Local Government Structures for Limerick 13 April 10 Version 18

8/9/2019 Local Government Structures for Limerick 13 April 10 Version 18

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Submissionto

Limerick Local Government Committee

Limerick City Council

May 2010


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Table of Contents

INTRODUCTION................................................................................................................................1

(A): GATEWAY...................................................................................................................................3

Response to questions posed under Gateway Theme.................................................................5

(B): SETTLEMENT PATTERNS AND REGENERATION................................................................7

Response to questions posed under Settlement Patterns and Regeneration Theme..................12

(C): DISADVANTAGED COMMUNITIES AND SOCIAL HOUSING..........................................15

Response to questions posed under Disadvantaged Communities and Social Housing Theme

...................................................................................................................................................16

(D): GOVERNANCE.........................................................................................................................21

Response to questions posed under Governance Theme..........................................................23

CONCLUSION..................................................................................................................................25

Appendix 1 ................................................................................................................................29

Net Effective Valuation (Commercial Rate Valuation)............................................................29

Appendix 2 ..................................................................................................................................33

Anomalies in Commercial Rates ..............................................................................................33Appendix 3 ....................................................................................................................................39

Net Effective Valuation (Commercial Rates base) per head of population .............................39

GLOSSARY:......................................................................................................................................44


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INTRODUCTION

Limerick City is over 1,000 years old and has been an independent City Council for over800 years. This should not be lightly cast aside. Limerick City must drive competitiveness

for the City, the Mid-West Region and the Country. To do this effectively it must be astrong and successful City. It must have a critical mass of population that will attracteconomic, social and cultural diversity. An effective local governance structure with acoherent vision whose sole focus is the development of the City is essential.

While the Limerick Metropolitan Area (Limerick City and its environs) has the critical massof population to become a strong city the current local governance arrangements (3 localauthorities) militate against this. National policy documents all point to strong citiesmaking strong regions. The proposed boundary extension accords with Governmentpolicy as it will make Limerick stronger.

Since the 1970s Limerick City Council (Limerick Corporation) has highlighted the need toaddress the weak governance arrangements for the Limerick Metropolitan Area and hasmade numerous requests to Central Government to have a single city authority govern thisarea. The most recent submission ' Amended Proposal for a Boundary ExtensionOctober 2005 ' set out four key reasons why the boundary of the City should beextended, with a single city authority, to cover the entire Metropolitan Area. These reasonsare :

1. STRONG CITIES MAKE STRONG REGIONS

2. CITY GOVERNANCE SHOULD BE UNITARY AND REPRESENTATIVE

3. CITIES SHOULD ENJOY JOINED -UP SERVICE PROVISION

4. CITY RESOURCES SHOULD BE RE-INVESTED IN THE CITY

The Boundary Proposal sets out our main arguments for the required change to thecurrent local governance arrangements under these four headings with detailed analysis ofdemographic and economic data to support our case.

In 2005 Limerick City Council submitted to the Minister for Environment its request for aboundary extension. In response to submissions from Clare and Limerick County Councils,we finally submitted a document called the ' Amended Proposal for a BoundaryExtension October 2005'. We understand the Limerick Local Government Committeesterms of reference includes the consideration of this document and the submission of arecommendation in relation to it to the Minister. In order to be helpful we have insertedadditional pages to the Proposal which update the 2005 figures to current values. Theseupdated figures confirm that our requirements for a boundary extension remain aspressing as ever. The Boundary Proposal is supported in the following submission with our

views on the issues raised for consideration by the LLGC.

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In addressing the issues raised for consideration we have given an overview of the currentsituation as it relates to the Limerick Metropolitan Area/ Gateway under the four mainthemes:

A) GatewayB) Settlement Patterns & Regeneration

C) Disadvantaged Communities & Social HousingD) Governance

This overview is in the context of national and regional policy and current regional policydevelopment in the areas of Planning, Retail, Housing and Transport. With regard to thequestions raised by the LLGC in respect of these themes we have given specific responseswhich are well supported in the Boundary Proposal and the overview comments.

Limerick City Council is of the view that the case presented in the Boundary Proposal

provides for the most effective, efficient and innovative government arrangements for theLimerick Metropolitan Area to allow it to fulfil its role as a Gateway to drive, develop andsupport economic recovery and expansion in the Mid West Region.

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(A): GATEWAY

The Mid-West is one of seven regions identified in the National Spatial Strategy 2002-2020. A key concept of the NSS is to develop the potential of each region with more

spatially balanced development throughout the country using Gateways (urban centreswith a critical population mass) to help realise the potential of each region. In the Mid-West, Limerick/Shannon is designated as a Gateway. The NSS states:

Gateways have a strategic location, nationally and relative to their surrounding areas, andprovide national scale social, economic infrastructure and support services. Furtherdevelopment of the five existing gateways at Dublin, Cork, Limerick/Shannon, Galway andWaterford is a key component of the NSS

Gateways are seen as major contributors to the development of the social, environmentaland economic potential of a region. The potential of an area is the capacity that itpossesses, or will possess for development arising from its natural resources, population,labour, economic and social capital and its location relative to markets.

Limerick / Shannon must act as a driver for the region in order to improve its nationalcompetitiveness.

The role given to Limerick / Shannon makes Limerick City the focus of the region anddemands that it perform in a certain manner and to a certain level. Forfs (The NationalPolicy Advisory Board for Enterprise & Science) and the National Competitiveness Council

(NCC) emphasise that cities are the drivers of national competitiveness and of social andeconomic development.

The 'competitive city' has emerged as a magnet for talent, investment and enterprisewhich drives the improved economic performance of the country. Cities also attracttourists, population, jobs, business, higher education, migrants and cultural activities. Theanalysis of competitiveness from an urban perspective is not seen as divisive norpromoting inter-city or rural-urban competition. The city operates within and createsdifferent linkages with its hinterland or region.

For the city to be a driver of economic competitiveness it must be regarded as a strongand successful place. The main prerequisite is a critical mass of population that will attracteconomic, social and cultural diversity.

The Mid West Task Force in its interim report concludes that a strong city is a pre-requisitefor a strong region.

The best way to achieve the above is to have a well planned and managed city thatprovides a high level of services.

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To-date the Limerick urban core element of the Limerick/ Shannon Gateway hasunderperformed. The Mid West Task Force Interim Report states :

The Gateway as a whole cannot progress greatly in GDI terms until the performance ofthe urban core can start to improve.

It is believed that Limerick, and its environs, appear to be punching below their weight interms of economic activity and that unless the issues are addressed in a strategic andcohesive way, the Mid-Wests relative underperformance is likely to be further exacerbatedin todays competitive environment, where enterprise investment is attracted to dynamicurban locations of scale. A dedicated, coherent marketing strategy would also assist inaddressing the negative image of the City.

