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    there. Notwithstanding the fact that Clare County Council recognisesthe suburbs of Limerick as such in its County Development Plan,Clare County in its response is still of the view that;

    "The planning issues and issues of identity facing the settlements to the

    north of Limerick can best be met through a common strategy for theirintegration into the wider area of rural settlements rather than in theirintegration into a larger urban area."

    Clare County Council goes on to insist that development ought to berestricted in the Clare Suburbs because lands are available fordevelopment in Limerick County;

    "If any area is to be included in the Limerick County Borough area itshould be that area which is within the same county and which has alreadybeen identified and serviced for development."

    Clare also states that there are inadequate services in the Limerick Suburbs area thus limiting development there;

    "North Limerick Environs, the Gilloge area, is also identified forexpansion but is constrained from development in the short term due topoor roads and drainage infrastructure."

    This statement from the South Clare Economic Corridor Plan is directlyin contradiction of other statements in the response in which ClareCounty claims credit for the provision of services which has made theClare Suburbs an attractive zone for development . Through suchcontradictions it is apparent that County Clare wishes to focus on therural areas of Clare and rejects participation through partnership inplanning of the future growth and development of Limerick City

    A.6.3 Limerick County Council in its Development Plans for the environs of Limerick does not acknowledge that Clare is involved at all in thedevelopment of the city and seems to regard the County Limerick suburbs as distinct and separate from the city as a whole. In itsstatement of response, Limerick County states that

    "Within Limerick the approach for deciding where urban growth shouldoccur and where urban containment should prevail is imperative to thesuccessful achievement of a sustainable compact city and it is contendedthat this role and function has been successfully performed by LimerickCounty Council over the years ..."

    Limerick County says that it wishes to prevent outward sprawl intothe environs - but yet it plans the environs as separate townshipsaround district centres, some of which compete in terms of floorspacewith the City Centre. This action is directly in conflict with thestatements made in the response and the response is in turn in conflict

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    with the policies and objectives as expressed in the CountyDevelopment Plan . The County Council has also varied its Countyplan to permit greater sprawl by limiting the area of specialdevelopment control.

    Adequacy of Development Plan Integration

    A.6.4 The lack of a coherent overall plan for the greater Limerick urbanarea is exemplified by issues such as -

    - There is no evident consideration of positive ornegative externalities that might be generated bydevelopment proposals in the County areas fordevelopments that impinge significantly on Citystructure and services.

    - While there is some prior discussion betweenofficials of both city and county councils, concerningstatutory development plan reviews, this cannotsubstitute for transparent and accountable debate between the elected councils on important planningissues. It is contrary to the representation of theinterests of the local community (as provided in theLocal Government Acts) that this has not occurred.

    - In the absence of adequate prior discussion, the CityCouncil finds that it must make submissions onpublished draft Development Plans, with littlenoticeable results. Although Planning Authorities arenot bound by time limits in making observations onadjoining plans, it is nevertheless interesting to notethat, Limerick County rejected the observations of Limerick City on the Caherdavin Local Area Plan,even though under Section 9 (5) of the 2000 Act they

    were obliged to take these observations intoaccount.

    - In the field of retailing, of central importance to theviability and vitality of the city centre, although a jointly prepared retail strategy has been prepared byall authorities, both County Councils have rejectedthe placing of limits on the scale of development inthe suburbs. Thus the policies of both CountyCouncils do not take account of the effect thatdecisions on major suburban development proposals

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    A.6.4

    In 2007, the DEHLG required that Limerick City, Limerick County and Clare County

    jointly prepare a joint Housing Strategy, a joint Retail Strategy and a joint Recreation

    Strategy. Limerick City would lead the Retail Strategy, Limerick County would lead the

    Housing Strategy and Clare would Lead the Recreation Strategy. The Retail Strategy was

    completed in 2009 but has not yet been considered by the respective councils. The

    Housing Strategy is still ongoing and the Recreation Strategy has not yet been initiated.

    Retail Strategy

    The recently completed study of Mid-West Retailing by Colliers concluded that

    Limerick City Centre, whilst at the top of the retail hierarchy, has suffered most from

    competition from other suburban and out of centre comparison shopping destinations.

    In the past there appears to have been a belief that any retail investment was good as it

    created wealth and jobs.

    What the developments over the last few years have shown, however, is that new retaildevelopment in one location unsupported by a corresponding growth in expenditure

    will divert trade from an existing location elsewhere, with a consequent disinvestment

    and loss of jobs there.

    The review of retail need has demonstrated that this potential was over estimated and

    since 2003, there has been a very signicant growth in retail oor space, a level of

    growth which has even outstripped even the level of capacity identied in the 2003

    Retail Strategy.

    The quantitative assessment of retail need underpinning the 2003 Retail Strategy

    identied signicant potential for the development of additional retail oorspace.

    Limerick County interpreted the 2003 strategy by concluding that if oorspace could

    not be immediately provided in the City Centre, then Limerick County Council

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    proposed that it should be met elsewhere within the Metropolitan Area.

    Whilst there has been growth across the region, the bulk of new oorspace has been

    provided in the Limerick Metropolitan Area. However there has been relatively little

    growth in the City Centre itself. As a consequence the relative importance of the City

    Centre has declined.

    Limerick City Council sought to restrain the development of out-of town shopping

    oorspace, in particular in relation to the proposed expansion of the Crescent Shopping

    Centre. The City Council argued at the Oral Hearing that the sequential test mandated

    by the Ministerial Guidelines ought to favour the City Centre as the rst location for theprovision of any new space.

    However, as reported in the Limerick Leader in March 2009, Limerick County Council

    proposed the view that the City Centre should be accorded no special status:

    "The Crescent is in fact the core of the Dooradoyle centre and under the sequential test

    qualies as a town centre. Under the retail planning guidelines, it is actually one of sixtown centres in the Limerick area."

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    may have on the city centre. In view of the emphasisplaced on financial impact in the Limerick Countyresponse, the clear conclusion is that such policies aredriven by financial rather than planning requirementsince each new centre generates up to ! 5,000,000 in

    capital contributions.- In planning for retailing in the suburbs there is no

    coherent policy. For example, there is an area thatstraddles the Limerick City/Limerick County boundary that is designated in both statutorydevelopment plans as the District Centre forCaherdavin, yet in Limerick County Council'sreview of the development plan for Caherdavin anextensive area of land is zoned for commercial use,including retailing, a short distance away and furtherout the Ennis Road. Permission has been grantedhere for a second major Shopping Centre totalingnearly 500,000 Sq Ft. At the Same time the ClareCounty Plan has proposed a rezoning of landsfurther out again for Commercial purposes on thegrounds that is green field and adjacent to theproposed Motorway Intersection. Both decisions arecontrary to the spirit and letter of the Ministerialdecision on Retailing.

    - In the Clare suburbs no areas are zoned for publicopen space. Consequently, the City Council has had

    to overcompensate in its zonings in an attempt toensure that the population of the City and suburbs isadequately provided for, taken as a whole.

    - The environs in both County areas contain extensivetracts of sporadic and ribbon development, mostlyof a residential nature. This development placesmajor constraints on the proper planning of futureurban expansion.

    - In attempting to agree a joint Housing Strategy asstipulated by law under the Planning Act 2000,neither County Council has agreed to jointly addressthe provision of social housing in the suburbs.

    - The County Development Board strategies,prepared by the adjoining counties, make noprovision for integration with the City DevelopmentBoard Strategy nor are there any efforts to makesuch joint provision.

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    Policy Focus

    A.6.5 Of the three local authorities only the City Council has the city as itssole policy focus. The extended city within the proposed boundaryextension is but part of the remit of the other authorities. It has been

    submitted that the proper planning and management of the areas caneasily be achieved by -

    - adequate liaison between the authorities,- a proper consideration of each other's Development

    Plans when development proposals are beingconsidered and

    - the preparation of a joint Development Plan for the areain question if necessary.

    A.6.6 Apart from the considerations involved in deciding when liaison isadequate, consideration proper, and joint plans necessary, it ispatently evident that this is not the most convenient method of management and planning and it is ineffective to the extent that,given the different objectives of the three authorities, consensus is notalways achieved or achievable.

