

v. To protect the environmental, agricultural and residential amenity of the area.

5.28 This approach has been developed in partnership and consultation with the Port of Waterford, IDA, Waterford Chamber of Commerce and local people and businesses. The County Council is committed to this approach and the objectives of the County Development Plan and this is evidenced by the excellent mutual working relationship that has been long established between the County Council and the Port of Waterford since the start of its relocation from Waterford City‘s North and South Quays in the early 1990s. Waterford City Council has been invited by Kilkenny County Council to participate in the process at all times but, despite its contention in the Proposal that the City has a symbiotic relationship with the port, engagement has been minimal. This sharply contrasts with the commitment and approach of Kilkenny County Council.

C. Promotion of the Region

5.29 A city should be planned within its regional context and not its administrative boundary as promoted by Waterford City Council. The European Commission‘s 1999 report on the European Spatial Perspective advocates the development of a region with a compact city at its core. This strategy of regional development by linking core urban areas with their regions is being pursued in the United Kingdom (UK) under the Core Cities initiative and this is being replicated throughout the leading mature economies of the European Union (EU). In the UK, the project involves the Core Cities of Birmingham, Bristol, Leeds, Liverpool, Manchester, Newcastle, Nottingham and Sheffield. The objective of the Core Cities is:

° To strengthen and promote the distinctive role of the Core Cities as drivers of regional and national economic growth

° To ensure that citizens, communities and businesses in Core Cities and their regions benefit from a high quality and sustainable environment

7 Strategic Industries are defined as industries that require very large sites (often 20+ha (49+ acres)).

° To ensure that the wider regional areas are involved with, and benefit from, the work progressed by the Core Cities.

5.30 The Core Cities initiative is reactive in response to the fact that economic development in UK cities lagged that of other comparable European cities and research found that throughout Europe there is a more effective partnerships between central government, regions and cities that has enabled cities to play more powerful economic roles than had been happening in the UK. While all of the UK cities listed above are significantly larger than Waterford, the lessons learned and model used is appropriate and transferable to regional development in the South East.

5.31 In the South East, SERPG advocates the development of Waterford as a compact city with a population of 70,000, as the engine of the region. The PLUTS has identified two key challenges that directly relate to implementing the compact city approach to development. These are:

i. Harnessing the riverfront potential and amenity, with the river as a central focus for the development of a ”new urban Irish experience‘. Bringing the northern banks of the Suir fully within the economic and social ambit of an expanded Waterford City; and

ii. Planning transportation networks that are appropriate and will integrate with designated land uses within a compact, sustainable city. Providing improved public transport with high quality designed residential developments at increased densities along public transport corridors.

5.32 According to the 2002 Waterford City Development Plan, Waterford has traditionally been a compact city with its neighbourhoods within walking distance from the city centre. The plan advocates enhancing the compactness of the city and states that an essential element of the sustainable development strategy is the development of the compact city, which is characterised by consolidation of existing and the establishment of new neighbourhoods. The rationale for this approach to the development of the city is presented in the City Development Plan as:

° A more compact form of development ensures access to and the efficient provision of services and reduces the need to travel

° A compact city will reduce land vacancy and underuse

° A compact city will protect the rural landscape, retain agricultural land and protect the environmentally sensitive rural habitat.

The Proposal builds on this strategic objective stating that:

”the compact city is an essential element of the City Council‘s sustainable development strategy‘ The Proposal pp 18

Closer examination of the approach and what is happening on the ground illustrates that Waterford as a compact city at the core of the Region is not delivering the desired results and is in fact increased commuting and dependence on private transport within the city‘s zone of influence.

5.33 Waterford City and its Environs play a key role in promoting the development of the South East Region in a similar manner to the strategy being adopted in the UK under the Core City initiative. From the Waterford City Development Plan the following two strategies can be derived as being pursued to ensure that Waterford can be developed as a compact city. These are:

i. The development of neighbourhood structures; and

ii. Rural planning in an urban area.

• Development of Neighbourhood Structures

5.34 The Waterford City Development Plan presents a development strategy for the city centre and six neighbourhood areas. These neighbourhoods should provide a range of facilities and services within a short distance from where people live, which is part of the strategy of developing Waterford as a compact city. Ferrybank was identified in City Development Plan as one of the six neighbourhoods. The Ferrybank neighbourhood, as defined in the City Development Plan extends into the areas administered by Kilkenny County Council and mirrors the area of the proposed boundary extension. Waterford City Council does not state any development objectives for the Ferrybank neighbourhood in the City Development Plan. This stated, both the City Development Plan and the Proposal recommend that to develop Waterford as a compact city will require the development of the Ferrybank to be optimised. However, contradicting the City Development Plan, the Proposal only identifies five neighbourhoods and excludes Ferrybank as a neighbourhood area of the city.

5.35 In contrast, and has been set out above, Kilkenny County Council‘s approach is more consistent with what the concept of the compact city seeks to achieve. This is evidenced by the County Development Plan‘s neighbourhood structure for the Environs of Waterford which is based on shorter distances of approximately a 10 minute walk. The County Development Plan is consistent with the City Development Plan‘s objectives but is translating the concept of the compact city that the City Development Plan purports to be pursuing in a way that is consistent with what the European Commission model seeks to achieve.

• Rural Planning in an Urban Area

5.36 The Waterford City Development Plan states that the rural area of the city is a component of the strategy of enhancing the compactness of the city and it provides a clear demarcation between the built up and rural areas. To this end, it is the policy of Waterford City Council to actively discourage the construction of new buildings and structures in the rural area other than for the purposes of agriculture, sport and recreation, one off housing or essential service installations.

5.37 Waterford City Council‘s administrative area spans a total of 4,157ha (10,268 acres). Of this, a total of 1,599ha (3,950 acres) is zoned for agricultural use within the City Council‘s administrative boundary. An additional 362ha (894 acres) is zoned for open space. The result is that a total of 1,961ha (4,844 acres) is zoned for either agricultural or open space use within the City‘s boundaries. This represents a total of 46% of the total area of Waterford City. In addition, it is estimated that Waterford County Council has zoned an additional 2,094ha (5,172 acres) surrounding the Waterford City boundary for agricultural use. Together, this provides a total of 4,055ha (10,016 acres) zoned for agriculture and open space in and around the southern environs of the city. The resultant ”green belt‘ has an area equivalent to 97% of the land mass of the City Council‘s administrative area. It effectively provides a ”double protection‘ of the rural area of the city. This is in an area where there are small sized villages and hamlets and not the expanding towns and villages which have coalesced around larger cities around the country.

5.38 These facts and figures are important when set in the context of Waterford Corporation‘s objectives for the 1980 boundary extension of the city, which was essentially to improve the development capacity of the city. Waterford City has not used the boundary extension to realise these objectives but has preserved a rural-urban fringe which does not contribute to the development of the city.

5.39 Looking to the proposed extension area within the Proposal, Waterford City Council seeks to mirror its approach rather than consolidate the compact city. This is well evidenced in the facts which reveal that there is 1,808ha (4,466 acres) of unzoned land within the boundary extension area, with a further 79ha (196 acres) zoned for agricultural use within the Environs of Waterford. Figure 5.1, presented in Appendix C, captures and illustrates the picture. Waterford City Council‘s concept of the compact city will include of the order of 3,843ha (9,505 acres) of land zoned for agriculture/open space if the proposal for a boundary extension were granted and if the current zoning objectives remain in place. This would represent a total of 59% of the newly extended city being zoned for agricultural use or open space.

5.40 Given the take up of residential and other development land even over the period of the NSS and SERPG to 2020, which is presented later in this report, the extension is not required or defensible. In terms of the interests of the proper planning and sustainable development of the city, the approach adopted by Waterford City Council does not represent the optimum use of land surrounding the city œ it is not consistent with the concept of the compact city and effectively represents rural planning in an urban area. This is contrary to the spirit of Waterford City Council‘s economic development objectives which seek to add value to economic output as it confines the residents of the area to agriculture or agriculture associated industry.

5.41 To put Waterford City Council‘s approach into context, a comparative analysis was undertaken of agricultural zonings and population densities in comparably sized cities in Ireland. The findings are summarised in Table 5.2.

Table 5.2 Proportion of Agriculture Zonings and Population Densities for Selected Centres Settlement Total Total Area of Total Area of Land % of Total Population Population1 Settlement (ha) Zoned for Area Zoned Density Agriculture (ha) for Agriculture2 Persons/ha Cork City 123,062 3,9611 02 0 31

Galway City 65,832 5,0571 1,1473 23 135

Limerick City 54,023 2,0351 02 0 27

Waterford City4 44,594 4,157 1,599 38 11

Waterford 2,142* 555 79 14 4 Environs6

Note: * This figure refers to CSO population of ”Suburbs of Waterford‘ in Kilkenny County which may differ from that of Waterford Environs Sources: 1. CSO Census of Population 2002 2. DTZ Pieda Consulting Estimate 3. Galway City Council Planning Department 4. Waterford City Development Plan 2002-2008 5. Subsequent to a recent boundary Extension 6. Kilkenny County Development Plan 2002 œ 2008

5.42 The table illustrates that, even though in population terms Waterford is smaller than the comparable Gateways of Cork, Galway and Limerick, it is in fact the second largest city in the group in terms of land area. Further analysis of the facts and findings show that: ° The population of Cork City is 2.75 times that of Waterford City, yet the administrative area of Cork City is 95% that of Waterford City. ° With an area 21% greater than the area of Waterford City, only Galway City is larger than Waterford City. However, the population of Galway is 45% greater than that of Waterford City. ° The population of Limerick City is some 21% larger than that of Waterford City, yet the area of Limerick City is 49% the size of Waterford City. ° Waterford has a substantially lower population density than most comparators. If the boundary extension proposal were to be granted, its population density would fall to 8 persons per ha.

5.43 While not indicated in the City Development Plan, the Proposal states that the land zoned for agricultural purposes cannot be developed at a reasonable cost. In September 2005, the Waterford City Outer Ring Road was opened. It runs through the southern area zoned for agricultural use in the plan and should reduce the costs of development of the area. This point is stated in the press articles reporting the opening of the road which state that the infrastructure should open up lands and facilitate construction of 5,820 houses as well as commercial development. The potential of the road to open up lands for commercial development is reflected in the fact that Variation 2, April 2005 of the Waterford City Development Plan has zoned areas adjacent to north eastern and north western parts the Outer Relief Road to accommodate Retail Parks/Warehouses.

° Development of the Region

5.44 Table 5.3 presents the relative growth of Waterford City and its surrounding towns that are within 40 minutes driving distance from the city centre, the four original Gateway cities, the South East Region and the State.

Table 5.3 Population and Population Change, Main Centres Surrounding Waterford City 1991-2002 % Change Area 1996 2002 1996-2002 County Waterford 52,140 56,952 9.2 Waterford City 42,540 44,594 4.8 Waterford Suburbs * 1,615 2,142 32.6 Waterford City and Suburbs 44,155 46,736 5.8 Dungarvan and Environs 7,175 7,452 3.9 Dunmore East 1,430 1,750 22.4 Tramore and Environs 6,536 8,305 27.1 South East 391,517 423,616 8.2 Cork 127,187 123,062 -3.2 Dublin 481,854 495,781 2.9 Galway 57,241 65,832 15.0 Limerick 52,039 54,023 3.8 State 3,626,087 3,917,203 11.1 Note: * Those elements located in County Kilkenny Categorised as Suburbs of Waterford Source: CSO, Census of Population, 1991, 1996 and 2002

5.45 The table illustrates that the growth of Waterford City lagged that of the South East, the State and of most other centres in the area, with the exceptions of Dungarvan and Environs. There is a marked contrast between the growth of Waterford Suburbs in County Kilkenny, which experienced a population growth of 32.6% between 1996 and 2002 and Waterford City which grew by 4.8% in the same period. The growth of Waterford City exceeded that of the cities of Cork, Dublin and Limerick, but not Galway over that period. This reflects a national trend whereby the suburbs or environs of the main cities are growing at a faster rate than the city areas. Therefore, the comparatively low population growth of Waterford City when compared with its environs and satellite towns is not unique but is a direct result of preferences amongst local populations for relatively low density residential schemes.