There are three key issues which, if addressed in the short to medium term with a degreeof urgency, will begin to make a significant difference to the development of Limerick Cityand its environs. These are:

1. The issue of governance in the wider city area2. The Regeneration Plan for Limerick; and3. The development of Limerick City Centre

In the context of the above Limerick City Council concur fully with the findings of theMid West Task Force and are of the view that the Boundary Proposal if implementedwould address these three key issues fully, restore Limerick Metropolitan City as the thirdlargest city in the state and create a functional Gateway to drive, develop and supporteconomic recovery and expansion in the Mid West Region. This is further reinforced in the

data and graphs on Net Effective Valuation (NEV) in Appendix 1 and Anomalies inCommercial Rates Appendix 2.

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Response to questions posed under Gateway Theme

Q1.Are the current local government structures for Limerick optimised tomaximise local government's contribution to developing a successful Gateway?

If not, what are the difficulties and what recommendations would the CityCouncil make to improve them?

The City of Limerick and its suburbs would give the impression, to the casual observer,that it was one cohesive metropolitan area. However the reality is that this metropolitanarea is administered from a local government perspective by three different localauthorities i.e. Limerick City Council, Limerick County Council and Clare County Council.The question is asked as to whether this structure is optimised to maximise localgovernment contributions to developing a successful Gateway. The structures evolvedmany centuries ago, and were formalised in the Act of Parliament of the United Kingdomcalled the Local Government (Ireland) Act 1898.

It is clear therefore that the structures were neither created nor indeed subsequentlyoptimised to foster urban based economic growth.There are many self evident problems with the current structure of these authoritiesdealing with one urban area. These problems, include the lack of cohesion andconsistency in policy and particularly in its interpretation and implementation. This isparticularly evident in the following areas:

Retail Policy In relation to a proposed extension to the Crescent Shopping Centre inDooradoyle in 2008, the City Council formally requested Limerick County Council to refusea permission on the basis of the damage such a large increase in retail in the suburbs

would cause to the City Centre.

Limerick County Council refused the development on traffic grounds but did not accept theimpact such out of town shopping would have on the City Centre.

The City had to subsequently appeal the matter to an Bord Pleanala. Limerick CountyCouncil argued strongly for an increase in out of town retail space at the Crescent.Fortunately, An Bord Pleanala refused permission on the grounds the proposal wascontrary to the Retail Planning Guidelines and that its scale would be detrimental to thevitality and viability of the City Centre.

Housing Policy The implementation of different housing policies by City and County overthe last 50 years has created a situation where there is a 'doughnut' of middle classsuburbs surrounding a City that has the highest proportion of disadvantaged socialhousing in the Country. This lack of social cohesion is at the root of many of the socialproblems of Limerick City, that is damaging the entire City.

Political Representation and Accountability The 40,000 people who live in theurban area of Limerick, but happen to be outside the City, live separate lives from the Cityand its adjoining counties. As they have no vote to elect representatives to the CityCouncil they have no voice in their own City. Similarly, as most of the people involved inthe business of the City reside outside the same line, they also are denied political

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representation and a say in the running of the City.

The current boundaries reflect what might have been appropriate over one hundred yearsago. However, they have long outlived their usefulness and change is urgently needed toprovide a single, focused, representative City Council for the full urban and sub urban areaof Limerick, including the surrounding undeveloped land that has potential to be

developed over the next 50 years.

Q2. What role should the local government system play to enable Limerickreach its potential as a successful Gateway, so as to underpin social andeconomic development and job creation?

It is clear that Government policy is to drive forward the development of the countrythrough the strengthening of the urban based development nodes known as theGateways.

If, as it must, Limerick City is to perform to its full potential as the Gateway of the Mid-West, it is critical that the best possible local government structure is put in place tosupport and implement government policy, as a single urban entity.

All data to date shows that Limerick City is under performing as a Gateway. This indicatesthat current structures are not delivering. It is obvious that a City Council with clearresponsibility for the full urban area is the only local governance structure that will give aclear, focused and singular vision to strengthen the City of Limerick.

A strong City is a pre requisite for the success of the Mid-West Region. There is nointernational example of the opposite i.e. a strong region driven by a divided weak city.Similarly there is no national or international evidence to suggest that a weak urban areasubsumed into a stronger rural county is a recipe for the success of the urban area.

The enlarged City, under the City Council, will have the necessary resources to kick startthe economic recovery that is now urgently required, especially for employment. It isunwise to assess the future of the City from the narrow perspective of a loss of territory. Astronger Limerick City will deliver improved benefits to the three counties of the Mid WestRegion and the wider national economy.

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(B): SETTLEMENT PATTERNS AND REGENERATION

The overview of settlement patterns and regeneration is addressed under a number of key

headings outlined below.

Gateway Population Performance

While the population of the Limerick/Shannon Gateway increased from 2002 to 2006, therate of growth was below the average for the nine national Gateways (5.6%) and was thesecond lowest rate of the Gateways. The annual rate of growth in the Limerick Gatewaydecreased since the 1996 to 2002 period in percentage and absolute terms. It is clearthat nationally, the Limerick/Shannon Gateway is under performing.

Of the population increase in the Limerick/Shannon Gateway from 2002 to 2006, 11%occurred in Shannon and the remaining 89% in the Limerick Suburbs. This occurredalongside a decrease in population in Limerick City. The population of the City as a shareof the Gateway population fell from 68% in 1996 to 59% in 2006. Within the Gateway,the Suburbs and Shannon increased in population significantly; however, theperformance of the Gateway as a whole has been negatively affected by thepoor performance of the City.

City & Suburbs

From 2002 to 2006, the population increase of the City and Suburbs together comprised17% of the population increase of the Mid-West Region. Yet the population increase of theSuburbs alone comprised 24% of the population increase of the Region. This highlightsthat the Suburbs are the dominant population driver in the Gateway. The Suburbs are alsothe largest single contributor to population increase in the Region. This also shows thatthe Suburbs have accommodated the majority of residential development generated bythe Metropolitan Area, while the City lost population. This is highlighted more clearly overthe long-term, where from 1951 to 2002 the City proper increased in population by circa6% and the suburban area increased by circa 800%.

While perhaps typical of suburban development, this pattern of population changeindicates how the development potential of the City has been diluted by development inthe Suburbs. The availability of zoned, greenfield lands in suburban areas has underminedthe commercial viability of potential sites in the City. The ensuing inefficient andunsustainable consumption of greenfield land for extensive, low density suburbandevelopment reduces the viability of high capacity public transport infrastructure withwhich to link the Suburbs and the City.

While there are patterns of change associated with deprivation in some areas of the City anumber of locations have experienced demographic change associated with rejuvenation

including significant population growth. More generally, patterns of economic and

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demographic development across Limerick City Metropolitan Area (Limerick City andSuburbs) highlight issues of inequality and imbalance which are eroding competitiveness.

As the focal point for the Mid-West Region, Limerick City Metropolitan Area functions as asingle, complex and nuanced urban system which is seriously affected by these issues.

Limerick City Council hasarticulated these issues in its Boundary Application

2005and its contributions to recent regional policies (Retail, Housing, RPGs &Transport MWASP) for prioritising and controlling development.