    Urbanisation and the Urban Economy

    A.6.7 Urbanisation is defined as the spatial agglomeration of population and activities. The definition combines two

    elements, the spatial/physical and the economic. Thespatial/physical element emphasises the high densitysettlement of the continuous built up area, the economicelement recognises the concentration of employment in theindustrial and service sectors.

    A.6.8 The urban area may be viewed as an economy comprising acomplex of markets: a land market, a housing market, a labourmarket, a capital market and a market for goods and services.Each market has a spatial context that is independent of administrative boundaries. The areal extent of the labourmarket, for example, is determined by the maximumcommuting range. The catchment area for services rangesfrom the local to the regional depending on the nature of theparticular service.

    A.6.9 In its response to the Citys proposal, Limerick County refersto the British Core Cities project and promotes it as a modelof partnership for future urban regional development. In factCore Cities is nothing of the sort. In 1995 the City Councils of seven major English regional cities began working together toset out a vision of the distinctive role that big cities must play in

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    national and regional life in the new century, and as theanalysis which is even quoted in the County response makesclear, saying on page 19 that;

    "One of the key challenges is to align governance with

    economic and social objectives. ... cities are fragmented betweendifferent local authorities with limited mechanisms forachieving coordination on key policy goals"

    which is precisely why the City Council has proposed a boundaryextension - in order to align local governance with both the social andeconomic objectives of urban development. The Core Cities participantsgo on to state that;

    Cities need to provide the modern infrastructure and services whichcommunities both in cities and in their regions which are nowlooking forward into the new century expect and have a right toreceive. That is the size of the challenge the Core Cities are determinedto meet successfully.It is a challenge that requires a positive andeffective partnership between the cities and Government .

    This analysis is confirmed by the subsequent British Government background studies leading to a white paper on Urban Policy Thestate of English Cities. This quote is rather long but the analysis is verypertinent

    Cities and regions often do not function well together even thoughproblems and opportunities frequently cross urban and regionalboundaries. But typically this is not recognised, and this gives rise tosuch problems as:

    fiscal exploitation, with the region using but not paying forservices provided by the city; local tax regimes which encourage municipalities to competeagainst each other; administrative boundaries which are often toonarrowly drawn to make economic or social sense. the physical segregation of excluded communities, with anunwillingness across the region to collaborate and share

    services and financial responsibility for those communities;Partnership structures or multi-level collaboration may go some waytowards achieving this, but regions with fewer transactional costs inmounting territorially competitive policies will be more successfulthan those without. And there are likely to be fewer transaction costswhere the boundaries of the administration are wider and fit moreclosely with the functional urban region. In other words, cities willbe more economically successful in an increasingly competitiveEuropean marketplace when their government boundaries most clearly approximate their functional economic areas .

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    A.6.10 Urban growth leading to overspill and administrative sub-division can give rise to problems. Many decision makers

    introduce an element of competition and trade off as eachendeavours, quite properly, to maximise benefits and/orminimise social costs to their own area. Where achieved,consensus inevitably involves compromise.

    A.6.11 If efficiency in operation is to be maximised (like managementeffect) and the quality of public services maintained andincreased (the distributional effect) then a common framework of objectives is necessary. This would be best constructed andimplemented by a single authority charged with theadministration of the city, its suburbs and contiguous lands.

    A.7 SOCIAL IMBALANCE

    Demographic and Socio-economic Indicators

    A.7.1 Rural depopulation is quite properly a matter of local, regional andnational concern. Loss of population from the City to the periphery

    creates similar socio-economic problems and calls for the same levelof concern.

    A.7.2 The drift from the city of the younger, more affluent and skilledsectors of the population gives rise to social imbalance reflected innegative changes in the demographic/socio-economic structure of theCity. The recent profile of Limerick City notes that

    The reduction in socio spatial polarization is not just desirable on grounds of social equity; the problem represents a major constraint onthe citys ability to realize its potential and as such must be of concern toall involved in the citys development.

    A.7.3 Negative demographic and socio-economic indicators over the period1981 to 2002 include the following -

    - Declining natural increase as death rates in the City riseand birth rates fall.

    - The fall in numbers in the 0-14 year school going cohort down 42%.

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    A.7.3

    Between 1981 and 2006, the fall in the under 14 age group is more than 48% - from 18,200 to 9,300.

    Almost one thousand children of school-going age have migrated out of the city with consequent impact onCity schools.

    The population of the city over the age of 65 has increased by 17%

    The following is an extract from the study Facing Challenging Times - (Prole of the City) prepared by Prof

    Des McCafferty which presents the continuing social imbalance and is based on statistics from the 2006

    Census.

    A number of signicant trends emerge from this analysis and mapping of the census of population for 2006, ayear which represents something of a watershed in Ireland and in Limerick, marking as it does the end of a

    sustained period of economic growth and the start of a period of considerable uncertainty about the

    immediate prospects for the national and local economy. Several of the emerging trends were already agged

    up in the report on the 2002 census, but the data for the last four years of the Celtic Tiger period enable us to

    distinguish those that continued and perhaps intensied, and those that weakened or indeed changed

    direction. In addition, a number of new issues have emerged in the more recent period.

    In terms of population distribution, the 2002-06 period witnessed a strengthening of the suburbanisationtrend already well established in the urban area. While the rate of population growth in suburban EDs

    accelerated, the City reverted to population decline after the moderate growth of the late 1990s. Although the

    net change over the decade to 2006 was still positive, the overall increase was small, and 23 out of 38 EDs in

    fact lost population. Population decline continued to be particularly acute in some of the main areas of City

    Council rented housing. Where population increase did occur, it tended to be associated with new private

    housing and expansion of the young adult population, largely as a result of inward migration. There was a

    particularly strong surge in immigration in this four year period, and as a consequence the number of foreign

    nationals resident in the urban area almost doubled. By 2006 non-Irish nationals formed more than half of

    the population in two city centre EDs, and as much as 70 per cent in one EA. Many of the recent immigrantsoriginated in eastern Europe, and Poles now constitute the largest non-Irish nationality in the urban area as a

    whole.

    Reecting the strength of the suburbanisation trend, the focus of new house building shifted strongly back to

    the suburbs between 2002 and 2006, as the apartment construction boom in the city centre came to an end.

    The new suburban developments have been on greeneld sites, some of which are located on the periphery

    of the built-up area, with others (for example in the area near the Groody river) representing a kind of in-ll

    development on land that had been previously leap-frogged by development. The construction collapse of

    2008 is pregured in data that show that, even by 2006, housing supply had outstripped demand, resulting

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    in almost 5,500 vacant units throughout the urban area. Vacancy rates were particularly high in the city

    centre, with more than half of the housing stock in one ED recorded as unoccupied.

    Current problems in the area of unemployment are also foreshadowed in the 2006 census. Having fallensharply between 1996 and 2002, the unemployment rate in Limerick urban area increased marginally in the

    subsequent four years. There were even more marked turnarounds at local level. For example, the

    unemployment rate in the OMalley Park area fell from 47 per cent in 1996 to 27 per cent in 2002, only to

    increase again to 35 per cent in 2006. In general the most marked swings occurred in areas suffering high

    levels of disadvantage, thereby further underlining the vulnerability of these areas. As the EA level analysis

    makes abundantly clear, a number of unemployment blackspots persisted in 2006.

    One of the interesting new trends that the analysis hints at is a shift in the spatial patterns of social class.

    Within a general context of increasing professionalisation of the urban areas population there is someevidence of a movement up the social class scale in areas such as Garryowen and the southern part of Kings

    Island. At the same time the numbers in the unskilled and semi-skilled classes decreased signicantly in areas

    of local authority housing and increased in the suburbs. It is possible that these trends are explained in part

    by class mobility, i.e., changes in a persons social class due to changes in his or her personal circumstances,

    including employment and occupation. However, it seems more likely that they are linked to population

    movements and, in particular, to the on-going shift in housing tenure towards private renting. One result is

    that the degree of segregation of social classes decreased over the period 2002-06. In spite of this, as other

    research currently underway in Mary Immaculate College shows, Limerick remains the most class segregated

    of the medium-sized Irish cities.