5.46 The growth experienced in Tramore and Dunmore East reflects their proximity to Waterford City and their continued development as dormitory towns for people working in the city and surrounding area. The growth of these towns has occurred despite the availability of residentially zoned land within the City Council administrative boundary to accommodate population growth to at least 2021 and possibly 2030. The relatively high growth recorded Tramore and Dunmore East, with associated increased commuting to the city centre, would suggest that the compact city strategy being implemented by Waterford City Council is not effective. The development of Waterford as a compact city will require Waterford City Council to cooperate closely with Kilkenny and Waterford County Councils to implement an agreed settlement strategy for the PLUTS area. This approach would be consistent with the recommendations of the PLUTS and SERPG and the strategic direction provided in the NSS founded on the European Spatial Development Perspective.

D. Inter-Authority Cooperation

5.47 A point made throughout the Proposal for the city boundary extension is that the division of the urban centre between two separate local authorities is contrary to the effective and convenient form of local government. It specifically states that:

”Inter-authority co-operation, while essential to the conduct of business, does not result in effective administration‘ pp17.

5.48 Kilkenny County Council does not accept this assertion. All national, regional and local policies advocate the principle of cooperation between local authorities to deliver a range of services to local communities. Both the SERPG and the PLUTS recognises the role of Waterford as a Gateway city and identifies a suite of strategic goals or principal features designed to deliver this potential. As outlined below, both the SERPG and the PLUTS identify that the achievement of these objectives will require inter-authority cooperation between Waterford City Council and Kilkenny, Waterford, Wexford, Carlow and South Tipperary County Councils along with a range of other state agencies and Government departments. The objectives and the mechanisms to achieve them demonstrate the emphasis on cooperation as follows:

° Population: more balanced growth between north and south of the River Suir to 2020. Provision for a population increase of almost 30,000 or 57% growth in Waterford City and its Environs to 2020. To achieve this there will be a requirement for approximately 11,500 new dwellings. It is also envisaged that there will be significant retail expansion in the expanding City Centre;

Cooperation between Waterford City Council, Kilkenny County Council and all other Councils in the Region working with the private sector.

° Improved Road Transportation: support the development of effective communications by road between Waterford and Dublin and also to the other Gateways. Support the development of internal road networks between the Gateway, Hubs and County Towns and other larger settlements and the better integration of land use and transport planning throughout the Region.

Cooperation between National Roads Authority (NRA) to work with Waterford City Council, Kilkenny County Council and other local authorities that link with the national primary and regional route networks.

° Air Access: Enhance regional accessibility to air services, building particularly on the important regional asset of the South East Regional Airport.

South East Regional Airport working in partnership with the Department of Transport, Waterford County Council and private air services operators.

° Sea Access: Establish a spatial policy framework through which development of the ports in the Region can be coordinated to deliver a critical mass of services and facilities, boosting the national and international competitiveness of the Region.

Achievement of this goal will require the Department of Communications and the Marine to collaborate with the Port of Waterford, New Ross Port Company and Rosslare Europort along with Waterford City Council and Kilkenny and Wexford County Councils.

° Rail Access: Promoting increased rail services between Waterford and Dublin. Improve the Rosslare œ Limerick (via Waterford) rail line and explore its potential as a means of commuting.

These are primarily a function of Iarnród Éireann working with all local authorities on the Waterford œ Dublin and Rosslare œ Limerick rail lines.

° Education: Support the establishment of a university in the South East by using and building on the existing network of third level educational establishments at Waterford, Carlow, Kilkenny, Clonmel and Wexford.

This goal acknowledges that Waterford Institute of Technology to achieve university status on its own, will require a partnership approach between the Institutes across the Region

° Strategic Development: Identify and facilitate the establishment of Strategic Development Zones (SDZ).

Kilkenny County Council has stated its objective of seeking a designation of Belview as a SDZ. To achieve full potential of this infrastructure, the County Council will work with IDA Ireland, Enterprise Ireland, Port of Waterford, Iarnród Eireann, NRA, DoEHLG, Department of Enterprise, Trade and Employment, Department of Communications and the Marine, Waterford City Council and Waterford Chamber of Commerce.

° Employment: Investment needed for almost 12,800 new jobs or 46% growth by 2020.

The key development agencies such as IDA Ireland, Enterprise Ireland and the City and County Enterprise Boards along with Waterford City Council and Kilkenny and Waterford County Councils will need to play their roles to ensure that a competitive environment is in place to attract this level of investment to the Region.

5.49 This illustrates that for Waterford to develop and fulfil its role as a Gateway will require substantial co-operation between Waterford City Council and Kilkenny and Waterford County Councils, other local authorities in the Region; other development agencies, State agencies and Government departments. Furthermore, the public sector will not be able to deliver all the objectives in isolation but will require the cooperation of the local community, the voluntary sector and the private sector. Such a cooperative approach to development is recommended in a range of European, national, regional and local policies. Later in the submission it is illustrated how Kilkenny County Council has effectively cooperated with Waterford City Council to deliver the full range of Council services.

• European Policies

5.50 At European level, the European Spatial Dimension Perspective (ESDP), recommends that Member States and regional authorities should pursue the concept of the ”compact city‘ in order to have better control over further expansion of the cities. To deliver this, the ESDP states that:

”it will only be possible to stem the expansion of towns and cities within a regional context. For this purpose cooperation between the city and the surrounding countryside must be intensified and new forms of reconciling interests on a partnership basis must be found‘. ESDP pp 22

5.51 Focussing on cooperation, the ESDP identifies the following key ingredients for partnership between urban and rural areas to achieve an integrated and coordinated response to development:

i. Equality and independence of the partners;

ii. Voluntary participation in partnership; and

iii. Consideration of different administrative conditions.

5.52 These recommendations made by the European Commission are designed to ensure that cities and regions can develop across Europe in a sustainable and integrated manner. Kilkenny County Council endorses these principles and advocates their adoption for the development of Waterford City and its Environs.

• National Spatial Strategy

5.53 The NSS clearly recognises that the area of influence of a Gateway covers the administrative boundaries of a number of local authorities. Furthermore, it recommends that local authorities and other agencies work together to harness the critical mass for the Gateways to function effectively and states:

”The strategies should focus on the practical realisation of the gateway or hub. In some cases, more than one local authority may be involved. However, provision has been made in the Planning and Development Act 2000 and in the Local Government Act 2001 for the preparation of joint plans and the use of joint committees between adjacent local authorities to address cross boundary issues, including transportation. Regional authorities, in cooperation with the local authorities and city and county development boards in the different areas, also have a role to play‘. NSS pp123

5.54 Thus, the need for adjoining local authorities to cooperate to deliver the critical mass required to function as a Gateway is not unique to Waterford but is consistent with the spirit and indeed the specific recommendations of the NSS. The area of influence and hinterlands of all gateways designated in the NSS span administrative boundaries of a number of local authorities. Therefore, from the NSS it is clear that cooperation is recommended in the NSS to delivery the potential of a gateway and is accommodated for in legislation.

• Regional & Local Policies

5.55 At regional level, the need for Waterford City Council and Kilkenny County Council to cooperate is acknowledged and well documented. The SERPG make specific recommendations in relation to the implementation of PLUTS:

”The Guidelines support the recommendations of the PLUTS. Following adoption of the PLUTS by the planning authorities in Waterford City Council, Kilkenny County Council and Waterford County Council, those authorities will need to agree on how best to cooperate and coordinate on implementation issues and to agree on appropriate joint monitoring and review structures.‘ SERPG pp 64

5.56 SERPG takes the requirement for inter-authority co-operation one step further by proposing the establishment of an implementation group to examine the development requirements and proposals for the PLUTS study area and it continues by stating:

”This area includes Waterford City as well as parts of Counties Waterford and Kilkenny. This implementation group would drive the process of developing the full potential of the regional Gateway as envisaged in the NSS, taking account of the need to deliver a consistent approach across administrative boundaries and it would advance detailed proposals for future incorporation into the development plan process‘. SERPG pp 123

5.57 Kilkenny County Council endorses this collaborative approach to the development of the South East Region and is at the forefront of establishing these cooperative mechanisms. These mechanisms should help to provide a framework for the development of Waterford as a Gateway, though it is recognised that additional structures will need to be established to implement the recommendations of the PLUTS.

5.58 PLUTS also acknowledges the challenge posed by its implementation and the requirement cooperation and coordination to achieve strategic objectives set out in the strategy. It identified the ”key strategic issues‘ facing its implementation as:

° Agreeing a joint implementation and monitoring structure that facilitates efficient cooperation and co-ordination between relevant local authorities

° Ensuring that all relevant agencies and major stakeholders commit to the plan

° Co-ordinate across a range of capital projects as well as in management

° Provide the staff, technical and financial resources for rapid implementation of specific flagship projects in order to demonstrate the vitality of PLUTS and the plan process.

5.59 Specifically PLUTS states that:

”The local authorities in Waterford City Council, Kilkenny County Council and Waterford County Council will agree on how best to co-operate on implementation issues to agree on appropriate joint monitoring, and review structures‘ PLUTS pp67

5.60 The Waterford PLUTS was adopted by Kilkenny County Council on 17 May 2004. The County Council recommends the adoption of the approaches to the development of Waterford and its Environs as set out in the PLUTS. As the lead agency, Waterford City Council was to establish implementation mechanisms to advance the recommendations of PLUTS. No progress has been made on this. Kilkenny County Council has sought to cooperate with such implementation mechanisms.

• Local Service Delivery

5.61 Within the Waterford City Development Plan, Waterford City Council acknowledges the need to collaborate with adjoining local authorities to effectively deliver the full range of council services. The City Council takes this a step further and adopts this cooperative approach to the delivery of council services as a stated and adopted policy of the Council within the plan. The specifics of these policies are presented later in this submission. This noted, these policies indicate an acknowledgement by Waterford City Council that it cannot effectively deliver either the traditional Council services nor achieve the development challenges posed by the city‘s status as a Gateway acting alone, but will require a significant level of inter-authority cooperation. Kilkenny County Council also accepts this principal and, later in this submission will demonstrate that the County Council has worked with Waterford City Council to deliver effective local authority services in the Environs of Waterford and into Waterford City.

5.62 In 1996, the Department of the Environment and Local Government (now the DoEHLG) published ”Better Local Government œ A Programme for Change‘. This document identified a suite of changes to the structures and processes of local government to ensure that they deliver good governance and improve the level of service delivery. A key initiative under this programme was the establishment of the County and City Development Boards (CDB). The CDB comprise representatives of local government, the community and voluntary sector, farming and employer representative organisations, trade unions and development agencies. The requirement for the CDB acknowledged the need for cooperation and better integration of all public services delivered locally. Subsequently, both the Kilkenny County Development Board and Waterford City Development Board prepared a 10 year county and city strategies for the social, economic and cultural development of their respective County and City. The Kilkenny CDB strategy acknowledges the need to cooperate with adjoining counties to deliver the regionally important initiatives. Therefore, in addition to Kilkenny County Council, the Kilkenny CDB acknowledges the need for cooperation to deliver the full potential of Waterford City.

CONCLUSION

Waterford City was first designated as a Gateway by the Government in the NDP. This designation was reinforced in the NSS which provided a framework for delivering the potential of Waterford City as a Gateway. It primarily involved harnessing critical mass of infrastructure, skills, facilities and services by the development of the Waterford œ Kilkenny œ Wexford growth triangle. Thus, it was not envisaged that Waterford would operate effectively as a Gateway in isolation, but would require close cooperation between other local authorities in the South East Region. The requirement for this collaboration and coordination of effort for Waterford to fulfil its potential as a Gateway is further emphasised in the SERPG and in the Waterford PLUTS. Furthermore, whilst the 2002 City Development Plan states a strategic objective of seeking a boundary extension of the city to the north of the River Suir, the principle of cooperation between the City Council, Kilkenny County Council and other local authorities, State agencies and Government departments is accepted and is adopted throughout the City Development Plan as a requirement to deliver the full range of local authority services to the city effectively. As such, the Boundary Extension Proposal contradicts the adopted policies of Waterford City Council as stated in its 2002 Development Plan.

