Statement of Response to the Waterford City Council Boundary Extension Proposal (2006)

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 Cities current boundaries, 1,599 ha (3,950 acres) or 38% of the City 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 Cities 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 Commissions 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 Citys 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 Citys role as a Gateway be delivered through collaboration and co-operation with Kilkenny City and Wexford Town, not through an expansion of the Citys 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 arising solely from the Citys higher rates charge 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 Citys assertion that a boundary extension would assist in securing the long-term financial base for the City is contradicted by Kilkenny County Councils 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;
• 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 Citys 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 areas community and social identity.
The boundary extension proposal contains a number of inaccuracies and inconsistencies.
In particular:

• 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 Citys proposal, and
• 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:

• Is not needed to provide development capacity in the City,
• Runs contrary to the current regional, national and international best practice approaches to planning and development which are based on inter-authority co-operation, not boundary changes,
• Makes no financial sense,
• Demonstrates absolutely no vision or practical benefits for the people and businesses in the area, Is based primarily on the Citys financial interests, not on its potential contribution to developing the area in particular, or the South-East region as a whole.
• Would alter the community, cultural and sporting identity of the area and the County, and 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.

Appendices Waterford City Extension Proposal.pdf (size 884.9 KB)