    Commuting patterns in Limerick and its hinterland region are very complex and more polycentric in character

    than for the other cities. Trafc congestion was identied as a problem for the city in the 2002 prole also

    prepared by Prof. McCafferty, and this seems to have worsened considerably in the later 2002-06 period, as

    indicated by increasing travel times relative to travel distances. The reasons for this have to do with a modal

    shift towards increased car usage and decreasing car occupancy rates for travel to work, school and college.

    Car ownership rates increased signicantly, particularly in areas where they had been low, with the result that

    there was a degree of convergence in ownership across EDs.

    Increased and more widespread car ownership is one result of the growth in prosperity up to 2006. However,

    the Haase-Pratschke scale of afuence/ deprivation suggests that, in terms of the overall level of socio-

    economic well-being, Limerick did not keep pace with the rest of the country. Rather, the urban area as a

    whole slid down the scale somewhat, and whereas in 2002, 4 EDs of the 43 were classied as very afuent

    relative to the national norm, by 2006 that had decreased to 2. Conversely the number of extremely

    disadvantaged EDs increased over the four year period from 4 to 7.

    Without doubt, a number of the trends summarised in brief above give cause for concern in relation to the

    development of the city in the immediate future. Both demographically and economically, Limerick appears

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    to be underperforming. Without the injection of substantial numbers of immigrants, population would have

    declined even more sharply in the City in general and the city centre in particular. Given that the migrant

    population is heavily weighted towards the younger, economically active age groups, who were attracted to

    Ireland by the employment opportunities created by a buoyant economy, the question that arises is whether itwill remain in the city in signicant numbers as growth gives way to the recession. The fact that the migrant

    population is relatively footloose and mobile adds to these concerns, as does the relatively low degree of

    residential integration with the indigenous population.

    On the economic side the data analysed here suggest that the roots of the current downturn extend back into

    the 2002-06 period, if not even earlier. The downward trend in unemployment had already given way to

    increase by 2006, and the current situation is of course a good deal worse. While job losses have been

    spread widely across the economy, they have been particularly severe in the construction sector, and, in the

    case of Limerick, in manufacturing, due to the downsizing of the Dell factory in Raheen. The spatial analysisdetailed earlier allows us to identify areas where the impacts of these job losses are likely to be experienced

    most severely. By and large they correspond to lower middle class and working class areas of the City. This in

    turn raises concerns about increasing social polarisation, a phenomenon that has been linked in international

    research to the loss of manufacturing employment in particular.

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    - The increase in the number of persons aged 65 yearsand over up 14%.

    - The decline in the number of females in the child- bearing cohorts 15 to 45 years.

    - Falling male participation rates down 7%.

    - Increase in the number of persons unemployed up3.8%.

    - The number of unskilled and semi-skilled workers in theCity up 37%.

    - Changes in the distribution of housing tenure types.

    Demographic and Socio-economic Trends

    A.7.4 Social imbalance is characterised and exacerbated by the trend,prevailing since 1981, in key demographic and socio-economicindicators.

    A.7.5 Natural increase, the excess of births over deaths, fell from 14.9persons per thousand of average population in 1981 to 4.1 in 1996 (seeTable 3).

    A.7.6 The 42.6 per cent decline in the number of persons in the 0-14 yearage cohort will impact on teacher numbers, use of existing

    educational infrastructure and the future number in the city labourforce (see Table 4).

    A.7.7 The population structure of the City is ageing with the percentageaged 65 years and over increasing from 9.1 per cent in 1981 to 14.34per cent in 1996 (see again Table 4).

    A.7.8 The total number at work declined by 8.5 per cent over the fifteenyears to 1996 although there was a welcome increase of 20% between1996 and 2002. The number of males at work decreased by 7.0 percent while the number of females at work in the labour forceincreased by 43 per cent (see Table 5).

    A.7.9 The male participation rate, defined as the number in the labour forceexpressed as a percentage of those aged 15 years and over, declinedfrom 73.4 to 66.0 per cent (see again Table 5).

    A.7.10 The number of socially marginalised persons, defined as thoseunemployed or seeking a first regular job increased by 9.1 and 3.8 percent respectively between 1981 and 2002.

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    A.7.11 The percentage of persons in the higher professional, lowerprofessional and self employed occupational categories in 1991 was15.8 per cent in the City compared to 30.9 per cent in the proposed boundary extension area. By 2002 the Borough had risen to 26% butno corresponding data is available for the environs.

    A.7.12 Semi-skilled and unskilled manual and non-manual workersaccounted for 29.8 per cent of the occupational structure in the Citycompared to 18.0 per cent in the proposed boundary extension areain 1991(see Table 6). However exact comparisons are not possiblewith 2002 due to a change in categorization.

    A.7.13. In the Mid West Region more than 175 EDs lost population between1996 and 2002 and the majority in number of these EDs of these wereindeed rural. The total loss from these EDs was 6,800 persons.However, twenty six of these EDs were in Limerick City and Ennisand these 26 lost more than 3,250 persons or 48% of the total fall.

    A.7.14 Out of a region total of 10,000 unemployed, 44% are located in thecore towns of Limerick/Ennis /Shannon.

    A.7.15 In its various submissions to the Regional Authority prior to theadoption of Regional Guidelines, Limerick City drew attention tothese issues of social imbalance.

    Limerick City Council recommends that brownfield developmentand urban deprivation are recognised in the guidelines as issues to besupported by general policies, both in the region and nationally. The

    report (Regional Planning Guidelines) remains completely silent onthe issue of the regeneration of deprived areas.

    The views of the regional Authority, which represents a primarilyrural ethos was succinct;

    Since the principal areas in need of regeneration are located withinthe city it is not clear what regional policies can achieve. Howeveramendments have been inserted to address the matter in the contextof the role of the city.

    The Regional Guidelines thus dismiss deprivation and regeneration asmatters of an entirely urban concern which is of little concern to theRegion as a whole, the only mention being as follows.

    In addition the re-development of deprived and obsolete areasparticularly within the Limerick City area should be addressed

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    This underlines the deep-rooted rural bias repeated in the responsesand which is entirely at variance with EU policy as outlined above.The City Council has consistently expressed the view that strongcities drive strong regions. This view has been endorsed byinternational experience but this view does not appear to be shared

    by Limerick and Clare Counties who in their responses, see the Cityas a revenue generator subsidising a vast rural hinterland. It is of great concern to the City Council that these subsidy losses from theurban area in turn means that the major social problems of the urbancore are left entirely to the City Council to be resourced from adiminishing financial base.

    Housing

    A.7.16 Social housing is concentrated in the City area accounting for 31.3 percent of total housing stock in the city in 1991 compared to 8.0 per centin the proposed boundary extension area (see Table 7). Most of thelocal authority housing in the proposed boundary extension area isalready provided by the City Council.

    A.7.17 Owner occupied dwellings, with and without mortgages, accountedfor 56.7 per cent of the housing stock in the City compared to 77.2 percent in the proposed boundary extension area (see again Table 7).

    A.7.18 The private rented sector, furnished and unfurnished, accounts for10.0 per cent of city tenants compared to 13.4 per cent in the proposedadded area (see Table 8).

    A.7.19 It is contended that an effective policy designed to meet the objectivesof a better social mix and spatial distribution of housing would be bestachieved by a single implementing housing and planning authority(see Appendix 6 for a fuller statistical analysis of the key indicators setout above).

    A.7.20 In its response to the 1996 proposal, Limerick County Council statedthat the attainment of social balance is an issue which requires to be addressed through an overall housing policy. Despite thesesentiments, the County Council has since then rejected all proposalsfor a joint housing policy in conflict with ministerial guidelines.

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    A.7.16

    Social Housing within the Borough comprises 21% of all housing in 2006 having risen from 2002.

    The following is an extract from Aspects of socio-economic development in Limerick since 1970: LimericksTroubled Estates: Residualised Public Sector Housing by Prof. Des McCafferty.