While the development of Waterford City as a compact city is consistent with recommended approaches to sustainable development, the methods being pursued by Waterford City Council to achieve this strategy is at odds with the concept. The preference of the local community is for lower density residential schemes and therefore, residential development is bypassing the city in favour of the coast and other centres, which in turn is having the effect of encouraging commuting.

In a city, such as Waterford, where there is limited demand for high density residential developments, a more appropriate approach would be to continue to zone lands closer to the city for residential purposes, with appropriate development densities consistent with the recommendations set out in Residential Density Guidelines. This, combined with the development of an integrated transport system and the implementation of a network of neighbourhoods that provide a range of services for the local population, would enhance the attractiveness of the city as a place to live. Such an approach would help to abate the increasing level of commuting to and from dormitory towns thus improving the compactness of the city.

Kilkenny County Council has planned for the development of the Environs of Waterford in a manner that is consistent with and contributes to delivering the role and the potential of the city as a Gateway. The neighbourhood and district centre approach to development of the Environs of Waterford as proposed in the 2002 Kilkenny County Development Plan will help to achieve this goal.

Kilkenny County Council is working to harness the full potential of the Port of Waterford at Belview by seeking a designation of the area as an SDZ to facilitate speedy development of the area and attract strategic industries to the Region. This is consistent with the recommendations of both the NSS and SERPG.

Inter-authority cooperation to deliver development objectives is an accepted principle at European, national, regional and local levels. Kilkenny County Council fully endorses this approach to development as is evident in the County Council‘s current policies and past actions. Furthermore, it is a principle that is accepted by Waterford City Council which has set a policy of cooperation with adjoining local authorities to deliver a range of local authority services. Therefore, when stating that inter-authority cooperation does not deliver effective local government, Waterford City Council is contradicting its own adopted policies along with broadly accepted principles and recommendations relating to local development.

Section 6: Development Capacity within Waterford City

6.1 In order to justify an extension of Waterford City‘s boundary, a key question that needs to be addressed is ”does Waterford City have sufficient capacity to develop in the long term?‘ This can be answered by assessing the level of population growth against the quantum of land zoned for residential, employment and other uses that is available to accommodate this growth. But this cannot be considered in isolation; it needs to be reviewed in the context of the development capacity provided in the Environs of Waterford along with the strategic development potential of Waterford City and Region. These issues are assessed in this section under the following headings:

A. Population Projections;

B. Housing Supply in Waterford City;

C. Housing Land Availability in Waterford City and its Environs; and

D. Land available for other uses in Waterford City.

A. Population Projections

6.2 As shown in Table 6.1, SERPG provides a likely population projection for the South East Region to 2020 and PLUTS presents an estimate of population growth for Waterford City and its hinterland over the same period.

Table 6.1 Population Projections for South East and the Waterford PLUTS Area 2002 - 2020 Growth % Growth Area 2002 2020 2002 - 2020 2002 - 2020 Region 423,616 463,740 40,124 9.5 PLUTS Study Area 119,077 163,278 44,201 37.1 Source: Regional figures œ SERPG, Waterford PLUTS Study Area œ Waterford PLUTS

6.3 There is a difference between the growth projected for the South East Region and the PLUTS study area whereby the quantum of population increase for the latter exceeds the total projected growth for the South East Region. While this can be explained by the inexact nature of forecasting, the figures illustrate the relative importance of the PLUTS area in relation to accommodating the majority of the growth of the Region.

6.4 This concentration of growth in Waterford City and its hinterland is further reiterated in the SERPG which recommends that Waterford and its hinterland plans for a growth of its population to 70,000 by 2020. This would represent a growth in the order of 20,000 persons in the area, or approximately 50% of the population growth forecast for the Region to 2020. Therefore, it will be necessary for the City Council and Kilkenny and Waterford County Councils to demonstrate that together they will be able to accommodate this level of forecast population growth within Waterford City and its Environs.

6.5 The City Development Plan presents more detailed population projections to 2021 for Waterford City and its Environs. These population projections for the city and its environs are underpinned by the acknowledgment in the City Development Plan that:

”changes in population and demographic trends are not respectful of administrative boundaries.‘ Waterford City Development Plan pp12.

6.6 The City Development Plan applies three assumptions to form the basis of the population projections for Waterford and its hinterland for the period 1996 œ 2021. The population forecasts used in the City Development Plan are similar to those presented in the SERPG, with the population of Waterford City and its Environs, including those in County Kilkenny, likely to grow to 62,324 or 68,678 by 2021, as set out in Table 6.2

Table 6.2 Population Projections for Waterford City & Environs 1996 œ 2021 % Growth Growth Scenario 1996 2001 2006 2011 2016 2021 1996 - 1996 - 2021 2021 Nil Net 49,497 50,394 52,468 54,198 55,564 56,449 6,952 14.0 Migration1 Inward Migration 49,497 51402 54,588 57,516 60,144 62,324 12,828 25.9 12 Inward Migration 49,497 52,410 56,750 60,966 65,002 68,678 19,181 38.8 23 Notes: 1 dropping fertility rates and improving survival rates 2 growth of 26% 3 growth of 39% Source: Waterford City Development Plan 2002

6.7 The City Development Plan uses these population projections to derive two scenarios that forecast housing demand in Waterford City and its Environs to 2021. These are set out in Table 6.3. The forecasts of demand for housing are based on the following assumptions:

i. Assumption 1: Nil Net Migration; and

ii. Assumption 2: 4% Inward Migration. This is based on Inward Migration 2 Population Forecast as presented in Table 6.2.

Table 6.3 Household Projections fro Waterford City & Environs 1996 - 2021 1996 2001 2006 2011 2016 2021 Assumption 1 15,091 15,897 17,146 18,248 18,771 19,600 Assumption 2 15,091 16,533 18,546 20,527 22,185 23,847 Source: Waterford City Development Plan 2002

6.8 From an analysis of the data, it can be deduced that forecasts are based on an average household size reducing from 3.28 persons per unit in 1996 to 2.87 persons per unit by 2021. Under the two growth scenarios, the City Development Plan forecasts that in the order of 4,500 and 8,700 residential units will need to be built between 1996 and 2021 to accommodate the projected population growth. The City Development Plan then concludes that it will be necessary to plan for over 8,000 new households in City and its Environs, including those in County Kilkenny, by 20218. However, there is an inconsistency in City Development Plan which later states that in excess of 9,000 units will be required to accommodate the population growth forecast to 2021 and the difference is not explained in the plan9.

B. Housing Supply in Waterford City

6.9 Between the two City Development Plans of 1994 and 2002, it is estimated by Waterford City Council that in the order of 121ha of greenfield land was consumed by housing development at an average density of 8.6 units per acre or approximately 22 units per hectare. The Residential Planning Guidelines for Planning Authorities, which were issued by the Department of the Environment and Local Government in 1999, presents a range of residential densities for town and city centres, brownfield sites, inner suburban infill and outer suburban/‘greenfield‘ sites. The guidelines highlight that:

”the greatest efficiency in land usage on such lands (suburban/‘greenfield‘ sites) will be achieved by providing net residential densities in the general range of 35 œ 50 dwellings per hectare (14 œ 20 per acre).‘ Residential Planning Guidelines pp11

8 Waterford City Development Plan 2002 pp12 9 Waterford City Development Plan 2002 pp 28

6.10 Therefore, development in Waterford City between 1994 and 2002 was characterised by low density schemes. Waterford City Council recognises that the continuation of these low densities may not be sustainable.

6.11 The City Development Plan zones a total of 974ha (2,406 acres) for residential development, of which 632ha (1,561 acres) are developed and 342ha (845 acres) are undeveloped. Thus 35% of the total land zoned for residential purposes is undeveloped. The City Development Plan states that:

”The undeveloped residentially zoned land within the City has the capacity, having regard to the Residential Density Guidelines, to accommodate 13,000 units, which is well in excess of the predicted demand‘ (Waterford City Development Plan pp26)

6.12 Based on the projections presented in the City Development Plan, there is sufficient land zoned for residential purposes in Waterford City‘s administrative area to accommodate between 144.0% and 162.5% of the demand for housing in Waterford and its Environs to 2021. Thus, it is evident that there is sufficient land zoned for residential use in Waterford City Council‘s administrative area to accommodate forecast population growth beyond 2021 and possibly onto 2030.

6.13 The City‘s Development Plan states that this capacity exists on undeveloped land although it does not present the quantum of brownfield land suitable for development. Thus, it can be assumed that there is additional scope to increase residential capacity on brownfield site within the city centre, in accordance with the recommendations of the Residential Planning Guidelines. Such central urban areas generally provide the potential for local authorities to deliver higher density schemes.

6.14 The City Development Plan states that the Housing Strategy for Waterford City identified a number of positive indicators in relation to the supply of housing. These were:

° An adequate supply and range of zoned and serviced land arising from the Serviced Land Initiative and the Planning and Settlement Strategy

° Existing planning permissions for housing not yet commenced

° Proposed improvements in strategic infrastructure both nationally, regionally and within the city

° Potential development in the environs of the city and South Kilkenny and in East Waterford including Tramore and Dunmore East.

C. Housing Land Availability

6.15 Figure 6.1 illustrates the level of housing completions in Waterford City, Waterford County and Kilkenny County between 1995 and 2003.

Figure 6.1 Housing Completions Waterford City, Waterford County and Kilkenny County 1995 - 2004

1400

1200

1000 s n

o 800 i

t Waterford City e l p Waterford County m 600 o

C Kilkenny County

400

200

0 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 Year

Source: Department of the Environment, Heritage & Local Government 2005

6.16 The figure shows a sustained growth in housing completions in Counties Kilkenny and Waterford between 1995 and 2004. Growth in housing completions in Waterford City fluctuates over the period, with very rapid growth experienced after 2002. The upsurge in delivery of dwellings in the city is a result of a number of factors with the availability of tax incentives being a key one. This point is reiterated in the City Manager‘s City Development Plan Progress Report 2004. However, for such schemes to be sustainable they should be market led and not incentive driven. The success of these schemes can only be measured as they mature over time.

6.17 Housing Land Availability (HLA) refers to the level of zoned and serviced housing land available for development. HLA data are provided to the DoEHLG in June of each year. At the time of this submission being prepared, HLA figures for 2005 were not yet published. As at June 2004, there was a total of 174ha of HLA in Waterford City. This represented 50% of the remaining greenfield land zoned for residential use in the City as detailed in the Waterford City Development Plan. It was estimated that this could accommodate in the order of 4,743 residential units or almost 53% of the housing requirement of the Waterford City and its Environs to 2021.

6.18 In contrast, there was a total of 188ha (464 acres) HLA in the Environs of Waterford in 2004. This represents 68% of the land zoned for residential purposes in the Environs of Waterford, be it that a proportion of this land has already been developed. It is estimated that this HLA could accommodate just over 4518 residential units. By combining the housing land available in Waterford City and its Environs, there is capacity to immediately deliver over 9,200 units. Hence there is sufficient housing land available to accommodate the projected population growth of Waterford and its Environs in County Kilkenny to 2021. Therefore Kilkenny County Council recommends that both local authorities cooperate to ensure that these areas can be developed in an integrated manner according to the recommendations of PLUTS.

D. Land Available for Other Uses

6.19 The quantum of land zoned in each category under the 1994 and 2002 Waterford City Development Plans is presented in Table 6.4.