Regeneration Limerick City Centre

The 1996 to 2006 Census data shows that Electoral Districts (EDs) approximating the CityCentre between Mount Kennet Place, Upper Denmark Street and Parnell Street/WickhamStreet performed relatively well demographically. This area, which equates to the Shannon

A & B and Customs House Electoral Divisions generally increased in population;

experienced high levels of in-migration; had a mix of household types; relatively youngpopulations and relatively low levels of local authority rented accommodation. This areaalso exhibited labour force growth; some of the highest labour force participation rates inthe City; decreasing unemployment; low levels of early school leavers; a relatively highlevel of persons who attained third level qualifications and low economic dependencyratios. This illustrates some of the innate strengths and potential of the City Centre.

In addition, the City Centre accommodates numerous features which represent the social,cultural and physical heritage of the Mid-West. These include Limericks Georgian Core,King Johns Castle, St. Marys Cathedral, St. Johns Cathedral as well as a range of other

socio-cultural uses located within the City Centre. Such features within the wider City areainclude Thomond Park and Pairc na nGael, Mary Immaculate College and Limerick Instituteof Technology. These elements represent a significant component of the heritage of theRegion. The unique built environment of the City is being improved by Limerick CityCouncil through a range of initiatives. These include the Park Canal Restoration Project2005, the Limerick Docklands Initiative 2005, the Limerick City Centre Strategy 2008 andthe Limerick City Public Realm Design Guide 2009. The Citys unique public realm sustainsmuch of the tangible and intangible cultural diversity of Limerick and the Mid-West Region.However, these elements of the City must be accompanied by a vibrant mix of othercommercial social uses to ensure their continued viability. Both of these cultural andcommercial components are essential to the creation of a distinct and attractive urbanenvironment.

Despite the significant progress made by Limerick City Council over the last decade ininvestment in the City Centre, substantial investment is required to address the publicrealm issues to allow Limerick Metropolitan City join the ranks of a modern, dynamic,cosmopolitan European city. For this to happen, the overall resources of the MetropolitanCity would need to be combined and prioritised for investment for the benefit of LimerickMetropolitan City and the Mid West Region as a whole.

This requires a single governance structure for the Limerick Metropolitan Area

to ensure an effective and efficient use of resources.

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Regeneration Social Areas

As well as suffering population decline, Moyross, St. Marys Park, Ballinacurra Weston andSouthill exhibit a range of other demographic characteristics associated with deprivationand disadvantage. This has been clearly illustrated by the University of Limerick1. The

need to regenerate these areas is reflected in the significant initiatives underway, inparticular the Limerick Regeneration and Mid-West Task Force programmes.

The FitzGerald Report2 highlights how, if unchecked, the scale of social and economicproblems in the Regeneration Areas could pose a real threat to commercial and social lifein the City and Suburbs. The exodus of population highlighted above supports this view.

The Regeneration Programme is also an important element of the Mid-West Task ForceInterim Report. The Task Force was established to consider the impact of the economicdownturn on the socio-economic fabric of the Mid-West Region. Recommendation 11 of

the Task Force found that the Regeneration Programme should be accelerated due to theseverity of the problems faced. The rationale for the recommendation is that:

The Limerick-Shannon Gateway, with a thriving city at its core, is central to the growthand prosperity of the Mid-West Region. Limerick needs immediate investment to addresssocial and economic issues. (page No. 3)

These reports highlight the importance of regeneration to the City and for theentire Region. The new local governance arrangments must deliverimprovements to the Limerick City Metropolitan Area which can then act as a

focal point for the more effective development of the Mid-West Region.

Employment & Economics

The largest single concentration of workers in the Mid-West is located in Limerick CityCentre, comprising 12.9% of all workers in the Region. The City is particularly dependenton public sector employment. It is estimated that approximately 40% of all workers thereare employed in the public service.

There are significant agglomerations of employment uses throughout the Suburbs, inparticular at Raheen, Castletroy and Plassey. When combined, the Suburbs comprise thesecond largest employment area in the Mid-West with 12.7% of all workers in the Region,marginally less than the City. With regard to sectoral breakdown, while the proportion ofpublic sector workers in the Suburbs is significant (+30%), particularly of those inhealthcare, there is a higher dependence on computer, electronics and softwaremanufacturing. A high proportion of employment in the Suburbs is state agency supported(+50%) also.

1Facing the Challenge of Change: A Spatial Perspective on Limerick. Des McCafferty & Brendan OKeefe, Department of Geography, University of

Limerick, 20092

Addressing issues of Social Exclusion in Moyross and other disadvantaged areas of Limerick City John Fitzgerald2007

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This illustrates the importance of the City and Suburbs within the Region.

More importantly, it highlights the clear spatial and sectoral imbalance and inequality ofemployment opportunities between the City and Suburbs. It also demonstrate the veryreal of delivering Government polices for SMARTER Travel.

This clearly shows the need to have a single vision and focus for job creationand retention for the Limerick City Metropolitan Area.

Retail

The supply of retail floorspace in the Region has doubled since 2003 and is now circa532,000 sq.m net. There is now an over-supply of retail floorspace with approximately86,000 sq.m net currently vacant. The quantum of new retail floorspace actuallydeveloped in the Mid-West has greatly exceeded the estimates as set out in Mid-WestRetail Strategy 2003 2011.

The New Draft Retail Strategy, which has been signed off by the executives of the localauthorities, concludes that there is no need for any additional retail floorspace in theRegion to 2016.

Despite this regional over-supply, the Draft Strategy finds that the City Centre is in urgentneed of a comprehensive retail development to prevent further erosion of its retailposition. The quantum of retail floorspace in the City Centre as a share of the Regionaltotal has decreased by half since 2002. The City Centre retail offer is considered to bequalitatively and quantitatively sub-standard. Rents, sales densities and footfall in

the City Centre are far behind those of other major provincial city centres suchas Galway and Cork. Uniquely, the retail rents in the City Centre are below that of theSuburbs. The Draft Strategy concludes that the City Centre no longer performs to its Tier 1status in the retail hierarchy. It finds that the City Centre requires at least 17,000 sq.m ofadditional non-bulky comparison goods floorspace to 2016, rising to a requirement for40,300 sq.m to 2022 if it is to regain its Tier 1 status.

The Strategy concludes that:

there has been too much suburban retail development in the Limerick urban area andwith very limited retail demand at the present time this is resulting in high levels ofvoids.3

The Draft Strategy finds that these patterns of retail development need to be reversed byre-establishing the City Centre as the preferred retail location at the top of the regionalretail hierarchy.

This view is supported by recent decisions on proposed retail development in the Suburbsby An Bord Pleanala. A proposal for an anchor retail store in Dooradoyle (Reg. Ref. 08/46 /

An Bord Pleanala Reference PL13.230654) was refused by the Board in 2009. The Boardfound that the proposal was contrary to the Retail Planning Guidelines for Planning

3Retail Strategy for the Mid-West Region 2008 2016, Final Draft. p.vi

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Authorities on the grounds that its scale would be detrimental to the vitality and viability ofthe City Centre, having regard to the primacy of the City Centre as the Tier 1 centre withinRegion.

The scale of retail development in the Suburbs has diluted demand for locations in the City

Centre.