    While contemporary social problems in Limerick can be traced back to the spatially uneven impact of high

    unemployment in the 1980s, a number of other factors have also contributed. In particular, aspects of

    housing policy at the national level have, perversely, exacerbated problems of poverty and deprivation in

    local authority estates.Foremost among these is the tenancy surrender grant scheme (1985-87) which was

    introduced as an emergency measure to deal with a growing waiting list for public housing, at a time when (as

    now) severe constraints on public expenditure had signicantly reduced the public housing programme. In

    order to increase the supply of public housing available for letting, the scheme offered a grant of IR5,000( 6,349) to households who surrendered their tenancy and moved into the private sector. In order to make

    this move, households in most cases had to be able to secure mortgage nance, and so the scheme was most

    attractive to higher income households in employment. As these households moved out of local authority

    estates they were replaced by lower income families, so that the average income in the sector as a whole

    decreased. Anecdotal evidence from many estates in Limerick at the time suggested that the households

    moving out were also those most actively involved in community and voluntary activity, so that levels of

    social capital also decreased.

    The tendency for average incomes of households in the public rented sector to decrease relative to those of

    households in the private sector has been interpreted in housing policy discourse as a process of residualisation of the public sector. Some insights into the extent of public housing residualisation in

    Limerick are available from a recent (2005) prole of City Council tenant households.

    This found that in terms of the basic demographic attributes of sex and age, public sector renters formed

    a highly distinctive population, with a much higher proportion of females, children, and adolescents, than the

    population as a whole. In total, 56 per cent of the renting population was female, but this rises to 62 per cent

    for heads of household. The youthful age prole was reected in the fact that 36 per cent were aged less than

    15 years of age, with 50 per cent aged under 25 years. The youth dependency ratio (the number of persons

    aged under 15 years relative to those aged 15 to 64) was more than two and a half times greater than in

    Limerick as a whole. Household composition was also signicantly different. The most common type of tenant household consisted of a single adult (lone parent) and children, which accounted for 33 per cent of

    all households, and for 46 per cent of family-based households, precisely twice the rate for Limerick City and

    suburbs.

    With regard to labour market engagement, the activity rate for City Council tenants aged 15 years and over

    (34 per cent) was signicantly below that of the city as a whole (59 per cent), and the unemployment rate (53

    per cent) was almost ve times higher. Given the low levels of employment, it is not surprising that persons

    aged 15 years and over were primarily dependent on social welfare payments as a source of income. In total,

    welfare payments accounted for 83 per cent of all incomes. Reecting the household composition, and in

    particular the high rate of lone parent families, the single most important welfare payment was the one-parent

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    family payment, which constituted the main income source for 30 per cent of primary income recipients (i.e.,

    those with the highest income in each household).

    Social imbalances in the prole of tenant households were associated with particularly high rates of income

    poverty risk. The report found that 80 per cent of individuals lived in households with incomes below thepoverty line, a rate of poverty risk almost four times the contemporaneous national rate. In general the rate of

    poverty risk was somewhat greater for females than for males, with the gender gap widest among heads of

    household, where the female rate was 82 per cent as opposed to 74 per cent for males. Rates of poverty risk

    were inversely related to age, so that the highest rate (89 per cent) was for children. There were also

    differences according to household composition. The highest rate of poverty risk occurred among individuals

    in lone parent households, 90 per cent of whom had incomes below the specied poverty line.

    While the socio-economic attributes described above clearly differentiate local authority rented housing from

    other tenure categories, there is nevertheless signicant variation within the tenure category, with differences

    evident among estates in respect of age-sex proles, unemployment rates and income levels. In general thepattern that emerges is of more imbalanced age, sex and family structures on estates that are located further

    from the city centre. Likewise, the highest rates of poverty risk tended to be in the more peripheral estates.

    These include the area of Moyross formerly known as Glenagross Park, in which 94 per cent of the renting

    population were at risk of poverty, and the Keyes Park / Carew Park area of Southill where the at-risk rate was

    85 per cent. To some extent this geographical pattern corresponds with the age of the estate, less central

    estates generally having been developed later. However, the highest overall rate of poverty risk (96 per cent)

    was for part of the Ballinacurra Weston estate built in the 1950s.

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    A.8 ENFRANCHISEMENT

    Population Overspill

    A.8.1 The failure to bring the administrative boundary of the City broadlyin line with the physical spread of the city has meant that growth inthe population of the city has been accommodated on an increasingscale in the county areas. This has the undesirable effect of removingfamilies and individuals with city roots from the city electorate andfrom participation in the civic affairs of the area to which they areprimarily attached in terms of tradition, personal identity,employment, social life and day to day activities.

    A.8.2 The City and its built up areas form a social, economic, physicallyintegrated interdependent and expanding system. Populationresident within the limits of that system should have an input,through their public representatives into policies and plans for thesystem as a whole. As matters stand 37 per cent of the urbanpopulation has no input into matters relevant to the City. Similarlythose resident within the City have no representation in matters andissues arising in the extended area which affect them.

    A.8.3 In its response, Limerick County rejects the need to align populationand representation the very basis of democracy itself - stating that;

    While the City document argues for twelve new City Councilmembers, it says nothing about the effect on Limerick County

    Councillors. Even if there is not a reduction in the number of Councillors to Limerick County Council, there would be at the veryleast significant changes in the electoral base of many Councillors andin electoral area boundaries.

    A.8.4 According to the Local Government Act 2001, the first duty of a LocalAuthority is;

    to provide a forum for the democratic representation of the localcommunity, in accordance with section 64, and to provide civicleadership for that community

    Within Limerick County the environs of Limerick City are divided between the Bruff and Castleconnell areas thus diluting the urbanvoice in local representation. In Clare the suburbs are part of theKillaloe Electoral area. Nearly 50% of the population of the adjoiningCounty Local Electoral Areas is contained in the suburbs of Limerick.The suburbs of Limerick which are primarily urban in character andinterest are thus denied access to the most relevant forum fordemocratic representation and a voice in determining a future forLimerick City. It is probably worth repeating here that the 2001 Actdefines a local community as;

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    persons ordinarily resident in the administrative area of the localauthority concerned and, where relevant as regards a functionof the authority, includes persons from outside that area whoregularly use facilities of a social, economic, recreational,

    cultural or other nature provided by the authority A.8.5 Again, Limerick County Council asserts that there is ample

    coordination of planning between City and County. It exemplifies thiscoordination by reference to, inter alia, quarterly meetings betweenofficials.

    Co-ordination of planning and development issues within LimerickCity and its hinterland is further enhanced by the Mid West SeniorPlanners Sub-Group and Directors Sub-Group who meet everyquarter to discuss strategic planning issues affecting the area.

    It is the contention of the City Council that such meetings are nomore than good administrative practice and common courtesy. Thekey issue is that such meetings whose attendance is confined tounelected officials and whose tranactions are not public, cannotsubstitute for the transparency and accountability of democraticallyelected unitary governance.

    A.9 FUNCTIONS AND SERVICES

    A.9.0 Local authority services in the City area and the environs beyond areprovided variously by Limerick City Council, Limerick CountyCouncil and Clare County Council. In the case of a number of services in the environs the provider is the City Council. Thisdiversity of provider has led to deficiencies as regards effectivenessand convenience of provision by all three local authorities. Thedeficiencies are summarised below.

    A.9.1 WATER SUPPLY

    A.9.1.1 Limerick City Council provides piped water to the environs in bothCounty areas, sold to the County Councils at less than commercialvalue. There are bulk meters at the points of export and thereafterthe City Council has no control over the use of the water or thecondition of the network. This leads to difficulties that include -

    - The City Council has no control over the amount of water used or the leakage rate in the environs. Thisshortcoming was not so problematical in the past whenthe supply greatly exceeded the demand but now that

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    A.9.1.1 Water Supply

    Limerick City Council's water treatment plant at Clareville has been upgraded to cater for its own predicted

    demand over the next twenty years..

    It will also provide for the predicted demand of Limerick County Council in the City environs and extended

    areas west and south of the City

    Similarly the upgraded supply will cater for the demands of Clare County Council in the City environs.

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    spare capacity is approaching the limit, the matter is of growing importance.

    - There are no formal arrangements for long termplanning or operational liaison between the three local

    authorities.- There is no consultation by the County Councils with

    the City Council prior to the granting of planningpermission for major water users.

    - There are no formal agreements as to what is required by way of volume or pressure at the points of export.The purchasing authorities simply draw off until aproblem arises.

    - When the supply to the Limerick County environs hasto be shut off by the City Council, Limerick CountyCouncil directs complaints to the City Council ratherthan dealing with them directly. Consumers havecomplained about a seeming lack of accountability.