Table 6.4 Land Use Zoning Maps 1994 & 2001 Change Change Total 1994 Total 2002 Zoning 1994 œ 2002 1994 œ 2002 ha ha ha % Residential 1,036 975 -61 -6 City Centre Commercial 30 40 10 32 General Business Use 57 95 38 67 Port Related 7 0 -7 -100 Industrial & Employment 429 347 -82 -19 Use Community Facilities 202 164 -38 -19 Open Space 295 362 67 23 Agriculture 1,570 1,599 29 2 Un-zoned 486 288 -198 -41 Total per Zoning Maps 4,112 3,869 -243 -6 Total City Area 4,112 4,157 45 1 Unaccounted for Land 0 288 288 N/A Source: Waterford City Development Plans, 1994 & 2002 Note: Variations were made to the 2002 Waterford City Development Plan. These allowed for additional mix use lands at Ballytruckle/Kilcohan and residential use at Kilcohan/St. Hiberlain, warehouse retail adjacent to the Outer Ring Road along with the adoption relaxing zoning use of protected structures, in addition to adoption of Local Area Plans in the North West Suburbs and Ballytruckle/Kilcohan.

Rounding errors may occur

6.20 The comparative analysis of the figures from the two plans indicates that there has been a number of key changes in the quantum of land in Waterford City between 1994 œ 2002. These changes can be summarised as follows: i. The amount of land zoned for residential purposes was reduced by 61ha or by 6%. That stated, there is sufficient land zoned for residential purposes to cater for population growth of Waterford City to 2030; ii. The level of land zoned for industrial use was reduced by 82ha or 19%. A total of 346ha is available for industrial use, of which 186ha is available for development. Of this, 40ha was available at the IDA Industrial Park on the Cork Road. A 31ha Business and Technology Park is being developed in the western suburbs. Thus, it can be concluded that there is sufficient land zoned for industrial use to accommodate the long term industrial development and employment creation objectives for the City; iii. The allocation of land zoned open space increased by 67ha to 362ha which is a significant increase of nearly 23% particularly given the reductions in both residential and industrial zoned lands and the fundamental basis of the City Council‘s proposal for an extension to the city‘s boundary; and iv. A total of 1,961ha was zoned for a combination of open space and agricultural use in the City area in 2002. This represents an increase of 96ha over the quantum of land zoned for these purposes in the 1994 City Development Plan. In 2002, the areas zoned for agriculture and open space combine to make up 46% of the City area. This significant zoning or the City Council‘s approach does not improve the compactness or optimise the development potential of the city.

CONCLUSION The Boundary Extension Proposal argues that the proposed boundary extension is required due to the development constraints within the current city boundary. Kilkenny County Council strongly refutes and questions this assertion. ° There is more than sufficient land zoned for residential purposes to accommodate the increase in population to 2021 and even on to 2030 within the City Council‘s administrative area. ° The Waterford City Development Plan identifies that there is a total of 184ha available for development for industrial use. There is sufficient land zoned in Waterford to accommodate a range of industries and employment uses in the long term.

Of significant importance to the Boundary Extension Proposal is the fact that a total of 1,599ha (3,950 acres) or 39% of the total land in Waterford City Council‘s administrative area is zoned for agricultural use. This represents rural planning in a city area. Kilkenny County Council strongly recommends that instead of seeking a boundary extension, the City Council should look to the development potential of this land, particularly as the Waterford City Outer Ring Road has now opened up the area to development œ a fact that has been publicly acknowledged by Waterford City Council in the media. This refutes the City Council‘s fundamental case for a boundary extension as set out in its proposal.

Section 7: Financial Implications 7.1 This assessment of the financial implications comprises four main sections, namely: A. A summary of the conclusions B. A description of the approach to the review C. An overview of the current financial position of the Councils D. A programme group by programme group assessment of the financial implications, and E. A detailed assessment of the financial implications.

A. Summary of Conclusions

7.2 The key conclusions from the financial review are that: 1. After taking account of: • The annual revenues losses of ⁄1.76 million that would be incurred by Kilkenny County Council; • The limited potential for Kilkenny to achieve cost reductions in its operations and staff, which are estimated at ⁄0.72 million annually; and • The increase in net expenditure proposed by Waterford City in respect of the extension area; the outcome of the proposed boundary extension would be a net loss to the two Councils totalling ⁄1.68 million in the first year of the proposed extension. This net loss would fall progressively to ⁄1.21 million after 11 years as the commercial ratepayers in the proposed extension area transfer onto the City‘s higher rates charge, but would remain a net loss. 2. To recover its lost revenues, Kilkenny would have to increase its rates charge in the remainder of the County by over 20%, or alternatively seek additional funding from central Government; 3. At the same time, to fund the City‘s increase in annual operating costs, ratepayers in the proposed extension area would suffer an increase of 28% as a result of the City‘s higher charges plus all ratepayers in the newly extended City would face an increase of 5%. Alternatively more funding from central Government or higher user charges would be needed. 4. In addition, if the proposed extension were to proceed, the County would transfer assets that have been funded from its own resources and that have an estimated market value of close to ⁄1 million to the City. 5. Furthermore, the people of Kilkenny are entitled to the future benefits of the County‘s substantial investment in roads, water, waste water and other services in the proposed extension area.

7.3 In its proposal document, the City claims the following amongst its reasons for seeking the boundary extension:

• An extended urban boundary will assist in securing the long-term financial base for the city. (Proposal pp2) • The provision of local services by two separate local authorities namely (Waterford City Council and Kilkenny County Council) within a single geographical urban area militates against consistency in quality, economies of scale and equity in distribution. (Proposal pp2)

7.4 In response to these points the financial analysis leads us to conclude that:

• The proposed boundary extension provides no improvements in economies of scale or efficiency of service provision. This is primarily because Kilkenny County Council is an efficient Council and cannot save all the costs of providing services to the area.

• If the proposed boundary extension were to proceed, and if Waterford City‘s financial base were to be secured, it would therefore be done at the cost of weakening the financial base of Kilkenny County to a very significant extent.

• From a financial and service provision basis, the proposed boundary extension should not therefore proceed.

B. Approach to the Review and Assumptions Used

7.5 The purpose of this review is to assess and quantify the financial implications of the proposed boundary extension for Kilkenny County Council and Waterford City Council. The Boundary Extension Proposal from Waterford City Council provides details of the expenditures that it proposes to incur if the boundary extension were to take place. In this review, the approach has been to accept the City‘s expenditure proposals and replicate this data where necessary in making this assessment. However, there are particular instances where the financial data presented by Waterford City is not accurate and therefore, where necessary, the data are amended. Where this happens the reasons are clearly stated.

7.6 The approach used by Kilkenny County Council in making this assessment has been to:

1. Review the overall financial position of the two Councils;

2. Carry out a line-by-line examination of all services and activities and identify those that would be affected if the boundary extension proposal were to proceed;

3. Identify the expenditures and incomes related to these activities and assess the scale of the impact;

4. Assess the potential direct, indirect administration and central management cost reductions that may be gained as a result of the proposed boundary extension; and

5. Assess the impact of the proposed boundary extension on Waterford City and Kilkenny County Council in Year 1 and over the length of the transition period proposed by the City.

7.7 In carrying out this assessment, the following assumptions have been used;

• Any income lost as a result of the transfer of services to Waterford City would be lost immediately by Kilkenny County Council, and the full impact of it will be borne in Year 1 and each year thereafter.

• Reductions in expenditure related to materials used or external contractors are considered to occur immediately.

• Expenditure savings from reductions in staff will be realised progressively over a period of three years. This reflects the likelihood that the realisation of any such savings is dependent on transfer opportunities arising, retirement or voluntary parting.

• All reductions in expenditure incurred by Kilkenny County Council have been calculated using 2004 actual financial data unless stated. This is to ensure that the basis for the response is the same as that of the City‘s proposal.

• We make no assumptions in respect of any emoluments or payments made to staff transferring from Kilkenny County Council to the City Council or in respect of any possible redundancy payments.

• An eleven-year financial profile has been prepared, based on the eleven- year transition period proposed by Waterford City Council. No provision has been made for inflation in these assessments. All future projections are at current prices

• The capital assets that would be involved if the boundary extension were to take place are described in this section. These assets have been purchased by Kilkenny County Council using the Council‘s own resources and the view of the Council is that if any such assets were to be transferred, compensation should be provided at current market value.

C. Overview of the Current Financial Position of the Two Councils

7.8 The Needs and Resources model is a computer based allocation system that distributes the general purposes element of the Local Government Fund amongst the local authorities in Ireland. In doing so it measures the performance of each local authority against income and expenditure targets to assess the relative efficiency and effectiveness of the authorities. Many of the targets are based on the average performance of the 88 rating authorities in Ireland targets, and as such are considered the —average practice“, not necessarily —best practice“

7.9 The detailed financial information submitted to the Department of the Environment, Heritage and Local Government by both Kilkenny County Council and Waterford City Council were analysed and the actual expenditures shown in those returns compared to the relevant targets were as follows:-

Table 7.1 Comparisons of Expenditure with Needs & Resources Targets Expenditure Target % ⁄million ⁄million

Kilkenny County Council 54.68 61.60 90

Waterford City Council 39.98 44.21 89

Both Kilkenny County and Waterford City Councils have a shortfall of the order of 10% when actual expenditure is compared to the target expenditure shown in the Needs and Resources model. This means that both Councils have an expenditure that is broadly 10% lower than the average of their peers. This can indicate either efficiency in expenditure or, potentially, a lack of resources.

7.10 The comparison for incomes is as follows:-

Table 7.2 Comparisons of Incomes with Needs & Resources Targets Income Target % ⁄million ⁄million

Kilkenny County Council 35.51 31.43 113

Waterford City Council 21.11 24.55 86

These income figures exclude the Local Government Fund receipts and rates income. The figures show that compared to the targets, which are based substantially on average performance, Kilkenny County Council performs well. On the other hand, Waterford City is underperforming its target income by some ⁄3.44 million per annum or 14% of the target.

7.11 These comparisons indicate that Waterford City Council is not effective in respect of generating income. This relatively poor performance is masked to some extent by the City‘s relatively high rates charge. It indicates that its relatively low expenditure is based on a resource shortage, whereas that of Kilkenny is based on efficient operations. From a financial perspective, the rates income derived from the proposed extension would merely mask the underperformance of the City in generating income from other sources. It suggests that —securing the long term financial base for the City“ would be better served by the City improving its existing performance and not diverting resources from a neighbouring County through a boundary extension.

D. Programme Group by Programme Group Assessment

7.12 An assessment of the impact on the income and expenditure of Kilkenny County Council if the proposed boundary extension were to proceed was carried out on a programme group by programme group basis. The results of the analysis are summarised in table 7.3:

Table 7.3 Overview of Programme Group Impact Reduction in Reduction in Loss / Benefit Impact on County Kilkenny Income E xpenditure ⁄ ⁄ ⁄ Programme Group: Housing & Building 61,019 14,902 46,117 Roads Transportation and Safety 145,716 74,006 71,709 Water Supply and Sewerage 128,837 112,361 16,476 Development Incentives and Control 49,070 50,000 930 Environmental Protection 126,300 100,900 25,400 Recreation and Amenities 15,132 103,400 88,268 Agriculture, Education, Health and Welfare 0 0 0 Miscellaneous 0 268,262 268,262 Sub-total 526,074 723,831 197,757 Rates 1,233,343 Net Change 1,035,586

The assessment shows that the impact on Kilkenny County Council is a net cost of ⁄1,035,586 per annum. The basis on which these findings are made and the results of the review for each individual programme group are shown in the following sections.

Readers should note that the reductions in expenditure shown in the following assessments do not represent the full cost of providing these services in the area cited in the boundary extension proposal. They are assessments of the expenditure reductions that would be achieved, and represent merely a fraction of the current costs of providing the services.