This shows that the lack of unitary planning control of market operations covering theLimerick City Metropolitan Area has resulted in excessive developments in the Suburbsrelative to the City centre.

An extension to the boundary will guarantee the proper planning andsustainable development of the Metropolitan City Area.

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Response to questions posed under Settlement Patterns andRegeneration Theme

Q3. If a vibrant and regenerated Limerick is an essential ingredient in

developing the Gateway, where should the focus of development of the city be,and in what order of priority, e.g. the regeneration of the four housing estates,the city centre, suburban areas, under-used brownfield development sites suchas the docklands, or currently undeveloped greenfield sites?

It is clear that if the Gateway is to thrive, a vibrant and regenerated Limerick City is aprerequisite.

There is a pressing need to upgrade the Core City. This will require investment to improvethe quality of the public realm. Major proposals for such works have gone through the

planning process, were submitted for Gateway Fund approval and are ready for tender.These proposals include pedestrianisation of the core areas and much improved facilitiesfor public transport and smarter travel. Our proposal for the core City are set out in our'City Centre Strategy' which was adopted unanimously by the Council in 2008. Limerickneeds a core on par with the best of similar sized cities in Europe.

In conjunction with the above it is of course also critical that the four designateddisadvantaged housing areas are regenerated. Proposals are currently with Governmentfor approval.

While the City Centre and the Regeneration areas are key priorities this will not detractfrom the other options mentioned in the question. The development of under utilizedbrownfield sites in the City should be prioritised before the development of greenfield sitesin the suburbs.

Similarly no further comparison retail should be permitted in the suburbs until the CityCentre has re established itself in the retail hierarchy.

The provision of a better social and income mix is also essential. This would be helped byencouraging more private housing closer to the Centre, rather than facilitating urbansprawl.

The suburbs have a huge role to play in relation to industry and economic activity whichare appropriate to a suburban setting and are not suitable for City Centre.

Again, in order to focus on and drive such coherent strategies a single City authority isrequired.

The new City would be economically sustainable as the full resource of the rates base inthe suburbs would then be focused on the sustainable development of the City as opposedto being dissipated as is currently the case.

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Limerick City, for the first time in probably 50 years would have a single cohesive andfocused vision for the urban area.

As the expanded City and the Dail Constituency of Limerick would almost align,there can be no doubt but that such a cohesive approach would find favour andfunding as necessary from Government.

Q4 What, in broad terms, are the City Councils plans for future development ofthe Gateway, what does the City Council envisage as the impact of thatdevelopment, and what level of cooperation with other local authorities andagencies exists to ensure a coherent focus for future development?

The City is the undisputed driver of the regions economy. Within a boundaryencompassing the whole of the City, Limerick City Council will provide a vision and a focus

for the state agencies engaged in the development of the gateway which hosts nearly halfof all employment in the Mid West region. The City Council will consolidate and expandthe role of the City by enhancing the city centre to provide a focus for modern retailing,creative business and cultural activities. We will take advantage of the Southern Ring Roadand Shannon Tunnel to extend the pedestrianized areas as a foil to the grace andsophistication of the Georgian Architecture of the City.

The City Councils initiative, in the Urban Renewal Programme, cleared dereliction on morethan eighty acres of brownfield lands and generated a private investment of over onebillion euros. This action has stabilised the population of the inner City. Moving away from

the centre, the City Council has provided parks and recreation areas and, through jointventures, a swimming-pool, shopping centre and student accommodation. The innersuburbs are well provided with education facilities at primary, secondary and tertiary leveland there is an evident spinoff benefit to local communities from these facilities.

The outer suburbs represent the frontier of new development in housing, education andindustry. Here the City Council will invest to clear impediments to the extension ofinfrastructure so that the University and the National Technology Park, can play their vitalrole in developing business and employment in the Gateway. By this leadership the CityCouncil will again encourage the participation of private finance in joint enterprise as itachieved in the inner City. The fruits of such enterprise in terms of capital and revenue willbe invested locally to the direct benefit of the Gateway. Suburban developments whichcomplement the role and dynamic of the City centre will be encouraged whileinappropriate and wasteful competition will be discouraged.

Under single leadership and within a defined boundary the City Council can maximise thecontribution of the City to the economic engine that is the Gateway. However the presentfragmentation of responsibility between three local administrations dissipates the effortnot only of the administrations but of the other state and semi-state agencies likewiseinvolved in the development of the Gateway.

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Q5 Are current local government structures delivering a coherent spatialdevelopment vision for the Mid-West Region as a whole?

If one examines the written policy documents of the various local authorities at presentresponsible for the planning of the Region and Gateway, one will perceive a appearance ofcoordination. There are population targets set in guidelines and repeated in local plans.There will be evidence of strategies jointly prepared for retailing, housing recreation andtransport. But then it will be noted that some local authorities dissent from participation insome strategies. All of the region participates in the MWASP transportation strategy.However, North Tipperary dissents from participation in the current review of Retail andHousing Strategies. There is no effort to coordinate the County Development Strategiesunder the auspices of the Regional Authority.

A joint Retail Strategy was prepared by the local authorities in 2003. A review of thisstrategy is currently ongoing between the administrations concerned in the City. There willbe evidence of aspirations in the various plans to keep under review the area of land

zoned for Housing. There will be mention of occasional participation in joint committeeson the promotion of tourism or festivals. Major pieces of infrastructure will have beeninstalled to service lands in the area of the respective administrations. Waste watertreatment, water supply and ring roads will have been installed to serve a common area.

But if you dig a little deeper than this superficial mutual acknowledgement, you will findlittle of substance. Take for example the Joint Retail Strategy of 2003. The preparation ofthis strategy was required by the Minister; it was not therefore entered into as aconsequence of a common purpose by the three local authorities. The most that could beagreed between them in policy terms was the least common denominator. Even though

the intent of the Minister in requiring the preparation of a common policy was to protectretailing in city centres and prevent competition from suburban centres, the localauthorities responsible for these suburban areas would not agree or commit to a policy ofrestricting the growth of suburban floorspace. No limits could be agreed. When the CityCouncil proposed a policy of limitation and proposed to assert leadership by incorporatingthis policy in a development plan review, both Limerick and Clare County Council lodgedformal objection to the proposed variation of the City plan. As a result Limerick City,Limerick & Clare County Councils agreed to incorporate in their plans anodyne policieswhich set no suburban limits. Even though committees of officials have been put in placeto monitor and review the implementation of policy. It has not worked.

The doughnut effect that has been created over the last 30 years in Limerick ispositive proof that the existing local government and regional structures havenot developed a coherent spatial development vision for the Metropolitan area.

Competition, between the City and Rural Authorities over the suburbs hashindered the development of a cohesive vision for the Region. Having a singleCity authority responsible for the full Metropolitan area and having the existingCounty Councils responsible for the rural areas would give clarity.

This clarity would facilitate the development of a more coherent vision for the

Mid West Region as a whole.