    - Maintenance and repairs of water networks in CityCouncil housing estates in the Limerick County areahave to be carried out by Limerick City Council.

    A.9.2 FOUL DRAINAGE

    A.9.2.1 With a few minor exceptions all of the proposed added area is withinthe catchment of the Limerick Main Drainage Scheme now under way(see Map 2 in Appendix 6). The City Council anticipates that,difficulties in the matter of planning and control will arise similar tothose cited above in the case of water supply.

    A.9.2.2 Maintenance and repairs of sewers in City Council housing estates inthe Limerick County area have to be carried out by Limerick CityCouncil.

    A.9.3 WASTE MANAGEMENT

    A.9.3.1 Limerick City Council and Limerick County Council are preparing a joint Waste Management Strategy but Clare County Council is notinvolved in that strategy. As a result the approach to wastemanagement in the urban area as a whole is disjointed.

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    A.9.2.1

    Current restrictions in trans-boundary surface water drainage channels are hindering development and

    investment and create a potential ood hazard in that part of the city environs drained by the Monaclinostream and Groody River to the East of the City

    Maintenance and repairs at Moyross have been resolved by partial boundary extension of 2008.

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    A.9.5.1

    The two other emergency services (Gardai & HSE) operate on a regional / national basis. These agencies need

    to communicate with all three re authorities concerning any matter involving the emergency services inLimerick City.

    Major Emergency Management operates within one small boundary area.

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    A.9.4 POLLUTION CONTROL

    A.9.4.1 Because the urban area is an entity and because noise, air and waterproblems are no respecters of boundaries, it frequently occurs that asource of difficulty or complaint lies in the adjoining local authority

    area. This is inefficient from the standpoint of the "false alarm"authority that responded to the incident and is inconvenient for thecomplainant. Clare County Council has a particular difficulty in thatresponding officials have to travel all the way from Ennis to carry outinspections.

    A.9.4.2 The difficulties described above are likely to increase as controls overpollution become more comprehensive and more stringent. Forexample, the statutory ban on bituminous solid fuels has beenextended to Limerick city and environs, effective as of 1 October 1998,with three separate enforcement bodies for the overall urban area. Inthat regard Limerick City Council is carrying out these functions forClare County Council.

    A.9.5 FIRE SERVICE

    A.9.5.1 On the operational aspects of the fire service the area served byLimerick City Council extends well beyond the City boundary in alldirections, dictated by response times rather than by local authorityfunctional areas. The Limerick City Fire Service, in common with allFire Services, requires advance, up to date knowledge of all high risk buildings and activities in its operational area. However, outside theCity the Limerick City Fire Service has no rights of inspection to gain

    initial knowledge or to update information. That information, if itexists at all in the public domain, is contained in the records of the twoCounty Councils and does not automatically come to the attention of the City Fire Service. Protocol requires that when the City FireService wishes to conduct inspections outside the City it must beaccompanied by representatives of the relevant County Fire Service.

    A.9.5.2 The class of fire cover provided in an operational area is determined by an assessment of the risks within that area. In the Limerick situation it is preferable for suburban stations, currently at proposalstage, to belong to the Limerick City Fire Service in that such stationscan "back feed" into city emergencies with the minimum of administrative difficulties.

    A.9.5.3 Limerick City Fire Service has no control over fire hydrants outsidethe City boundary. The City Service operates from digitised mapsand removes from its maps any hydrant within the City that ceases tofunction. That practice is not followed by the County Fire Serviceswith the result that the City Service can never be certain that itsinformation on hydrants in the environs is reliable.

    A.9.5.4 On the safety and prevention side of things, although providing theoperational service for the environs, including high risk locations, the

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    City Fire Service has no input into control over the design and layoutof buildings and installations there. The City Service is not consulted by either of the County Fire Services on such matters.

    A.9.6 ROADS AND TRAFFIC

    A.9.6.1 The administration of Limerick City and its environs by threeseparate local authorities, acting as road authorities, is not conduciveto effective and convenient management of roads and traffic in thegreater Limerick area.

    A.9.6.2 The specifications for road construction and maintenance differ between the City and the County areas. The City applies a moredemanding form of construction and maintenance, which should alsoprevail in many parts of the environs. For example, in County areas,even in those quite close to the City, there is widespread use of surface dressing, whereas the City Council would not consider such apractice nowadays, due to the volume and type of traffic in urbanareas. It would be more effective, in the medium and long terms, if Limerick City Council were able to apply urban standards of roadconstruction and maintenance in the environs which are experiencingthe same urban conditions as adjoining roads and streets within theCity.

    A.9.6.3 Limerick City Council currently has to carry out road maintenanceand traffic management in City Council housing developments whichlie outside the City, in Limerick County Council's functional area.These developments have not been taken in charge by Limerick

    County Council, nor does it seem likely that they will be in theforeseeable future. Consequently, Limerick City ratepayers arefunding a considerable amount of road and traffic maintenance inareas which are outside the City.

    A.9.6.4 In traffic management, there is a marked contrast between practicesin the City and the County areas of the environs. Speed limits insome cases change suddenly on leaving the City, regardless of thetraffic conditions. Repeater signs are used to a large extent within theCity, and are not used in the County environs, - again regardless of traffic conditions. Traffic calming measures on regional roads leadingout of the City stop at the City boundary. Traffic signals within theCity show a greater degree of versatility and sophistication in suchmatters as vehicle actuation, programming and linking. It would bemore effective if Limerick City Council were to have morewidespread control of such matters in its County environs as well asin the City. Limerick City Council has installed a system of UrbanTraffic Control. It is less effective since the system does not extend tothe adjoining suburbs in the County areas. Control should obviouslyrest with one authority, which should be Limerick City Council.

    A.9.6.5 Limerick City Council currently has to arrange for trafficmanagement in the adjoining County area in connection with major

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    A.9.6

    The Proposed Northern Distributor Road

    This important piece of infrastructure for Limerick City and the region will result in a signicant reduction intrafc congestion on all northern access routes to the city centre as well as signicantly reducing the amount

    of trafc crossing the three city centre bridges. The proposed route of the northern distributor road passes

    through the administrative area of three local authorities along the northern fringes of the city between

    Coonagh and Annacotty. Despite commitments in 2008 only Limerick City Council have progressed the

    section between Coonagh and Knockalisheen. To date neither Clare or Limerick County Councils have

    carried out work to conrm the route of the road and protect it from development. If the complete route was

    within the administrative area of Limerick City Council this vital road infrastructure would be more advanced

    due to its strategic importance to the city and the region in reducing congestion. This road will also open up

    access to the north campus of UL and the land-banks around it that could be used to prioritise innovationand job creation similar to the National Technology Park.

    PUBLIC TRANSPORT BENEFITS

    The long term planning of Limerick Citys roads & transport infrastructure over the next 30 years would be

    best served by having it all controlled by one large urban authority focused on delivering a world class urban

    transportation system. With Limerick City in charge of the city and its environs it would be much easier to

    deliver a better integrated public transport system and build it up over the next few years by promoting

    sustainable land use policies along key public transport corrridors. With proper planning and cordination of

    our public transport systems and land-use policies, public transport corridors currently served by busescould develop over the next number of years into Bus Rapid Transit Systems (BRT's) and eventually be

    serviced by LUAS type Trams.

    These type of policies would also benet the provision of Park & Ride facilities and to promote their use

    through creating disincentives to bringing cars into the city centre.

    Road Maintenance

    Road maintenance is disjointed between the authorities at present. Limerick City promotes the use of surface

    overlays and quality line marking suitable for urban locations whereas the county councils tend to use road

    surfacing materials such as surface dressing and road lining more suited to rural settings. A good example of this would be the work recently carried out at Athlunkard Bridge. A serious road safety issue existed in

    relation to school children from housing estates in County Clare crossing the bridge to go to school in

    Limerick City. Despite many requests Clare County Council failed to carry out improvement works on the

    bridge to improve pedestrian safety. Limerick City Council then carried out the improvement works after

    requests from parents and councillors in both authorities.