7.13 Programme Group 1: Housing and Building

If the proposed boundary extension were to proceed, the implications for Programme Group 1 are that on the basis of 2004 activity levels

• 1 out of 115 Emergency Repairs and Disabled Persons Grant applications; • 8 out of 184 housing loan applications; and • 34 applicants in the County‘s Housing applications list would be transferred.

It is noted that Waterford County Council proposes that it will not take over any of the houses provided by Kilkenny County Council in the area. However, these houses are served from an Area Office and depot based in Newrath in the proposed extension area. The City Council proposal is silent in respect of the transfer of this Area Office; however, it would not be logical for Kilkenny County Council to maintain an Area Office in another local authority area.

It is therefore concluded that the Waterford City proposal that Kilkenny County Council retains these houses is not realistic and this assessment assumes these houses being transferred. The number of houses involved is 24 out of Kilkenny County Council‘s estate of 1,150 houses.

The following table shows the assessment of the impact of the transfer of these activities.

Table 7.4 Housing Programme Group Impact Reduction in Reduction Programme Group 1 Expenditure i n I n come ⁄ ⁄

Local Authority Houses 5,379 46,591 ERG / DPG grants 9,522 14,428

Total 14,902 61,019

The savings shown in respect of local authority housing refers to materials used in maintaining houses. The scale of the activities that would be transferred is so small that no direct staff, indirect administration staff, central management staff or other operating cost savings would be possible. The reduction in income arises from the rents paid by tenants in the boundary extension area. This is an example of where the reductions in expenditure are far below the costs of providing the service.

In its proposal, Waterford City has made an allowance in respect of Public Liability Insurance on a Programme Group by Programme group basis. The impact on insurance costs is reviewed under Programme Group 8.

In conclusion, the Waterford City proposal would have a net annual cost implication of ⁄46,117 for Kilkenny County Council in Programme Group 1.

7.14 Programme Group 2: Road Transportation and Safety

In this programme group four areas where the proposed extension would have a financial impact on Kilkenny County Council are identified. These are:

• National Primary and Secondary Routes • Regional and local roads • Motor Tax Office transactions, and • Public lighting

• National Primary and Secondary Routes Expenditure on National Primary and National Secondary routes is funded by National Roads Authority œ it is a contra item, however the Waterford City view that the transfer of these roads would have no financial impact is not valid.

The total road network in Kilkenny County is 3,064.2 kms, of which 216.1 kms are National Primary and Secondary routes. Of these national routes, 9.9 kms would transfer to the care of Waterford City if the boundary extension were to proceed. Local roads are discussed in detail below; however, at this point it is noted that the length of local roads that would be transferred is 42 kms. The total length of roads transferred amounts to 51.9kms of all types of road or 1.6% of the total roads in Kilkenny. A reduction of this scale is not sufficient to allow Kilkenny County Council to achieve any savings in respect of staff, vehicles, depot costs or management and administration.

In respect of National Primary and National Secondary Routes, it is concluded that the NRA grants will be transferred on a pro-rata basis, and therefore the income lost will be as shown in the summary table. The operations of the roads maintenance division have been examined and it is concluded that the costs of external contractors used for road maintenance will be saved. However, the length of roads being transferred is small relative to the overall length in Kilkenny County. Consequently, it is not reasonable to expect any savings from direct staff, depots, vehicles or engineering staff. Therefore, other than contractor costs, the realisable savings will amount only to the road maintenance materials used.

• Local Roads The length of local roads that would be transferred is 42kms, or 1.65% of the total length of local roads in Kilkenny Council. As in the case of the National Primary and Secondary routes, it is concluded that no savings other than material costs and third party contractors would be possible.

It is also concluded that a pro-rata reduction in local road maintenance and upkeep grants provided by the Department of the Environment, Heritage and Local Government will occur.

• Motor Tax Office The volume of transactions that would be transferred is estimated at 2,000 out of a local number of transactions of 92,000. Given that many of these transactions are now completed on-line, it is not envisaged that any staff costs or indirect costs would be saved, except for some marginal savings in post and stationery.

While the motor tax collected is paid into the Local Government Fund, Kilkenny County Council will lose the allowance provided by the Department of the Environment, Heritage and Local Government in respect of Motor Tax Office costs. This has been allowed for in this assessment.

• Public Lighting The total number of public lights in Kilkenny is 6,057. Of these, 585 or 9.7% are in the proposed extension area. The cost of lighting on National routes is recouped from the NRA, but other lighting is funded by the Council. In this assessment savings in respect of the total costs of lights on non-national roads and housing estates are shown.

The following table shows the assessment of the impact of the transfer of the above activities from Kilkenny County Council.

Table 7.4

Table 7.5 Roads Programme Group Impact Reduction in Reduction Programme Group 2 Expenditure i n I n come ⁄ ⁄

National Primary and Secondary Routes 33,770 100,000 Regional and Local Roads 4,701 29,396 Motor Tax Office 0 16,320 Public Lighting 35,535 0

Total 74,006 145,716

7.15 Programme Group 3. Water Supply and Sewerage

The area where the proposed boundary extension may have an impact in the water supply and sewerage include: − Income from water connection fees − Income from supply of water and waste water services − Costs of supplying water including system operations − Costs of group water schemes − Costs of water account collection, and − Costs of sludge disposal

• Income from Water Connection Fees

Based on 2004 activity levels the income from water and sewerage connection fees should fall by approximately ⁄12,000 per annum in total.

• Income from supply of Water and Waste Water Services

Receipts by Kilkenny County Council from water and waste water services in 2004 were ⁄1,013,235. The number of water charge accounts in the proposed extension area is 165 out of 3,316 in the county or just under 5%. However, estimates of the volumes of water involved shows that a transfer of some 4% of commercial water volumes would be involved. On that basis, the reduction in receipts would be ⁄40,529 from the commercial sector and ⁄76,308 from the payments made by the Department of the Environment, Heritage and Local Government for providing water to private households, giving an overall income loss of ⁄116,837.

• Supply of Water and Water Waste Water Services

The cost of supplying and distributing water in Kilkenny County and receiving and treating waste water was ⁄3.68 million in 2004. Some costs such as waste treatment are volume related and some such as maintenance are dependent on the size of plant, length of pipe work, age, intensity of use etc.

In overall terms it is estimated that the full costs of water production, distribution and maintenance in the proposed extension area to be ⁄145,500. This is close to the estimated operating and maintenance costs of ⁄123,100 submitted by Waterford City Council. However, it is also estimated that the realisable savings to Kilkenny County Council are ⁄109,150 œ given the limited potential for savings in engineering or administration functions.

• Group Water Supply Schemes

There are five Group Water Supply Schemes in the proposed extension areas. These schemes are funded through allocations from the Department of the Environment and therefore no provisions are made in respect of expenditure or income. No savings will be generated by the transfer of these schemes.

• Cost of Water Account Collection

Savings of the order of ⁄3,200 may be generated through transaction cost savings.

• Costs of Sludge Disposal

The volumes of sludge in the proposed extension area are small relative to the County as a whole. Potential savings are immaterial and no provision for savings is made.

The following table shows the findings of our assessment, which are that, in summary, the potential expenditure savings are less than the income lost to the amount of just under ⁄16,500.

Table 7.6 Water Programme Group Impact Reduction in Reduction Programme Group 3 Expenditure i n I n come ⁄ ⁄

Income from Water Connection Fees 12,000 Income from supply of water and waste water services 116,837 Costs of supplying water 109,154 Costs of water account collection 3,207

Total 112,361 128,837

7.16 Programme Group 4

The proposed boundary extension would, if proceeded with, impact on Kilkenny County Council‘s income and / or expenditure in three areas, namely

• Planning applications processed • Planning enforcement inspections, and • Building Control Enforcement inspections

• Planning Applications

In 2004, 78 planning applications were received from the proposed boundary extension area, just under 5% of the total number of 1,635 received by Kilkenny County Council. The income generated from all applications was ⁄1.028 million and on a pro-rata basis, the loss of income would be at least ⁄49,070. The savings potential is estimated at one officer at an overall saving of ⁄50,000 per annum.

• Planning Enforcement Inspections

Fourteen such inspections were carried out in the proposed extension area and therefore no savings are anticipated.

• Building Control Enforcement Inspections

There were 30 such inspections in the proposed extension area in 2004 and no savings from the transfer of this level of activity are realisable.

In summary, the assessment of the impact on Kilkenny County Council for Programme Group 4 is as shown in the following table.

Table 7.7 Planning Programme Group Impact Reduction in Reduction Programme Group 4 Expenditure i n I n come ⁄ ⁄

Processing of Planning Applications 50,000 49,070 Planning Enforcement Inspections 0 0 Building Control Enforcement Inspections 0 0

Total 50,000 49,070

7.17 Programme Group 5 œ Environmental Protection

There are a number of areas within this programme group where income and/or expenditure may be impacted. These are assessed under the headings of

− Waste Management − Fire Service and − Other activities

• Waste Management

The waste collection and disposal services in the proposed extension area are operated by private sector companies and there would be no impact on Kilkenny County Council in respect of these operations.

The County has provided two bring centres and has three recycling initiatives on-going in the area. Transfer of these would generate expenditure savings of the order of ⁄45,000 per annum.

On the receipts side, the County Council would lose an estimated ⁄24,500 in respect of the recycling initiatives and income from sales of recyclables.

The County would also lose an estimated ⁄91,000 of landfill gate fees as a result of the diversion of waste collected from the proposed extension area away from the Kilkenny County landfill.

Street cleaning costs would be reduced by an estimated ⁄25,900.

• Fire service

The proposed transfer will not impact on the cost of providing a fire service in Kilkenny County as the full compliment of firemen and tenders will be retained.

There would be savings of ⁄15,000 from the contribution made by Kilkenny County to Waterford City for attending fires in the County.

The County Council‘s contribution to CAMP would fall by an estimated ⁄15,000.

On the income side, eight fire certificates applications were received from the proposed extension area in 2004, out of a total in the County of 236. On a pro-rata basis, the revenue lost from a transfer of these would be ⁄10,800.

• Other

There would be no material impact from any other activities in the Environmental Protection Programme Group on either the expenditure or revenue accounts.

Table 7.8 Environment Programme Group Impact Reduction in Reduction Programme Group 5 Expenditure i n I n come ⁄ ⁄

Recycling Activities 45,000 24,500 Landfill gate fees 91,000 Street cleaning 25,900 Contribution to Waterford City fire service 15,000 Contribution to CAMP 15,000 Fire Cert applications 10,800

Total 100,900 126,300

7.18 Programme Group 6: Recreation and Amenities

There are two areas where income and/or expenditure would be affected if the proposed change were to go ahead, namely Library Operations and Recreation & Amenity.

• Library Operations

The library operations in Kilkenny County Council and the costs associated with the staffing, operations of the buildings or the purchase of books are fixed costs. There is no library building in the proposed extensions area, consequently no savings opportunity presents itself.

On the other hand, the proposed boundary change would see the transfer of 6.4% of the population of Kilkenny County to Waterford, if it were to proceed. On this basis it is reasonable to assume that Kilkenny County Council will lose a similar portion of its income from membership fees and fines, this is equivalent to a loss in income ⁄15,132.

• Recreation and Amenities

Using the same basis as that proposed by Waterford City Councils, the savings in recreation and amenity expenditure by Kilkenny County Council would be ⁄103,400. This is based on the needs and resources model expenditure target of ⁄20 per head of population for County Councils.

The overall conclusion for Programme Group 6 is shown in the following table.

Table 7.9 Recreation and Amenity Programme Group Impact Reduction in Reduction Programme Group 6 Expenditure i n I n come ⁄ ⁄

Library Operations 0 15,132 Recreation and Amenities 103,400 0

Total 103,400 15,132

7.19 Programme Group 7, Agriculture, Education, Health and Welfare.

Expenditure under this programme group is made up largely of contra items such as Higher Education Grants or payment of VEC pensions. The number of Higher Education Grants that would be transferred is relatively small œ 42 out of 790 œ and no measurable savings would be achieved. The position is similar with other activities in this programme group.