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(C): DISADVANTAGED COMMUNITIES AND SOCIALHOUSING

Limerick City has always had a strong presence of social housing driven by sustaineddemand over many years. This is one outcome of the reasonably large industrial base intraditional low and semi skilled industries for which the City was noted from the 1940sonwards, especially food and clothing. In response to local demands and national policy,very large tracts of social housing estates were built particularly from the 1960s through tothe 1980s. Owing to changes in national policy (the surrender grant), changes in familyformation patterns, greater economic prosperity and the growth of private housing supplyin the suburbs and beyond, some of these estates became severely disadvantaged andresidualised at a level that was never intended and could not have been foreseen by theCouncil or other policy makers.

Regrettably these estates did not benefit from the general economic improvements in therecent past and in fact declined in both relative and absolute terms. This decline wasaccelerated by sustained levels of extreme anti social behaviour and criminality whosescope extends beyond resources available to local government and other local agencies.The Government response was the establishment of the Limerick Regeneration Agencies.The agency has to regenerate 4 named estates that contain approximately half of theCouncil's rented housing stock of 2,800.

The current analysis of the social and economic geography of the Limerick MetropoloitanCity by the University of Limerick4 emphasises the social disadvantages outlined above.

4Facing the Challenge of Change: A Spatial Perspective on Limerick. Des McCafferty & Brendan OKeefe, Department of Geography, University ofLimerick, 2009

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Response to questions posed under Disadvantaged Communities andSocial Housing Theme

Q. 6 What are the key features of the City Councils housing strategy which aredesigned to address the well publicised issues of social disadvantage?

The amount of socially provided housing within the Citys boundary at over 44% ispossibly the highest in any Irish city.

In addition the City contains some of the largest social housing estates in the country.Moyross with over 1,100 houses was the countrys biggest estate.

A further compounding factor is the adjacency and contiguousness of estates, with oneestate leading into another. In effect there is a continuum of social housing throughout theCity that is only relieved intermittently with private estates.

These huge estates have, per force, led to extreme socio spatial segregation within theCity boundary, but the contrast is even greater between the City and its suburbs wherethere is almost no social housing. There is a continuing high demand for further socialhousing with over 2,800 households on the waiting list.

These estates are amongst the most deprived communities in the country with very highdependency on social welfare, higher than average unemployment rates, significanteducational disadvantage and low literacy levels, disproportionately high concentrations of

poverty and inhabited by higher than average numbers of single parents.

In Limerick a further special factor is the incidence of serious anti social behaviour andcrime, especially drug related criminality.The decline and social disadvantage of these estates is caused by a complex range of interrelated factors, some of which are set out above.

The outcome is that Limerick City has ranked since 1991 as the second mostdisadvantaged local authority area in the state when taking the concept of social well

being into account and using the composite measure of affluence/deprivation compiled byPobal. Even during the period of strong economic growth 2002-2006 Limerick City's scoreworsened relative to state averages almost entirely due to the social profile of the City.

(Quote from document presented to Limerick City Council from Des Mc Cafferty andBrendan O'Keefe.)5

The housing strategy adopted by the council to begin to deal with these issues follows twobroad heading (1) housing provision and management and (2) social attributes of estates.

5Facing the Challenge of Change: A Spatial Perspective on Limerick. Des McCafferty & Brendan OKeefe, Department of Geography, University ofLimerick, 2009

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1) Housing Provision and Management

Housing Provision

Council housing provision is based on a number of factors. Traditionally the Council relied

on construction for new social supply. The council has generally switched fromconstruction to mainly purchase in the last 3-4 years.As part of this process more than halfthe houses being bought are located in private housing estates thereby fostering greatersocial inclusion. The construction programme features smaller infill schemes.

In addition the City Council fully supports the provision of special needs accommodationfor disadvantaged applicants and works very closely with the voluntary sector in thedevelopment of such schemes. A recent example of this is the McGarry Mews scheme thatdelivered 67 units as an open access hostel for homeless persons with dependency issuesrequiring high support.

Separately the council is providing through its own construction programme high qualityand well located developments for vulnerable households and in particular the elderly.

Housing Management

1. Allocations and Transfer Policies are being used to deliver more stable communities.All households must have Garda vetting and Housing Department clearance prior toallocation.

2. The council has a dedicated team of four staff to investigate reports of anti socialbehaviour of which c. 250 cases are reported annually.

3. Tenant purchase has been suspended in regeneration estates, to prevent housesbeing sold on for private renting, in some cases to households previously evictedby the council for anti-social behaviour (ASB).

4. A housing inspector was appointed in the past two years to monitor tenantscompliance with tenancy agreements.

5. The Council is delivering a planned upgrade of its stock through the energyefficiency programme and the recently completed windows and doors and centralheating programmes. These investments help reduce fuel poverty and improve thequality of life for residents whilst also protecting the significant public investment inthese estates.

6. Vacant and derelict houses in regeneration estates are being demolished at a ratein excess of 100 per year. This reduction in the size of estates has resulted in asignificant decrease in crime and anti- social behaviour and is beginning to foster agreater sense of community and security amongst residents.

7. The 2010 budget for housing maintenance is 3m for a stock of 2,800 rentedhouses and has been protected despite general reductions in local government

funding.

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2) Social Attributes of Estates1. The Council is trying to improve income mix in the estates by judicious allocations.

The objective is to stabilise communities.2. Grants are allocated annually to various community based groups for community

development and estate management. The Council operates the RAPID programme

in three locations and has piloted the Limerick City Community Safety Partnershipwhich, in collaboration with the Gardai and HSE, focuses on elderly, young peopleand low level anti social behaviour.

3. Stigma and Media Attention-the Council is working with residents and communitygroups to ensure a more balanced reporting of incidents in the City and helpredress the stigma attached to some estates.

4. Some estates have very high levels of Lone Parent Households. This is beingaddressed through allocations.

ConstraintsHowever the ability of the City Council to deliver on its strategies as outlined above isconstrained by the limited accommodation supply within the present City boundary. Newsocial housing supply options such as RAS, leasing and the income support providedthrough rent supplement require access to the private housing market. There is anincreasing demand for these options and Government policy is to promote their use. Thispolicy, when coupled with the Council's own acquisition programme in private estates,makes it extremely difficult for the Council to meet these demands within the limits ofprivate housing available in the current City boundary.

It is evident that the under bounding of the City and the subsequent lack of suitableaccommodation militates against the Council delivering on Government housing policies.

Q. 7 To what extent are the existing local authority strategies deliveringsustainable communities, and what level of cooperation takes place betweenthe three local authorities in that regard?

Delivery of Sustainable Communities

At present all three local authorities operate independently of each other. The huge socialimbalances and severe socio spatial segregation that characterises the City, and isparticularly more evident between the City and its environs, arise directly from the longterm under bounding of the City. It is compounded by the policies pursued by Clare andLimerick County Councils where they traditionally did not provide any social housing in theenvirons. In effect almost all social housing obligations for the City are carried by the CityCouncil. This outcome shows that the separate and independent strategies pursued todate by the three local authorities have not delivered socially sustainable and integratedcommunities for the City.

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Within the City, the regeneration process has begun to remove dereliction and is improvingthe physical appearance of the regeneration estates. It has also reduced the incidences ofanti social behaviour. This process, when coupled with more active management policiesoutlined above, is beginning to stabilise these estates and make them more sustainable.