    TRAFFIC

    Specically in terms of trafc management a boundary extension offers an opportunity to improve the City

    and environs trafc planning procedures and to utilise the Citys trafc control tools and statistics.

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    One overarching trafc management strategy can bring better conditions and proven solutions to the issues

    of suburban arterial route congestion and event management.

    The Citys trafc control centre can be utilised to expand public transport priority on the suburban network

    and offer improvements to pedestrian management, parking guidance and park and ride. In addition the

    Citys C.C.T.V. trafc monitoring system can be extended in a cost effective manner to suburban areas.

    The expansion of the Citys U.T.C. system would extend and improve data collection to suburban areas and

    provide improved methods of system maintenance including connections, and networks for regional bus

    management systems.

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    public events or construction work within the City. While co-operation in most such cases is readily provided, the City Council hasno direct control over arrangements within the County areas,especially when unexpected changes occur.

    A.9.6.6 Limerick City Council has no control over large developments,particularly housing in the County area which can have significanteffects on traffic into and out of the City. Some of the trafficproblems arising would be lessened if the City Council had morecontrol over the planning of such developments.

    A.9.6.7 Limerick City Council has no input into the design and road layout of major estates being built in the environs.

    A.9.7 HOUSING

    A.9.7.1 The City Council house building programme was reviewed on fiveoccasions since the passing of the Housing Act, 1966. The rate of construction between 1985 and 1994 averages about 50 houses perannum. During the five years, 1990 to 1995, Limerick City Councilrecorded 218 new starts under the Housing Programme. Thisinvolved the construction of small parcels of housing developmenttogether with the acquisition of second hand housing in both publicand private estates. An assessment of the housing waiting list inMarch 1996 showed an active waiting list of 666 persons.

    A.9.7.2 The City Council provided 433 tenant purchase houses at DelmegePark, Pineview Gardens and Craeval Park, Moyross in the functional

    area of Limerick County Council. Limerick City Council isempowered under section 59 of the Local Government Act, 1955 tomake housing loans to tenant purchasers wishing to acquire adwelling house located in the county area. It was agreed under theprovision of the 1955 Act that it would "be more convenient that thepower, function or duty of making housing loans to tenantpurchasers" be exercised by the City Council.

    A.9.7.3 Social housing is also provided by the City Council in the County areaunder the 1966 Housing Act. Apart from two halting sites no socialhousing has been provided by Limerick County Council in thesuburbs of Limerick. The City Council considers that in terms of estate management it is neither convenient nor effective that theprovision of social housing be divorced from its servicing. This canand does lead to disparity of services between estates.

    A.9.7.4 The major concern of the City Council is the relative scarcity of housing land within the City boundary. A boundary extension byincreasing the amount and spread of developable housing land wouldfacilitate a balanced approach to the disposition of local authority andprivate housing estates thus avoiding the creation of enclaves andachieving better social mix.

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    A.9.8 OPEN SPACE, PARKS AND PLAYING FIELDS

    A.9.8.1 There is a discontinuity between the three local authority areas asregards the provision of open space, parks and playing fields. The

    City Council is alone in having a plan for open space and relatedmatters. Clare County Council provides no open space in itsenvirons area and carries out no tree planting there. Ongoingmaintenance, including grass-cutting of Open Spaces is conducted byresidents. The open space provided in the environs by Limerick County Council contains no playing pitches. The use of City Council-owned pitches is open to all, regardless of place of origin and the ratescharged are subsidised by the City Council.

    A.9.8.2 Limerick City Council carries out the maintenance of open space inCity Council-owned housing estates in Limerick County,notwithstanding that the open spaces are nominally in the charge of the County Council. Riverside walks within the City stop abruptly atthe boundary and the aim of the City Council to effect a cycleway between the city centre and the University campus has been met withseeming disinterest by Limerick County Council.

    A.9.9 OTHER RECREATION

    A.9.9.1 The City Council operates a swimming pool and leisure centre atGrove Island Both facilities are heavily patronized by persons fromoutside the City, including use by groups in reserved sessions. Suchgroups that are based outside the City have no influence on the

    degree of priority accorded to their requirements.A.9.10 MUSEUMS AND LIBRARIES

    A.9.10.1 Limerick City Council runs the City Museum and the City Gallery of Art, both of which are patronized by residents of the city environs.The City Council has a headquarters library in the city centre and a branch library at Roxboro, and a second branch at Moyross. Limerick County Council has a recently opened a branch library at Dooradoyleand a part-time branch at Caherdavin. The County Council alsooperates two mobile libraries for the whole of the County. ClareCounty Council does not provide a mobile library, the nearest branchlibrary being in Killaloe. The City Council understands that there is aproposal for a branch library at Parteen but has no details thereof.Some 20 per cent of City library members are from County Limerick with around 8 per cent from County Clare.

    A.9.10.2 There are no formal arrangements for co-operation between thethree local authorities, and the three library services operateindependent policies and purchasing of stock resulting in someduplication of stock. The computer systems operated by the libraryservices are different and there is no online linkage between them.

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    A.9.10.1

    Limerick City has taken over the former County Council branch library at Caherdavin with the partial

    boundary extension in 2008. A new County Council library headquarters has been established in

    Dooradoyle. Clare County Council has a branch library in Sixmilebridge.

    A.9.10.2

    Following the creation of the Watchouse Cross Branch Library and the partial boundary extension of 2008,

    the following are the usage statistics. Seventy-six percent of members now come from Limerick City. Eleven

    percent are from Limerick County and the remainder are from either Clare or Tipperary.

    There is signicant potential to enhance service to the public by means of an on-line link between the

    services offered by the City and the adjoining counties both in loans and in staff-time that must be spent on

    cataloging.

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    A.10 FINANCIAL MATTERS

    A.10.1 The proposed extension of the boundary will ensure that revenuesraised within the city and the proposed boundary extension area will be dedicated to the functions and services of the extended city onlyand not used, in part, as a vehicle for the cross-subsidisation of policies extraneous to that area.

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    SECTION B : PROPOSED BOUNDARY AND SUBJECT AREA

    B.1 EXISTING BOUNDARIES

    B.1.1 The existing boundaries of Limerick City, Limerick County and ClareCounty are shown in Map 1 in Appendix 7.

    B.2 PROPOSED BOUNDARY AND SUBJECT AREA

    B.2.1 The proposed boundary for the extended City is shown in Map 1 inAppendix 7.

    B.2.2 The proposed extension comprises a total of 4,830 hectares in CountyLimerick and 1,621 hectares in County Clare. These additional 6,451hectares combined with the existing 2,086 hectares of Limerick Citywould give an enlarged City of 8,537 hectares. Further informationon the extended area, including the composite townlands, is given inAppendix 7.

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    B.2.2

    In 2008, the boundary of Limerick City was extended by the incorporation of Limerick

    North Rural ED into the City of Limerick. In the original proposal, the riverside

    boundary of this ED was conned to the High Water Mark on the River Shannon. It did

    not extend to the centre of the river as does the ED boundary. The area of North Rural

    proposed to be added was therefore 2,272.2 Ha. Since the whole of the ED has been

    added, the areas of the proposed added area must now be adjusted.

    Place Area in 2005 Application Area Post-2008 Extension

    Clare 1,621.0 1,621.0Limerick North Rural (Land

    Only)2,272.2 0.0

    Rest of Limerick (Land

    +Water)2,257.8 2,257.8

    Total Limerick County 4,830.0 2,257.8

    Limerick City 2,086.0 4358.2

    Water (in existing +

    extended area)349 411.51*

    * The original 2006 proposal excluded water from part of Limerick North Rural ED.

    However the 2008 extension included all adjoining water in the river Shannon.

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    C.2.1

    The downward trend in population has continued from 2002 to 2006 with the population falling from

    54,058 to 52,539, roughly comparable with the position in 1991.

    C.2.2

    Between 2002 and 2006 the population of the Borough declined by 2.8% while the populations of the state,

    the region and the adjoining counties increased by between 6.3% and 8.4%

    C.2.3

    The population of the proposed added area has increased by 845% between 1950 and 2006 and isestimated to have grown only 3.4% between 2002 and 2006. However this reduced rate of growth contrasts

    with the 34% growth experienced in the six years 1996 to 2002. Almost a tenfold fall in the rate of growth.