No changes between income and expenditure in this programme group are shown.

7.20 Programme Group 8 œ Miscellaneous Services

There is a number of areas of potential impact, some of which are referred to in the Waterford City proposal and others on which the City‘s proposal is silent. It is noted that there is a number of activities within this Programme Group (such as the issuing of dog licenses where the effect would be a loss of income of about ⁄300 per annum) where the impact is not material and consequently no reference is made to them.

The areas of impact are as follows:-

• Rates income

The rates demand for the relevant area was ⁄1,298,256 in 2004. Allowing for 5% uncollected rates and rates refunds, the net loss to Kilkenny County Council would be ⁄1,233,343 per annum. This is not shown in the programme group 8 table, but is included in the summary as a separate item.

• Rates Refunds

These have been accounted for in the rates income discussed above

• Rates Collection Costs

The number of rates demands issued in the proposed extension area is 73, or 5% of the total number of demands issued by the County. However, the value of the rates in the affected area is 15.3% of the total rates demand for Kilkenny County Council.

There is no realistic prospect of savings being generated from staff involved in rates collection. However, there should be savings in transaction and other costs which are estimated at ⁄16,200.

• Bank Interest and Charges

Relevant costs in 2004 were ⁄59,828. Savings are estimated at ⁄1,500 per annum.

• Councillors‘ Expenses

No reduction in the number of County Councillors is anticipated.

• Staff

As noted throughout this assessment, opportunities for staff reductions in Kilkenny County Council are very limited. However, as a result of internal structures within the County Council being aimed at optimising customer service and efficiency, it considered that it would be possible, in time, through staff leaving, to realise savings of some four posts, 2 in administration and 2 technical staff.

The impact of these will be a saving of some ⁄180,000 per annum.

• Insurance

Public liability insurance costs were ⁄1,096,500 in 2004. Based on the scale of the population transferred, the potential savings are assessed at ⁄70,562.

It is considered that employer liability insurance costs will not change by a material amount.

The overall conclusion for Programme Group 8 is shown in the following table.

Table 7.10 Miscellaneous Items Programme Group Impact Reduction in Reduction Programme Group 8 Expenditure i n I n come ⁄ ⁄

Rate Collection Costs 16,200 0 Bank interest and charges 1,500 0 Staff 180,000 0 Insurance Costs 70,562 0

Total 268,262 0

E. Overview of Findings

7.21 Programme Group Review œ Summary of Findings

The results of the programme group analysis were provided earlier in this assessment, but the summary table is repeated in order to highlight the key findings:

Table 7.11 Overview of Programme Group Impact Reduction in Reduction in Loss / Benefit Impact on County Kilkenny Income E xpenditure ⁄ ⁄ ⁄ Programme Group: Housing & Building 61,019 14,902 46,117 Roads Transportation and Safety 145,716 74,006 71,709 Water Supply and Sewerage 128,837 112,361 16,476 Development Incentives and Control 49,070 50,000 930 Environmental Protection 126,300 100,900 25,400 Recreation and Amenities 15,132 103,400 88,268 Agriculture, Education, Health and Welfare 0 0 0 Miscellaneous 0 268,262 268,262 Sub-total 526,074 723,831 197,757 Rates 1,233,343 Net Change 1,035,586

In its proposal, Waterford City Council estimated the impact on Kilkenny County Council as a loss of ⁄337,521 per annum. The assessment shows that Waterford City has understated the impact by ⁄698,065.

The difference is found in both the receipts and expenditures assessments.

• Expenditure Differences In respect of the assessment of the impact of the proposed boundary extension on the expenditure of Kilkenny County Council, the potential reductions in expenditure are assessed at ⁄723,831 compared to Waterford City‘s estimate of ⁄905,061. The key areas of difference are in Roads; Environmental Protection and Recreation and Amenity expenditure. In these cases, Waterford City Council did not provide any detail as to how it reached its conclusions, but it appears that the City overestimated the potential to reduce both operating and administration/central management costs by significant amounts. The difference between the two sets of estimates of the impact on Kilkenny County‘s expenditure is ⁄181,230.

• Income Differences However, much of the difference between the two estimates is in the area of income losses that would be incurred by Kilkenny County Council. In simple terms, Waterford City has underestimated the impact on Kilkenny County Council‘s operations by an amount of ⁄362,861. Much of this comes in the programme groups dealing with roads and environmental protection, and in particular the City‘s failure to allow for any reductions in grants for both national and local roads maintenance and upkeep. The City also failed to provide for any impact on landfill gate fees and a host of other income sources such as library memberships, housing rents and suchlike.

• Rates Income Differences The City also understated the potential loss of rates income by ⁄153,974.

The components of Waterford City‘ underestimation is therefore:-

⁄ Overestimate of expenditure savings 181,230 Underestimate of operating income loss 362,861 Underestimate of rates loss 153,974

Total differences 698,065

In conclusion, the assessment shown in the boundary extension proposal by Waterford City Council is inaccurate; it has failed to assess the full implications and therefore understates the true position regarding the impact on Kilkenny County.

7.22 Net Impact on Waterford City and Kilkenny County Combined.

In its submission, Waterford City Council stated in its proposal document that:

• An extended urban boundary will assist in securing the long-term financial base for the city.

• The provision of local services by two separate local authorities namely (Waterford City Council and Kilkenny County Council) within a single geographical urban area militates against consistency in quality, economies of scale and equity in distribution (Proposal pp3).

Waterford City estimated that the impact of the proposed boundary extension on the City‘s finances would be as follows:

Table 7.12 Waterford City Council Impact Assessment Increase in Increase in Net Increase in Table D.2.2 Waterford City Income Expenditure Expenditure/Income ⁄ ⁄ ⁄ Housing & Building 6,500 48,178 41,678 Road Transportation & Safety 0 300,580 300,580 Water Supply & Sewerage 121,652 144,393 22,741 Development Incentives & Control 45,000 65,034 20,034 Environmental Control 414,000 1,446,080 1,032,080 Recreation & Amenities 0 202,823 202,823 Agriculture, Education, Health & Welfare 0 13,797 13,797 Miscellaneous 0 125,007 125,007 Total 587,152 2,345,892 1,758,740 Additional Rate Income in Yr. 1 to Waterford 1,107,856 City Council Net Additional Expenditure to Waterford City 650,884 Council if area is extended

It is not proposed to critique the City‘s expenditure proposals; however, some succinct observations on the proposal are merited. In particular:

1. The City does not provide for taking over a number of houses owned by Kilkenny County Council that are situated in the proposed extension area. While the City is foregoing expenditure on maintaining these houses, it is also foregoing the rents received from those houses.

2. The City provided for no additional library expenditure resulting from the proposed extension. Recreation and Amenity expenditure targets shown in the Needs and Resources model and used by the City to project its future spend in this area do not include swimming pool or library operations. As no expenditure has been provided for these activities, the City‘s conclusion may understate the net cost to it of the boundary extension.

3. The target expenditure for Recreation and Amenity expenditure in the Needs and Resources model on the part of Cities is ⁄45 per head of population. In its proposal, Waterford City used a value of ⁄35 per head which is the target applicable to Town Councils. If, as is stated, the City proposes to incur expenditure at the appropriate target value, then the expenditure is understated and the net effect on the City is underestimated.

In summary, it is concluded that the impact stated in the boundary extension proposal most likely understates the true position.

However, taking the City‘s assessment as projected, with one adjustment which is to bring the City‘s estimate of rates income into line with Kilkenny County Council‘s assessment of the rates loss, it is concluded that:-

1. The proposed extension will have cost implications for both local authorities in year 1;

2. The total cost implications in year 1 will be ⁄1.68 million.

It is concluded therefore that:

1. The proposed boundary extension and the resultant transfer of activities would reduce the efficiency by which the services in the proposed extension area are provided 2. The total costs to the two authorities in year 1 would be ⁄1.68 million. This would have to be recouped either by higher than necessary commercial rates increases; higher domestic and commercial user charges or an increased contribution from the Local Government Fund to the two authorities. 3. The view that the boundary extension would —assist in securing the long-term financial base for the city“ would be achieved only by undermining the financial base of Kilkenny County Council.

In short, none of the financial arguments provided to support the proposed boundary extension stand up to scrutiny.

7.23 Impact on Waterford City and Kilkenny County over the Transition Period.

The Waterford City Council proposal showed the impact of the proposed boundary extension for year 1 only. To assess the full implications, account of the full eleven year transition period that is proposed by the City has been taken. In effect, the City proposes that commercial rate payers will have their rates demands adjusted progressively from the Kilkenny County Rate on Valuation of ⁄45.62 to the Waterford City Rate on Valuation of ⁄58.53 over this period.

Ratepayers in the extension area would pay additional rates of close to ⁄350,000 per annum due to this higher rates charge. For an individual ratepayer with a property valuation of ⁄200, the annual rates demand would increase from ⁄9,124 to ⁄11,706, excluding any inflationary increases.

The Waterford City proposal is silent on the impact on valuation of transferring rateable properties from Counties to Cities. If a change in valuation were to come about as a result of such a transfer, then the valuations could increase by 26% as a result of the transfer from a County to a City.

Were that to happen, the impact of the boundary extension on a commercial property with a valuation of ⁄200 would be an increase from ⁄9,124 to ⁄14,750.

These two scenarios provide the bases for assessing the impact over the transition period, namely: a. assuming no change in valuations arising from the proposed boundary extension, and b. assuming that the valuations do change as a result of the transfer to the City.

Case (a) is summarised in table 7.13 overleaf.

It clearly shows that the effect of the increased rates income during the transition period is simply to reduce the overall costs from ⁄1.68 million per annum to ⁄1.21 million per annum. Total costs over the transition period would be ⁄15.31 million. Consequently the previously stated view of Kilkenny County Council that the boundary extension proposed by Waterford City would not provide for efficiencies or economies of scale still holds.

Table 7.13. Impact over Transition Period, assuming no change in property valuations.

Year 1 2 3 4 5 6 7 8 9 10 11 Total Income (⁄m) Rates 1.23 1.23 1.23 1.23 1.23 1.23 1.23 1.23 1.23 1.23 1.23 13.57 Kilkenny Reduction Other 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.53 0.53 5.79 County Council Expenditure Immediate 0.49 0.49 0.49 0.49 0.49 0.49 0.49 0.49 0.49 0.49 0.49 5.43 Savings (⁄m) Long Term Staff Costs 0.08 0.15 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 0.23 2.30

Net Cost 1.19 1.11 1.04 1.04 1.04 1.04 1.04 1.04 1.04 1.04 1.04 11.62

Year 1 2 3 4 5 6 7 8 9 10 11 Total Increase in Rates 1.27 1.30 1.33 1.36 1.39 1.42 1.46 1.49 1.52 1.55 1.58 15.66 Waterford Increase in Income 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 6.46 City Council Increase in Immediate 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 25.80 Expenditure (⁄m) Long Term 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Net Cost 0.49 0.46 0.43 0.40 0.37 0.33 0.30 0.27 0.24 0.21 0.18 3.68

Total Cost 1.68 1.57 1.47 1.43 1.40 1.37 1.34 1.31 1.28 1.24 1.21 15.31

Case (b) which assumes that the valuations of commercial properties change as a result of the transfer to the City, is shown in table 7.14 overleaf. The effect of this change would be to increase valuations by 26%. When coupled with the increase in the rate on the valuation arising from a transfer from the County to the City, the effect on commercial ratepayers would be a rates demand increase of 61.7% by the end of the transition period.

Despite this potential level of increase, the table overleaf clearly shows that the effect of the increased rates income, including the valuation increase, would be to reduce the net costs in year 1 from ⁄1.68 million to ⁄1.35 million. These costs would reduce progressively as the transition proposals take effect, but by the end of the eleven year transition period, the costs would still be ⁄0.8 million per annum. In this case, the total cost over the transition period would be ⁄11.23 million. This reduction from the ⁄15.31 million stated previously would arise solely from increases in rates income. The continuation of total net costs to the two local authorities reinforces the previously stated view that the proposed boundary extension will not provide for efficiencies or economies of scale.