However the Council recognises that for a community to be truly sustainable, there must

also be far greater interventions in the economic, social and environmental areas asenvisaged in the regeneration masterplans.

Inter Authority CooperationThe three local authorities are currently preparing a joint housing strategy. In the interimthe three authorities have agreed a joint protocol governing the purchase of dwellings intheir administrative areas.

This protocol is crucial to deliver greater integration across the entire City. It was fullysupported by the DEHLG and the Limerick Regeneration Agency.

Limerick City Council, having regard to this protocol, ceased purchasing dwellings outsideof its administrative area in October 2007, on the agreed understanding that the other twolocal authorities would purchase dwellings to facilitate the transfer of existing tenants fromthe regeneration areas.

In 2009, the Department of the Environment made specific ring fenced allocations of4.25m to Limerick County Council and O.75m to Clare County Council to support thisprotocol agreement. (Prior to this, Limerick County Council had a policy to declineapplications for housing from applicants with addresses within the boundary or whooriginated from the City).

Limerick City Council however is of the view that progress to date in implementing thisprotocol has been poor.

By end 2009 Limerick County Council had transferred only 11 households and ClareCounty had accepted none. In contrast the City Council had transferred 74 families duringthe same period. This lack of progress demonstrates the real limits to cooperation. Thesocial regeneration of the City needs urgent action. The slow performance of the CountyCouncils reinforces the view of the City Council that greater social integration can beachieved more efficiently and effectively by extending the boundary immediately.

Q. 8 What can be done in terms of new structures or new governancearrangements to improve responses to social disadvantage and to deliverimproved settlement diversity in the region?

The present social profile and socio spatial segregation of the City and its suburbs isdirectly resulting from the local government structures. Neither County Council deliveredsocial housing in the environs. The process of greater inter authority cooperation hasdelivered very little (as set out above), since the City Council was requested to stoppurchasing houses in the environs in October 2007.

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Having regard to the foregoing, the City Council is strongly of the view, as evidenced bythe facts given above, that greater social integration can be delivered most effectively inthe City by a single local authority for the City. The most effective way to deliver this is byextending the present boundary, as per the boundary application.

There is a continuing very high demand for social housing from the City Council and the

housing waiting list now stands at 2,868 households (March 2010). Of this figure 16% ofthe households have an annual income of less than 10,000 and a further 66% have anincome of between 10,000 and 15,000. Further it is estimated that this will rise by circa600 new households in 2010. At the request of the DEHLG a Joint Housing Strategybetween the three local authorities is being drafted.

It is quite clear that further new social supply on the scale necessary to meet this demandwithin the current boundary would have catastrophic social consequences that wouldundermine the viability and future of Limerick City.

If the boundary is not altered, then it is clear that very little new social housingconstruction can occur within the boundary unless it is significantly outnumbered andpreceded by private housing. There is very little scope for the latter owing to the shortageof private building land within the City.

It follows that most new social housing supply will have to occur outside the Cityboundary. While there is no legal impediment to this, it can lead to potential politicaldifficulties under the current governance arrangements.

It has long been accepted that Limerick City must be developed to its fullest extent if it isto deliver on its potential as a strategic Gateway. It is clear that the well publiciseddifficulties experienced in some of our large housing estates have been very damaging tothe reputation and image of the City and militated against its development.

It is also clear that the difficulties associated with the estates can be directly linked to theirphysical size and social profiles. These difficulties have arisen, in part, as a result of thedivergent housing policies followed by the three local authorities over the years and thefailure to develop an integrated policy for the whole City.

Having regard to the foregoing, the City Council is of the view that the social integrationrequired to foster the development of the City can only be achieved by delivering a

coordinated, single vision for the whole City.

The Council therefore believes, in the interest of efficiency and effectiveness and theimplementation of Government policy in relation to the delivery of sustainable andintegrated communities, that the case for the boundary extension has been well made.

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(D): GOVERNANCE

The lack of co-ordination in the Limerick Metropolitan City has undermined the potential ofit to perform as the engine of growth for the Region.

Promoting and achieving the optimised development of the Metropolitan City as the coreof the Region requires absolute coordination of effort, policy consistency and coherence ofcontrol. The Mid-West Task force concludes that a strong city is a necessary pre-requisitefor a strong region6. Recommendation 11 of the Task Force found that the governance ofthe City must be addressed as a priority. A solution to this has been highlighted by anumber of important stakeholders including Forfas:

'Gateways have a critical role in driving regional economic development. In many casesgateway footprints and their functional areas span a number of administrativeboundaries. To date, this has negatively impacted on strategic and cohesive planning,development and delivery for the wider metropolitan areas. It is important that onebody only is designated with responsibility for the strategic development ofthe gateways. Addressing the existing situation could range from boundary extensions,to the establishment of Unitary Local Authority structures, or other incentives to drivecollaborative action.(Regional Competitiveness Agendas: Overview, findings and actions, 2010, p.7, Forfas).

Due to the level of competition for limited investment, solving the problems set out aboverequires the coordinated and phased release of lands to:

Regenerate disadvantaged areas, Achieve critical mass, and Provide high capacity public transport.

Focusing on the Metropolitan components of the Gateway the goal of City is to:

Reinvigorate parts of the City suffering from deprivation and inequality, Provide a strong, mixed-use core for the Metropolitan City and Region, and Assist in economic recovery of the Mid-West.

The emphasis of the strategy is to better co-ordinate development to ensure an optimaldistribution of development capacity at strategically important locations. This will provide a

critical mass of population, employment and commercial activity at these priority locations.It will also maximise the benefits, potential and positive externalities arising frominvestment and development.

The size of the City informs both public and private investment decisions. The NationalSpatial Strategy recognises the relationship between the actual size of a city and the levelof investment it can sustain over time. The efficient and economically sustainable provisionof services and infrastructure will directly influence the quality of life that can be achieved.The main employment centres should be in the City, close to residential areas and servedby public transport.

6 Mid-West Task Force Interim Report, 2009, p.36.

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This will also restore spatial and functional balance across the Metropolitan City andGateway. Restoring a more robust centre will provide a stronger core for the MetropolitanCity and stronger engine for the Region. It is necessary to enhance the cores performancewith positive spill-over effects for the Metropolitan City. The urban core must be developedin a structured and cohesive way, recognising its importance as a key driver of growth for

the Mid-West Region.

To date the Mid-West Region has had a city core that has lost population, with suburbsand villages close to the City that have grown at its expense. Even though some largersettlements distant from the City have grown, commuting times and the use of the carhave increased. The result is a low density city relative to other European and Irish cities.The continued existence of a low density city has inevitable consequences for serviceprovision, infrastructural investment and the attainment of sustainable development.

The critical role of cities in national and regional prosperity requires that they are

successful, strong and vibrant. It is such a city that will attract and sustain increased levelsof population growth. The City should be regarded as a fixed asset with existing transport,telecommunication and infrastructure systems. The Citys historical culture and commercialinvestments which are made over a period of decades has added to this. The clustering ofhigher order facilities in areas of culture, education, health and leisure results in the Citybeing a key resource to be improved for the benefit of its citizens and those of the region,alike.