    C.2.4

    In 2006, the Aggregate Town area of Limerick County had risen to 43,074, of which the City Environs

    accounted for 34,197 persons. The Aggregate Town area of Clare had risen to 43,391 with 4,021 in the

    suburbs of Limerick. The City suburbs therefore accounted for a smaller fraction of the aggregate town

    population of Limerick in 2006 - only 79.3% as opposed to 94.6%. Likewise the Clare fraction has fallenback to only 9.2% of the aggregate urban area population in Clare. It is clear therefore that urban growth in

    the counties is now far more widespread than hitherto.

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    SECTION C : SOCIO-ECONOMIC MATTERS

    C.1 INTRODUCTION

    C.1.1 This section examines socio-economic matters and sets out for theextended area information on population, the area in hectares and dataon the number of households. Information on rateable valuations andthe number of commercial premises is also set out together withdetails of the estimated annual income generated from commercialrates, charges for services and other sources. This information isprovided for the extended area in aggregate and is also detailed for thetwo adjoining local authority areas.

    C.2 POPULATION

    C.2.1 Between 1951, approximately the date of the last boundary extension,and 1981 the population of Limerick City increased by 0.59 per centper annum rising from 50,828 persons in 1951 to 60,736 persons in1981. Over the subsequent fifteen years to 1996 the population of theCity declined by 1.02 per cent per annum falling from 60,736 personsin 1981 to 52,039 in 1996. The net effect of population growth anddecline over the forty five years from 1951 to 1996 was an increase of 1,211 persons, 2.38 per cent, in the population of Limerick City (seeagain Table 1). Between 1996 and 2002 the population of the City roseslightly to 54,058 persons an increase of 3.8%. Overall in the 51 yearssince 1951 an increase of 6.3% was recorded in the City population.

    C.2.2 In sharp contrast the populations of the State and the Mid-West Regionincreased by 32.3 and 21.4 per cent respectively over the same period.Similarly the populations in Counties Clare and Limerick increased by26.9 and 34.1 per cent respectively (see again Table 1).

    C.2.3 Between 1951 and 2002, the population in the proposed added areaincreased by 814 per cent rising from 4,294 to 30,215 personscompared to a 6.35 per cent increase in the City. During the period1981 to 1996 when population was declining in the City, the populationof the proposed added area increased by an average of 4.54 per centper annum rising from 15,554 to 30,215 persons (see again Table 1).Over the same period population declined by 1.02 per cent per annumin the City.

    C.2.4 In 1996 23,690 persons, 82.1 per cent of the aggregate town populationof County Limerick resided in the suburbs of Limerick as defined bythe CSO. In County Clare 2,780 persons, 7.5 per cent of the aggregatetown population, resided in the suburbs of Limerick. By 2002, theLimerick County figure had risen to 34,824 and the Clare figure to5,704 and the relevant percentages based on these figures areestimated to have risen to 94.6% and 15% respectively.

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    FUTURE TRENDS

    C.2.5 Projection of trends in the City population is as set out in the 2004Development Plan. The size of the future population of Limerick will

    be determined by three major life trends. How many will be born? How many will die? How many will move in or out of Limerick City?

    This simplified picture is complicated by the artificially tightadministrative boundary of Limerick City Council, which means thatthe majority of new growth occurs in the suburbs in Limerick Countyand Clare County.

    Of the major life trends the following assumptions are relevant. The birthrate, which had steadily declined since the 1960s reversed thistrend in recent years and demonstrated a six per cent per annumincrease during the period 1996-2002. It is not certain that this trendwill be sustained and therefore an initial continuation followed by aresumption of decline is assumed over a 20-year period. The impact of a continuation would have a marginal impact on work force housingnumbers although the impact on school numbers would be significant- almost as significant as an increase in the numbers migrating intoLimerick city and its extended area.

    Life expectancy improved dramatically in the 1980s and again

    improved marginally during the 1990s. It is probable that lifeexpectancy will continue to improve and the principal effect is thatthere will be almost a doubling of the population aged 65 and over inLimerick City and its extended area and an increase of about one thirdin the City.

    Migration, because it is concentrated in the middle age groups has avery significant effect on the demands arising from population change.Out-migration tends to concentrate in the 15 to 25 age groups while in-migration, although it concentrates in the 35-45 age cohorts, alsoinfluences significantly the 0-9 cohorts because of associated youngfamilies. Migration therefore affects demand for housing, jobs andschool places. In-migration is most often a side effect of economicprosperity resulting from job creation.

    We may therefore consider two principal scenarios for Limerick Cityand its extended area;

    Scenario one : we could presume that only the natural growth of Limerick City and its extended area population is to beaccommodated.

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    C.2.5

    In January of 2009 the DEHLG published a set of population targets for each region in

    Ireland. In July 2009, the DEHLG published specic population targets for the Gateway

    of Limerick/Shannon and the Hub of Ennis. The intent of these targets is to ensure that

    the Gateway and Hub are accorded a priority and it is proposed that they grow at a

    proportionally faster rate than the region as a whole. According to the DEHLG:-

    The Department fully accepts that economic development and investment strategies at

    national, regional and local levels are therefore critical in supporting the growth of the

    Gateways and Hubs. While it is difcult to make accurate projections in relation to

    economic and employment growth at a Gateway and Hub level, the planning systemmust play its role in ensuring that future development needs are planned for in a

    strategic, plan-led, infrastructure delivery friendly and co-ordinated manner, hence the

    role of regional planning guidelines ... Regional Authorities must incorporate the

    population targets for Gateways and Hubs in this note into the new RPGs, in line with

    the approach recommended

    In the case of the Limerick Gateway the DEHLG target shows a proposed minimumgrowth of 32,000 persons to 2022. Additionally the DEHLG requires that a minimum of

    70% of this target be located within the area of Limerick City. The following table sets

    out the local distribution of the DEHLG Target Populations.

    Place 2006 2016 2022

    Limerick City 59,790 77,642 86,990

    Gateway (Incl

    Shannon)99,979 113,746 126,256

    (Excl Shannon) 91,498 107,352 121,767

    Suburbs of

    Limerick31,708 36,104 39,266

    Updated Material April 2010

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    While the population targets directed by the DEHLG and incorporated in the Draft

    Regional Guidelines have subsequently incorporated in the Draft City Development

    Plans, there is little indication how these targets can be realized. If the City population is

    to grow to 86,990 in the sixteen years from 2006 to 2022 then at least 15,886 houses

    would have to be built within the boundary. This is a rate of construction of about 1,000

    houses per annum. From 2006 to 2009 the rate of construction has been less than 400

    per annum with only 93 dwellings completed in 2009. At an average density of 35

    dwellings per Ha. this would require 453 Ha. but at present the total area zoned

    residential and available for development within the boundary is only 172 Ha.

    Updated Material April 2010

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    Scenario two : on the other hand if we could presume that the rate of job creation which prevailed during the 1996 to 2002 period wouldcontinue, leading to in-migration and higher growth.

    The future population of the City is essentially determined by the

    number of houses contained within the City and by the averagenumber of persons inhabiting each house. The number of housesavailable within the City is reduced by demolition and change of useand is increased by new construction. Sufficient land remains for amaximum of 3,500 dwellings and about one per cent of the total stock is lost every year to demolition. The convergence of these trendsimplies that the total number of houses within the City is unlikely torise much above 20,000 or 21,000 over the coming 20 years. If averagetotal size continues to decline, as it has done throughout the twentiethcentury (to say 2.7 or 2.8 persons per household), then the populationof the City is unlikely to rise much above present level and could evendecline.

    In summary then, over the coming twenty years, Limerick City and itsextended area will experience a population growth of between 21,000and 29,000. There will be a requirement to provide between 8,000 and13,000 new jobs. At least 10,000 and as many as 14,000 new houses willrequire to be built to keep pace with population growth and a further6,000 will be needed to replace demolitions. School numbers will atvery least flatten out but may grow by 5,000. The number of personsover the age of 65 will double from 8,000 to 16,000. Within the City thepopulation will probably stabilize but may grow. The number aged 65and over will grow by about one-third. The number of households will

    grow by about 3,000. Primary school numbers will increase somewhatalthough secondary school numbers will stabilize.