The final comment on this issue is that in order to recover the increases in costs that would result from the proposed boundary extension, higher user charges; increased central Government grants and/or increases in rates income would be needed. Three observations can be made:

• Funding an unnecessary boundary extension through increased demands on central Government funding is not an efficient use of national resources;

• Funding an unnecessary boundary extension through increased user charges would mean that the user charges would no longer be related to the service provided, but would in effect be a tax used to cross subsidise losses; while

• If the boundary extension were granted, and the increased costs were to be funded by the ratepayers, then

– There would be an increase in the rates charge of over 20% for the remainder of Kilkenny County, plus – There would be a 28% in rates for businesses in the proposed extension area, arising from the City‘s higher rates charge, plus – There would be a 5% increase in rates across the newly extended City.

Such cost increases clearly show that the proposal does not provide for —effective or convenient local Government“

Table 7.14. Impact over Transition Period, assuming a change in property valuations to City Basis.

Net Cost 1.19 1.11 1.04 1.04 1.04 1.04 1.04 1.04 1.04 1.04 1.04 11.62

Year 1 2 3 4 5 6 7 8 9 10 11 Total Increase in Rates 1.59 1.63 1.67 1.71 1.75 1.79 1.83 1.87 1.91 1.95 1.99 19.73 Waterford Increase in Income 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 0.59 6.46 City Council Increase in Immediate 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 2.35 25.80 Expenditure (⁄m) Long Term 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Net Cost 0.16 0.12 0.08 0.04 0.00 -0.04 -0.08 -0.12 -0.16 -0.20 -0.24 -0.39

Total Cost 1.35 1.24 1.12 1.08 1.04 1.00 0.96 0.92 0.88 0.84 0.80 11.23

7.24 Other Considerations

• Other Income Streams The proposal from Waterford City Council is silent in respect of development levies from developments in the proposed extension area. The policy of Kilkenny County Council has been to use such levies to develop the social and physical infrastructure of the area providing the levies. It is a concern that levies from the proposed extension area would be diverted to fund shortfalls in Waterford City‘s infrastructure or to subsidise day-to-day operations within the existing City.

Kilkenny County Council estimates that its investment in South Kilkenny will yield some ⁄18 million from various sources. Of this, some ⁄6 million will be expended on recreation, sporting and environmental projects in the area. The balance of ⁄12 million will be expended across the county and reflects the return on the investment by the County at large into the area in recent years.

The people of Kilkenny are entitled to benefit from their past investment through new business and employment investment, with the associated income benefits, particularly in the Belview Port area.

• Local Government Fund We have not provided for any changes to either Kilkenny County Council‘s or Waterford City Council‘s allocation under the Fund. However, given that the proposed extension would result in net costs to both authorities, a loss in service provision could be avoided only through increased allocations to both Councils. In our view, diverting money from this Fund to offset the costs of the proposed boundary extension is not an efficient use of national resources.

Furthermore, in past years, the amounts of money available for redistribution through the Fund have been modest, and it is unlikely that the level of the funding needed to offset the net costs to the two Councils will be available.

• Rates Buoyancy We have not provided for any change in the valuation base in the proposed extension area through new commercial developments. In general terms however, relatively high levels of rates buoyancy would be reflected in below average increases in allocations from the Local Government Fund. This is because LGF allocations are based on an assessment of the needs of the resources of individual local authorities.

• Assets Transfer The assets of Kilkenny County Council that have been funded from its own resources and that area located in the area sought by Waterford City include a depot at Newrath; a quarry and a chipping dump. These have a market value of ca. ⁄1 million.

Section 8 Response to Specific Points in the Waterford City Proposal

8.1 In the Proposal, Waterford City Council makes claims in relation to:

A. Shortcomings of inter authority cooperation;

B. Franchise;

C. The Port of Belview; and

D. Precedents.

8.2 In this section, we present how, either Waterford City Council has selectively provided information or how it does not appreciate the complexity of boundary extensions or the administration of the Port Authority.

A. SHORTCOMINGS OF INTER AUTHORITY COOPERATION

8.3 Within the Proposal, Waterford City Council suggests that there is a range of shortcomings in inter-authority cooperation, particularly in relation to the delivery of local authority services within the Waterford Environs within County Kilkenny. In the paragraphs that follow outlines the practice in relation to the Council services in question.

Planning

8.4 According to the Proposal:

”In terms of proper planning and sustainable development Waterford City and its physical environs in County Kilkenny constitutes a single entity. To ensure that needs and changes in the urban system are directed in the most convenient manner it is essential to have a unitary approach to the development of the city‘ the Proposal pp2

8.5 This statement directly contradicts Waterford City Council‘s policies as adopted in the Waterford City Development Plan where the requirement to integrate and coordinate development of the city and its environs based on the principles of sustainable development is stated in the introduction as follows:

”Waterford City Council will work in close co-operation with its neighbouring Planning Authorities to ensure that common policies are pursued for the betterment of the City and Region‘ Waterford City Development Plan pp6

8.6 Kilkenny County Council cooperated with the preparation of the Waterford City and Environs Framework Plan in 1998.

8.7 The preparation of the Waterford PLUTS was led by Waterford City Council working in partnership with Waterford County Council and Kilkenny County Council. From the beginning Kilkenny County Council participated, at senior level, on the Steering Committee responsible for the preparation of PLUTS. Acknowledging the importance of implementation of the PLUTS to achieve the potential of Waterford and its surrounding area, Kilkenny County Council adopted the PLUTS in May 2004. Many of the emerging recommendations in PLUTS were anticipated and integrated into the Kilkenny County Development Plan and specifically the Development Plan of the Environs of Waterford and the Area Action Plan for Belview.

8.8 Focussing on retail planning and development, it is a stated objective of Waterford City Council to engage with the County Councils of County Waterford, Kilkenny and Wexford in the preparation and adoption of a joint retail strategy. This is also a stated objective of the adopted Kilkenny Retail Strategy. This approach is consistent with the Retail Planning Guidelines for Planning Authorities published in November 2000 and revised by the DoEHLG in January 2005. Kilkenny County Council has written to Waterford City Council seeking to cooperate on this issue but has met with no success.

8.9 Kilkenny County Council has a record of facilitating acquisition and servicing development land to support the development of the city and Region with an important strategic example being the approach adopted by the County Council to Belview, in full partnership with the Port of Waterford.

Waste Management

8.10 In the Proposal, Waterford City Council states that:

”Waterford City Council is contend(sic) that a single local authority responsible for waste collection and disposal, recycling facilities and services for Waterford City and its Environs, would provide a much more economical and sustainable service for the greater benefit of both residents and the environment‘ the Proposal pp 35.

8.11 This statement contradicts the spirit Waterford City Council adopted policies as stated in the Waterford City Development Plan as follows:

”It is the policy of the City Council to fully participate in the preparation, adoption and implementation of the proposed Joint Waste Management Plan‘ Waterford City Development Plan pp52

8.12 Kilkenny County Council refutes this assertion. Kilkenny County Council plays a key role in delivering waste management services, not just in Kilkenny County but also in the South East Region. The Regional Waste Management Plan, which was recently prepared by all local authorities in the South-East Region provides a strategic framework for the delivery of waste management services the Region. South Tipperary County Council is designated as the lead agency to deliver the South East Regional Waste Management. This plan points to the consolidation of land filling within the South East Region. Kilkenny County Council is the nominated authority for issuing Waste Collection Permits for the South East Region, including Waterford City.

8.13 Kilkenny County Council provides waste management services in the proposed boundary extension area. The County Council collects waste on the basis of the polluter pays principle. Furthermore, contrary to suggestions in the Proposal, Kilkenny County Council has not prevented Waterford City Council from acting against illegal dumping .

8.14 In addition, a civic amenity site for recycling is proposed for the environs of Waterford within County Kilkenny. A site has been identified for this purpose and Kilkenny County Council proposes that the site will be developed in consultation with Waterford City Council.

Fire Services

8.15 Under an agreement dating to 1965, Waterford City Council provides a ”first turn out‘ fire service for to extinguish fires in South Kilkenny from Piltown in the west to Lukeswell in the north and Glenmore in the east. However, the Proposal for the proposed boundary extension promotes that a single local authority would provide a more efficient fire service. The proposed extension area covers a small proportion of the area within County Kilkenny serviced by Waterford City fire service. Thus, the granting the boundary extension will not alter the agreement whereby Waterford City Council provides fire extinguishing services in County Kilkenny. Furthermore, the Proposal contrasts with the policy of Waterford City Council as set out in the Waterford City Development Plan which states:

”to co-operate with the adjoining Local Authorities in the development of the Fire Service‘ Waterford City Development Plan pp 52

8.16 This policy of Waterford City Council acknowledges that, by its very nature, the effective and expeditious delivery of fire services generally requires a high level of cooperation between adjoining local authorities, which is the case for South Kilkenny. Applying the same principle, Kilkenny County Council is the first turn out for Tinnahinch in Carlow and for areas in County South Tipperary adjacent to Urlingford, with the fire service in Carrick-on-Suir, County South Tipperary responding to emergencies in South West Kilkenny.

8.17 The Proposal suggests that the provision of fire services is hampered due to the fact that Kilkenny County Council and not Waterford City Council assesses developments through planning and control legislation and inspects premises under the Fire Services Act. However, Kilkenny County Council fully acknowledges the importance of exchange of information to ensure that an effective service which prioritises fire safety in the area is delivered and provides Waterford City Council with any relevant information regarding premises to which Waterford Fire Service is first turnout.

8.18 A Regional Major Emergency Plan is currently being prepared for the South East Region. This should provide clarification in relation to roles and responsibilities for incidents at border areas. While policies are emerging, it is currently envisaged that the Regional Major Emergency Plan will advocate the strengthening of collaboration between the various local authorities to provide effective fire services. This regional approach erodes Waterford City Council‘s contention that it would better provide the service on it‘s own within Waterford City.

8.19 In addition to the level of cooperation listed above, Kilkenny County Council is supporting Waterford City Council in the delivery of a range of services and strategic initiatives as summarised below.

Transport

8.20 Waterford City Council acknowledges the need for a co-ordinated approach to the provision of transportation services and the Waterford County Development Plan states:

”Responsibility for the transportation system is shared with a number of bodies including the Department of the Environment and Local Government, the Department of Public Enterprise, the National Roads Authority the adjoining Roads Authorities, the Garda Siochana and the providers of public transport services, and an integrated and co-ordinated approach to transportation planning is required‘ Waterford City Developmement Plan pp 45

8.21 Kilkenny County Council is leading the delivery of strategic road infrastructure that will serve Waterford City and improve access to and within the South East Region. The County Council is the lead authority for the development of the N9 Waterford œ Dublin Road. It is also responsible for co-ordinating the upgrading of the N25, which serves Waterford City, along with the development of the Belview Port Access Road and Slieverue Bypass, both of which were developed by Kilkenny County Council.

Water Services

8.22 There is significant evidence of cooperation with both Waterford City Council and Kilkenny County Council playing key roles in the provision water services in the area, specifically in relation to water supply and treatment.

8.23 Water is supplied to the city from the Adamstown water treatment plant at Kilmeaden, which is operated by Waterford County Council. All demands for water supply in the proposed boundary extension area have been met by Kilkenny County Council. Waterford City Council does not produce any water but receives the bulk of its water from Waterford County Council.

8.24 Kilkenny County Council works in partnership with Waterford City Council in providing drainage and wastewater treatment for Waterford City and its Environs. A Waste Water Treatment Pant is being developed at Gorteens in County Kilkenny. The Waste Water Treatment Plant is being developed under a Design, Build and Operate contract. This will have the capacity to service to Waterford City and its Environs for the next 20 years. Furthermore, the facility is designed to accommodate modular extensions to cater for increasing demand. The delivery of this scheme represents an example of good inter-authority cooperation between Kilkenny County Council and Waterford City Council, whereby the City Council as the lead agency is procuring the DBO contract for the waste water treatment plant, while Kilkenny County Council facilitated the development by acquiring the site.