The 'competitive city' has emerged as a magnet for talent, investment and enterprisewhich drives the improved economic performance of the country. Cities also attract

tourists, population, jobs, business, higher education, migrants and cultural activities. Aprerequisite for this is a critical mass of population that will attract economic, social andcultural diversity. Such diversity combined with a high level of educational attainment willattract a skill base that is entrepreneurial and creative.

It is against this backdrop that Limerick City Council proposes:

A boundary extension (Boundary Submission 2005) to encompass the MetropolitanArea which defines the Gateway City and

An enhanced City Council to govern and manage this area with its primary focus todeliver efficient, effective and innovative governance to:

o Address the current well documented problems (Strategic Planning, Social

imbalance, economic development etc.) ando Ensure Limerick Metropolitan City can play its strategic role in driving

economic recovery and development in the Mid West Region and thecountry as a whole.

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Response to questions posed under Governance Theme

Q9.Are the current local government arrangements delivering quality, efficientand effective services in Limerick and its environs?

If we consider the basic services such as drinking water, waste water, public lighting,libraries, roads, etc, then the answer to the above question is yes. However, the challengefacing the Limerick Gateway is not a lack of basic services but rather a lack of a singlefocused City Authority with a vision and plan for the economic development of the fullurban area.

Q10. How do Limerick City Council, Limerick County Council and Clare CountyCouncil cooperate in providing services and planning for the future? Whatchanges would be beneficial?

The cooperation in relation to the provision of non-controvential basic services is good.For example, the City provides the Fire service for the full urban area, similarly theprovision of drinking water is managed by the City as is the new waste water treatmentplant. However debate in relation to the allocation of costs between Authorities,particularly in relation to drinking water have been ongoing for several years and mayhave to go to arbitration.

The current structure is not the most efficient in relation to planning for the future. Themany statutory plans and policies relating to Development, Retail, Housing, Travellers etc.

have to be approved by three separate management teams and three separate councils.(There are 17 City Councillors, 28 Limerick County Councillors and 32 Clare CountyCouncillors).This is clearly not an efficient and agile process and generally leads to plans that go forthe lowest common dominator.

Q11. Are there significant disparities of quality, equity, availability and/or costin the provision of local services between the three local authority areas?

No . The problem is not about services.

Q12. How do current local government arrangements impede, or contribute to,meeting the challenges of developing Limerick as a successful Gateway?

The current local government arrangements have not made Limerick a successful Gatewayto date and are unlikely to do so in the future. The division of the Limerick MetropolitanCity (Gateway City) between three authorities is clearly not working. The currentarrangement lacks focus and clarity.

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Q13. What local government arrangements would best serve the needs of theMid-West Region as a whole?

It is clear that the best arrangement is to have a boundary extension for the City, to havea single urban authority whose sole function and focus is to drive the development of theGateway.

The existing County Councils of Limerick and Clare should remain and continue to providefor the needs of their areas.

This solution has the merits of being clear, focused and deliverable within the next 6months. It is not depending on government funding, it merely requires a decision.

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CONCLUSION

The sections above highlight the range of imbalances and inequalities between the City

and Suburbs. Demographically, the deprivation within the Regeneration Areas is affectingthe City, which in turn is impacting upon the performance of the Gateway. The socio-

cultural vibrancy of the City and the level of retailing in the Suburbs compete rather thancompliment each other. The imbalances of employment both spatially and sectorallyrepresent significant inequalities in employment opportunities and represent a threat tothe economic viability of numerous locations in the City and Suburbs. The excessundeveloped, zoned land within the Region dilutes the potential for employment andpopulation concentration and any positive externalities that might arise from this. Thisexcess also undermines the potential for public and private infrastructure investment,particularly transport, due to the lack of critical mass provided at specific locations.

Competition for social, demographic and economic investment is intense and resources forinvestment are limited. It is clear that the challenges and solutions are shared bywhat is a single, mutually dependent urban environment comprised of the Cityand Suburbs; the Metropolitan City.

A stronger Metropolitan City is required to improve its constituent parts but also to benefitthe Region as a whole. The importance of a unified, coherent and dynamic MetropolitanCity to the Region is described by the National Competitiveness Council and Forfas:

Cities are increasingly seen as the drivers or national competitiveness and of economicand social development

(Our Cities: Drivers of National Competitiveness, 2009, p.5, NCC & Forfas)

competitive cities have emerged as magnets for talent and investment .. [and] arehubs of international trade, transport and communications and attract higher number ofimmigrants and tourists than other areas in the country.

(Our Cities: Drivers of National Competitiveness, 2009, p.5, NCC & Forfas. )

Successful countries and regions must have successful cities at their coreIt is criticalthat both national and regional policies support the development of Dublin and of ourother main cities and that nationallly we work to ensure that the development of our citiesis fully understood as being in the national interest.

(Our Cities: Drivers of National Competitiveness, 2009, p. 7 & 2, NCC & Forfas. )

One of the central Priority Actions which Forfas recommends to enhance skills andinnovation capacity is to:

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Develop the urban core of Limerick City in a structured and cohesive way, recognising itsimportance as a key driver of growth for the region.

(Regional Competitiveness Agenda: Volume II- Realising Potential Mid-West, 2010,p.26, Forfas.)

These views highlight the need to strengthen and prioritise the development of theMetropolitan City which will increase the opportunities for it and the Region.

The recent patterns of development in the Metropolitan City, if continued, will contributefurther to the emergence of Limerick City as a doughnut city, heavily reliant on suburbandevelopment with a dysfunctional core. These patterns have already provideddevelopment at inefficient and unsustainable locations of a scale that has undermined theevolution of the City. As a result, areas have underperformed and require regeneration asa priority. The scale of this task necessitates a single focused vision for the LimerickMetropolitan City so that the strengths and opportunities offered by all areas in the

Metropolitan City are utilised in a coordinated manner.

It is these imbalances across the Metropolitan City that requires improved managementand governance. This necessitates a single vision and focus for the Metropolitan City sothat these areas would be prioritised due to their importance as focal points for theMetropolitan City and their importance to the competitiveness and employment of the Mid-West Region. For this to happen, the Metropolitan City Area (Map Appendix1), as definedin our Boundary Submission 2005, the Dail Constituency Revised Boundaries 2008 and thegeneral descriptions of the Gateway City in national and regional policy documents,requires an effective local governance structure solely focused on urban management of

this area.

The various policy documents referred to in the Terms of Reference of the Limerick LocalGovernment Committee all highlight the need to address the governance issue of theLimerick Metropolitan City. Below are two such references:

The strategic development of Limerick, as the gateway for the region, has been hinderedby the fact that its metropolitan area falls across a number of local authorities,(Regional Competitiveness Agenda: Volume II- Realising Potential Mid-West, 2010, p.7,Forfas.)