    FUTURE POPULATION OF THE PROPOSED BOUNDARYEXTENSION AREA

    C.2.6 The population of the added area is likely to lie somewhere between54,000 and 67,000 by 2022. This could be an underestimate and theadded area could be required to accommodate a population of up to67,000 most probably exceeding that of the current City. Apart fromdemographic factors such as fertility and net migration, both now onthe increase, the extent to which population levels in the proposedadded area will grow will also be influenced by the success of policiesaimed to promote balanced urban and rural development within thewider region.

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    C.3 THE SUBJECT AREA

    The Townland Unit

    C.3.1 The townlands in the proposed boundary extension are situated in 9District Electoral Divisions (DEDs), five in County Limerick and 4 inCounty Clare. The Limerick DEDs include Ballycummin, Ballysimon,Ballyvarra, Limerick North Rural and Limerick South Rural. The DEDsin Clare are Ballycommon, Ballyglass, Capavilla and Kilealy. Thetownlands in each of the DEDs are set out in Table 9. It is proposed toinclude the whole of each townland with the exception of Ballykeelaunin Ballyglass DED (see again Table 9).

    Advisory Expert Committee

    C.3.2 In proposing the integration of whole townlands within the proposedadded area regard is had to the basic principle (para 5.2.3) stated by theAdvisory Expert Committee on Local Government Reorganisationand Reform 1991 that "urban centres should not be divided by county boundaries with part of the same urban area under the jurisdiction of adifferent county authority". An exception is made in the case of Ballykeelaun townland in order to minimise the impact on the ratesrevenue of County Clare.

    C.3.3 The Expert Report recommends (para. 5.2.3) that immediateconsideration be given to extending the boundary of Limerick City totake in part of County Limerick as specified in Appendix III of the

    Report. While townlands in Clare are not included in the saidAppendix III, it is clear that the basic principle of single jurisdictionapplies in that townlands in Ballyglas DED lie within the Limerick suburbs as defined by the CSO. The inclusion of townlands not yetwithin the defined suburbs is to ensure the proper planning anddevelopment of the area in the future with the objective of ensuringadequate land resources for the accommodation of future populationoverspill from Limerick City and indigenous population growth withinthe proposed added area.

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    Recent Extensions

    C.3.4 Since the 1991 Act was commenced a number of boundary extensionshave been granted, including for example the following:

    Area PreExtension(in Ha)

    Area PostExtension(in Ha)

    % IncreaseIn Area Population2002

    Killarney 1,169 1,534 31.22 12,087Castlebar 393 1,099 179.64 10,287Ballina 433 1,451 235.10 9,478Westport 813 821 0.98 5,314

    The above extensions were granted in 2000, 2001 and later to extendurban administrative areas to encompass the suburbs of growingtowns. These clearly demonstrate;

    That the extending of administrative boundaries is required in urbanareas in order to achieve effective and convenient Local Government.

    That notwithstanding the passage of the Local Government Act of 2001, the extensions were granted under the Act of 1991.

    That the town of Killarney with a population of 12,087 personsencompasses an area 73% the size of the current Limerick City.

    That the town of Ballina with a population of 9,478 personsencompasses an area 69% the size of the current Limerick City.

    Extension Area

    C.3.5 The area of the proposed boundary extension is 6,451 hectares (15,943acres). This comprises 4,830 hectares (11,937 acres) within CountyLimerick and 1,621 hectares (4,006 acres) in County Clare. Thecombined area of the City and the boundary extension area is 8,538hectares (21,101 acres) (see Table 11).

    C.3.6 In addition to those townlands within the suburbs of Limerick theproposed boundary extension includes the villages of Annacotty,Mungret and Parteen. Annacotty and Mungret are within theenvirons of Limerick City as defined in the County Limerick Development Plan and are zoned for urban uses. Parteen is not the

    subject of a zoning objective in the Clare County Development Plan.The inclusion of these villages is critical to orderly planning anddevelopment since they form the central nuclei around which futuresuburban neighbourhoods will be developed.

    Conclusion

    C.3.7 Limerick County Development Plan recognises the nature and degreeof development pressures on Limerick environs. It is submitted thatthe intensity of these pressures demands a holistic/integratedapproach to the problems and potential of Limerick City and itsenvirons. This will prove a more logical, efficient and effectiveapproach than one which is sequential and separate, however well co-ordinated.

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    C.4 RATEABLE VALUATION

    C.4.1 Information on the rateable valuation in the proposed added area is

    based on figures supplied by Limerick and Clare County Councils. Thedetails are set out in Table 12.

    C.5 NUMBER OF COMMERCIAL PREMISES

    C.5.1 The number of commercial premises in the City Council area is 3,239.It is estimated that there are 798 commercial premises in the proposed boundary extension area of County Limerick. The 1997 Clareresponse indicates the commercial valuation base in 1996 comprised 32premises. This is estimated to have risen to 38 in 2004.

    C.6 NUMBER OF HOUSEHOLDS

    C.6.1 There were 16,970 private households in the City in 1996 and anestimated 8,920 in the proposed boundary extension area. By 2002 thetotal households within the City had risen to 18,945 and the number of households in the extension area is estimated to have risen to 12,319. Acheck on the numbers of houses declared by the DOEHLG to have been constructed in the City between 1996 and 2002, revealed thatmisreporting had mistakenly placed 4,000 extra within the City boundary. The misreporting stems from the fact that the averagecitizen cannot believe that the City boundary is so small. Averagehousehold size ranged from 2.94 in the City to 3.32 persons in theproposed added area in 1996. The latter estimate, 3.32 persons, is based on the average size of households in County Limerick and assuch is most likely an underestimate. Taken together, averagehousehold size in the extended city area is 3.18 persons per household.This compares with a total 23,094 households in 1991 with an averagehousehold size of 3.40 persons. By 2002, average household size in theCity had fallen to 2.7 persons and in Limerick County had fallen to 2.9

    persons. In Clare the average had fallen to 2.9 persons also. Currentpopulation estimates for the proposed extended area are based on theAddresspoint data and so averages may be somewhat misleading.

    C.6.2 In order to facilitate a population projection the area base is defined toinclude Limerick City and the DEDs of Limerick North Rural, Limerick South Rural, Ballycummin, Ballysimon and Ballyglass. Futurehousehold size in the proposed extended city is based on extrapolationof the recent trend in household size.

    C.6.3 It is estimated that the number of households in the city and proposed boundary extension area will rise from 31,047 in 2002 to between41,000 and 45,000 in the year 2022, a maximum increase of over 14,000households (see Table 14).

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    C.4.1 RATEABLE VALUATION:

    Information on the rateable valuation in the proposed added area is based on gures supplied by Limerick

    County Council for 2009 rateable period. Up to date rateable valuation details were requested from ClareCounty Council but the request remains unlled. For Clare County Council, the proportion of the rateable

    valuation is based on the 2004 as adjusted by the percentage increase in Clare County Councils overall

    rateable valuation for the period 2004-2009. The details of rateable valuations in the proposed added area

    are set out in Table 12.

    C.5 NUMBER OF COMMERCIAL PREMISES:

    The number of commercial premises in the City Council area for 2010 is 3,363. Details were not made

    available from Limerick County Council or Clare County Council to identify the number of commercialpremises for the period 2009/2010. It is likely the numbers presented in 2005 submission have signicantly

    increased over this period to the current day, as it was the peak period of the building boom.

    C.6.1

    By 2006 the number of households in the City had grown to 19,500 and an estimate prepared using

    Geodirectory indicated that there were as many as 13,400 in the proposed extended area excluding

    Caherdavin which was added to the City in 2008.

    Average Household size in the proposed added area is approximately 3.06 compared with 2.68 within the

    City.

    Future populations and households are based on the DEHLG Regional population targets which are required

    to be assigned in specic proportions to the Gateway and to Limerick City proper by direction of the DEHLG.

    Updated Material April 2010

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    C.7 ANNUAL INCOME

    C.7.1 The effect on the Annual Income of Limerick City Council is set out insection D.

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    SECTION D: ESTIMATED INCOME AND EXPENDITUREFOR PROPOSER

    D.1 METHODOLOGY

    D.1.1 The current proposal for the extension of the City Council boundary isprepared on information fr