Housing

8.25 Kilkenny County Council has facilitated Waterford City Council in the provision and servicing of social housing in the Environs of Waterford.

B. DEMOCRACY & FRANCHISE

8.26 Focussing on franchise, the Proposal states that the boundary has the:

”undesirable effect of divorcing a portion of city dwellers from the city electorate and from participation in the civic affairs of the area to which they are primary attached in terms of tradition, personal identity, employment, social life and day to day activities.‘ the Proposal pp 30.

8.27 Kilkenny County Council rejects these assertions. The boundary expansion area is situated within the Piltown Electoral Area of the County Council. The Piltown Area Committee, which is composed of six elected members of Kilkenny County Council representing the Piltown Electoral Area. This committee represents the people of the Environs of Waterford in County Kilkenny and ensures that their interests are clearly presented and stated in the County Council. Furthermore, the quantum of submissions objecting to the proposal for a boundary extension made to Waterford City Council from the residents of County Kilkenny is evidence of the strong association that the population of County Kilkenny has with the area. The Piltown Electoral Area Committee meets approximately every six weeks at the Newrath Area Office which is located within the area of the proposed boundary extension. The committee review and examine all matters across the full range of Council services. In addition, the committee meet deputations from local community groups. Between 2001 and 2004, the committee met a total of 24 times and received 32 deputations from local groups.

The Confederation of Community Groups in South Kilkenny provides a voice for the voluntary and community sector in Ferrybank. This is acknowledged by Kilkenny County Council and the Confederation, through the Kilkenny County Forum which has representation on Kilkenny County Council‘s Strategic Policy Committee; the Expanded Area Committee for the Piltown Electoral Area; the Kilkenny County Forum and the Kilkenny Rural Transport Work Group.

8.28 There are three electoral areas in Waterford City. Other than statements that the proposed boundary extension will improve the franchise of the local community in the Environs of Waterford, by integrating it into the electoral area mechanism used in Waterford, it does not illustrate how this will be achieved or its impact on the electoral representation on Kilkenny County Council or the Piltown Electoral Area Committee. However, it is noteworthy that as recently as 1998 the Electoral Area Boundary Committee reported on the boundary changes required to ensure that the correct franchise was in place for local elections. Kilkenny County Council made a submission to this committee which reflects the Council‘s commitment to the democratic representation in the County.

8.29 The Proposal quotes from the Electoral Area Boundary Committee Report, 1998 when it states:

”…in many cases local authority boundaries largely based on these (historic counties with strong traditional, sporting and community loyalties) do not bear a close relationship to the pattern of living today œ be it transport patterns, travel to work, shopping, school catchment and social life generally. This divergence between local authority administrative area and the pattern of life is probably at its most acute in the case of urban centres which themselves are located near, or indeed split by, local authority boundaries‘ The Proposal pp 24 and The Electoral Area Boundary Committee Report pp12.

8.30 This represents selective quoting from the Electoral Area Boundary Committee Report, which in the same paragraph continues to find that:

”We faced particular difficulties in seeking to apply our terms of reference when considering the electoral area boundaries around larger towns or cities of this kind. In such cases much of the natural hinterland is contained in a separate adjoining county. While boundaries clearly matter, from a practical point of view the focus needs to be addressed in a sensible way by the authorities concerned with a view to optimising local service and operational arrangements‘ The Electoral Area Boundary Committee Report pp 12

8.31 This finding applied to a total of 26 towns, including Waterford, of which, only Waterford City and Limerick City have submitted proposals for a boundary extension. The terms of reference of the Electoral Boundary Committee only extended to boundary extensions for local election purposes and as such, the recommendations of the committee are limited to that function and do not extend to the full range of services provided by local authorities.

C. PORT OF WATERFORD

8.32 The importance of the Port of Waterford and the Belview facility is well documented. The Proposal states that the new Port of Waterford at Belview already offers many benefits to Waterford City and the Region helping to reinforce the status of Waterford City as a national urban centre. However, according to the Proposal, Waterford City has lost an important economic activity due to the relocation of its port within the administrative are of County Kilkenny. It continues to state that:

”as both the port and the city have a symbiotic relationship…it would be more logical if the administrative responsibility of the port lay with Waterford City Council‘.

8.33 Kilkenny County Council plays a key role in harnessing the potential of the Belview facility through correct land use zoning and the provision of infrastructure and services. However, the Port of Waterford, not Kilkenny County Council or Waterford City Council are responsible for the administration of the harbour functions, including the two freight terminals Belview, County Kilkenny a piloting service to Great Island Electricity Generation Station, County Wexford. In 2005 the Department of Communications, Marine and Natural Resources published a Ports Policy Statement. This states that:

”the Minister sees groupings and partnerships of ports as options to reduce costs, create synergies and improve marketing and critical mass. The Minister would, in the first instance, encourage ports to fully explore such options as a means of improving financial and business performance and providing better service‘.

8.34 The Statement found that, while the High Level Review10 suggested a number of possible merger groupings, the only merger that has recently been considered is the possible amalgamation of the Port of Waterford Company and the New Ross Port Company. Acknowledging the requirement to achieve economies of scale, in January 2005 the chair of the Port of Waterford stated it would consider mergers with Rosslare Harbour and the Port of New Ross, both in County Wexford to form a South Eastern Ports Group. The operations of South Eastern Ports Group would span the administrative boundaries of Waterford City, Kilkenny County and Wexford County.

8.35 The policies being implemented by Kilkenny County Council will harness the full potential of the Belview facility, ensuring the potential economic impact of the facility will extend beyond its immediate area in accordance with the recommendations of the NSS and SERPG. Thus in addition to improving the symbiotic relationship the Port has with the City and its Environs these policies will also improve its relationship with the entire region and the state.

10 High Level Review of State Commercial Ports operating under the Harbour‘s Acts 1996 - 2000

D. PRECEDENTS

8.36 The Proposal presents the precedents of boundary extensions such as Galway, along with the reorganisation of local government in Dublin to illustrate that boundary extensions have been granted to local authorities. In addition, Limerick City Council has submitted a proposal to the Minister for the Environment, Heritage and Local Government seeking an extension of its administrative boundary. However, not all urban centres follow the same development patterns and they in fact require bespoke responses to their specific development needs. In the paragraphs that follow we present how these boundary alterations do not represent precedents for the expansion of Waterford City‘s administrative area, but that each proposed boundary extension needs to be considered on a case-by-case basis with the merits of each needs to be appraised individually.

Galway

8.37 The Proposal refers to the boundary extension granted to Galway County Borough. This boundary extension was granted, and Galway City now extends to an area of 5,057ha. According to the Proposal

”the boundary extension enlarged considerably the area of Galway County Borough to include not only its adjacent environs and existing built up area, but also a wider less urbanised hinterland‘ the Proposal pp 60

8.38 There is a number of key differences that do not make this a precedent for the Waterford City case for a boundary extension. These include:

i. To the south Galway City is bound by the sea at Galway Bay, which constrains the development of the city other than the river, no such natural geographical constraints exist in Waterford City. The development constraints of Waterford City are primarily due to the unsustainable strategy of significant agricultural zoning with a City Boundary. This can be rectified with correct and optimum zoning strategies;

ii. Twenty years following the boundary extension there remains 1,146ha of undeveloped land zoned for agricultural purposes within Galway City. Like Waterford City this represents rural planning in an urban area, constraining development adjacent to the city and thus forcing development to dormitory towns.

iii. There is currently an agreement between Galway City Council and Galway County Council to develop the area surrounding Galway and deliver strategic objectives for the city. As such Galway City is not seeking further boundary extensions, but is cooperating with Galway County Council to deliver the Gateway function required in the West Region.

Dublin

8.40 The Proposal highlights that under the Local Government (Reorganisation) Act 1985 a series of comprehensive boundary revisions were made between Dublin County Borough and Dublin County. According to the Proposal:

”the subdivision of these local authority areas through boundary revisions created a reduction in the size and scale of these areas making them capable of functioning much more effectively and conveniently‘ the Proposal pp 60.

8.41 The Proposal contends that:

”local authority areas can either be too large and complex as opposed to being too small and fragmented. The Dublin situation clearly belonged to the former while the current Waterford situation relates to the latter‘ the Proposal pp 60.

8.42 When compared with Waterford, the size of Dublin compounds the complexity of delivery of local authority services and thus they are not directly comparable cases. However, some models and cooperation applied in Dublin illustrate that, even with larger local authorities, there is a need for effective coordination amongst local authorities for a gateway to achieve its potential. Dublin County is administered by one city council and three county councils along with a number of town and borough councils. The Greater Dublin Area includes an additional three county councils with associated borough and town councils. Examples of collaboration in the Dublin area include: ° The supply and distribution of water throughout Greater Dublin involves cooperation between Dublin City Council and Wicklow, South Dublin, Dun Laoghaire, Fingal, and Kildare County Councils. The four authorities have co-operated on the provision of a regional waste water treatment facility. ° The establishment of the Dublin Transport Office to coordinate transportation in the city amongst the Dublin local authorities and other agencies responsible for transportation including; Dublin Bus, the Railway Procurement Agency, Iarnród Éireann and the Garda Siochána. In recent announcements, the Government acknowledged the need to establish a Greater Dublin Transport Authority to coordinate the integrated development of transport in the Dublin region. ° The preparation and adoption of the Greater Dublin Retail Strategy, which is used as a basis for the retail planning in the Greater Dublin Area. ° The four local authorities have prepared a Waste Management Plan 2005 œ 2010 to replace the previous plan. They co-operate in a wide range of waste management activities such as landfill cost and revenue sharing; Public Private Partnership projects and kerbside recycling collection. ° Fire and ambulance services throughout the four local authorities in Dublin are provided centrally.

Limerick

8.43 Whilst the Proposal does not refer to the current proposal made by Limerick City Council to extend its boundary into Counties Limerick and Clare, we seek to highlight a number of key differences between the settlement patterns and development objectives of the two:

i. Similar to the Proposal submitted by WCC, the Limerick City proposal does not appreciate that to achieve the development concept for a Gateway requires a co-ordinated approach to development that extends the full area of influence of the Gateway, which is well beyond the existing and proposed administrative boundary of the city.

ii. In 2002 the population of Limerick was 54,023 which is 23% greater than that of Waterford City. However, the administrative area of Limerick City (2,035ha) was almost 49% the size of Waterford City (4,157ha). Furthermore, there is no rural planning or area zoned for agricultural purposes in Limerick City.

8.44 Therefore, whilst Kilkenny County Council does not seek to influence the outcome of the deliberations in relation to the proposed boundary extension for Limerick City, it is highlighted that the dynamics of development at Limerick are significantly different to those in Waterford, and thus each case should be considered independently on its own merits.

CONCLUSION

Kilkenny County Council has co-operated effectively with Waterford City Council along with the other local authorities in the South East Region to ensure that the City is planned and developed in an integrated and sustainable manner. Kilkenny County Council advocates the continuation of this partnership approach between adjoining local authorities in planning for Waterford City, as happened in the preparation of the Land Use Framework in 1998 and the PLUTS in 2003.

Kilkenny County Council advocates a collaborative approach to the delivery of local authority services. This is particularly necessary when considering the requirement to maintain critical mass in the region and ensure that the full range of services will be delivered in an efficient and economical manner.

The population of the Environs of Waterford in County Kilkenny are democratically represented through the Piltown Electoral Area Committee of Kilkenny County Council.

The Boundary Extensions cited by Waterford City Council do not set precedents for its proposal.

Kilkenny County Council has taken a proactive strategic approach to the development of Belview which will benefit not just Waterford, but the entire South East Region, ensuring that Belview provides the strategic infrastructure required for the City to act as a Gateway for the Region.