In recent years numerous reports have focused on the governance structure in Limerick.Three councils are involved in a relatively small geographical area which is proving to beinefficient and ineffective in articulating a coherent, ambitious plan for the GreaterLimerick area. These reports have stated that if the governance issue is not tackled thenLimerick City is unlikely to achieve its full potential as a key Gateway City for the Mid-WestRegion. This issue has been referred to by almost all stakeholders to the Task Force as aserious hindrance to the development not only of the City but to the Mid-West Region andneeds to be reviewed as a matter of urgency(Mid West Task Force Interim Report July 2009)

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Limerick Metropolitan City needs to find a whole new development paradigmbased on the principles of sustainability (economic and environmental) andsocial cohesion. It will not be easy to do this, nor should it be expected tohappen quickly or without problems, but it may well be that the recessionaryenvironment is best suited to making the paradigm shift. This in turn calls forintegrated governance arrangements which can best be provided by a single

city authority with its focus on the Limerick Metropolitan City as a driver for theregion as a whole.

Limerick City Councils position is that the model proposed above, which is articulated inour Boundary Application 2005 will address and solve the current problems of ourunderperforming City and is the most effective model to address the leadership required tomake Limerick Metropolitan City play its strategic role as a Gateway City to drive, deliverand support economic recovery and expansion in the Mid West Region and the country asa whole.

Limerick City Council believes that the model proposed, would strengthen theoverall local governance arrangements in the Mid West Region for the followingreasons:

The redefining of the City boundary as the Limerick City MetropolitanArea would address the spatial planning, transport and socio economicissues which have affected the Citys performance and that of theregion.

Competition between the three local authorities for shares in the

Limerick Metropolitan Area would no longer exist. Each authority would be sustainable from a population and financial

perspective (see appendix 3 )

Each authority could focus on the delivery of efficient and effectivegovernance within its own operational environment.

Removal of the boundary issue will allow the three local authorities tomutually focus on the key issues and challenges to develop the Mid-West Region.

In addition Limerick City Council also believes the model proposed is the most effectiveand efficient governance arrangement for the Gateway Region and should be consideredin the drafting of the White Paper on Local Government Reform for the other regions. Thismodel could further be enhanced over time with the strengthening of the Regional

Authorities to oversee and support regional policies. Successful implementation of theDublin Mayor and Regional Authority Bill 2010 would inform how best to approach thisissue.

In the meantime the Limerick City Gateway is in urgent need of new governancearrangements. The model proposed is tried and tested and operates successfullythroughout the developed world. The only reason why it was not progressed earlier is thatthere was no political will at national level to address the thorny issue of a boundary

alteration. Unfortunately the delay in addressing the governance issue over the last thirty

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years has created the current situation whereby the competing interests of three localauthorities has caused the Gateway City to underperform on a number fronts ( socially,economically, and culturally). Not alone has this affected the citizens of Limerick but alsothe region as a whole.

There has never been a more pressing need for clear decisive action to be taken. Thebest option for the governance of Metropolitan Limerick is a City Council withresponsibility for a united Limerick City. Any solution that lacks this focus and clarity ofresponsibility is clearly second best for Limerick City and the Region.

Signed

Tom Mackey, Councillor Kevin Kiely

Limerick City Manager Mayor Limerick City

Dated 2nd May, 2010

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Appendix 1

Net Effective Valuation (Commercial Rate Valuation)

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Appendix (1): Net Effective Valuation (Commercial Rate Valuation)

Local Authorities determine the annual commercial rate charge by taking the valuation ofthe commercial property provided by the Valuation Office, and multiply this valuation bythe current years Annual Rate on Valuation (ARV) (i.e. Multiplier). The ARV is determinedat the annual Budget Meeting. The total of the all of the commercial property valuations is

the Net Effective Valuation (NEV) of the local authority, which could also be interpretedas the rates base of the local authority.

An analysis of the NEV for Limerick City Council area and Limerick County Council area isnoted below, compared to the Gateways of Galway and Waterford (both spilt at CityCouncil and County Council level) (see Figure 1 below). Its clear from the illustrationsnoted below that for the Gateways of Galway and Waterford, the city areas are leading thedevelopment of the county areas with reference to NEV, but the opposite is the case forthe Limerick area i.e. Limerick County Council area is ahead of the Limerick City Councilarea with regards to NEV. This re-emphasises the need for a boundary extension for

Limerick City.

Comparision of Net Effective Valuation (2010)

401,036

277,311

492,028

145,829

372,873

457,805

0

100,000

200,000

300,000

400,000

500,000

600,000

Limerick

County

Limerick

City

Waterford

County

Waterford

City

Galway

County

Galway City

Figure 1: Comparison of Net Effective Valuation for Limerick, Waterford and Galway City

Councils and County Councils.Source: Department of Environment, Heritage and Local Government (DoEHLG) 2010 Budget Documents.

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Appendix 2

Anomalies in Commercial Rates

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Appendix (2): Anomalies in Commercial Rates between Limerick CityCouncil and Limerick County Council

There are a number of anomalies in the area of Commercial Rates which impacts

negatively on the competitiveness of business in the Limerick City Council relative tosimilar business in Limerick County Council and other neighbouring local authorities.

Different valuation formula used by the Valuation Office in LimerickCity Council area compared to Limerick County and Clare County areas:

The Valuation Offices valuers determine the valuation of commercial properties, and theresultant valuation is adjusted by an adjustment factor, which gives the property valuationthat will attract a commercial rate charge. For Limerick County Council area (includingsuburbs of Limerick City) and Clare County the adjustment factor is 50% and for LimerickCity Council the adjustment factor is 63%. See Table 1 below for illustration of this

difference for each local authority area. The difference in this adjustment factor results incommercial properties in Limerick City Councils area having a higher valuation (26%higher) than similar properties in the suburbs of the City managed by Limerick CountyCouncil or Clare County Council. This clearly put a greater burden on Limerick City Councilcommercial rate payers, and results in them being less competitive than similar businessesin the suburbs. This difference incentivizes the doughnut effect in the Limerick CityGateway.

Sample Property Valuation

before adjustment

100000

Final Valuation forCommercial Rate charge

Limerick County Council Adjustment Factor: 50% 50,000

Limerick City Council Adjustment Factor: 63% 63,000 (26% higher)

Clare County Council Adjustment Factor: 50% 50,000

Table 1: Illustration of application of Valuation adjustment factor for sample property for Limerick

City Council area, Limerick County Council area, and Clare County Council area.

As per the Valuation Office the adjustment factors used nationally are as follows:

1. 63% in the cities of Dublin, Cork, Limerick, Waterford and Galway; the countycouncil of South Dublin, Fingal, Dun Laoghaire-Rathdown and the town councilsof Dundalk & Drogheda.

2. 40% in the Town Council of Ennis.3. 50% in all other areas (which includes the Limerick Citys suburbs managed by

Limerick County Council and Clare County Council.

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Significant difference in the commercial rate multiplier (i.e. AnnualRate on Valuation (ARV)) between Limerick City Council and LimerickCounty Council.

The Annual Rate on Valuation (ARV) is the multiplier when applied to the valuation of acommercial property determines the commercial rate charge. The difference in the ARVbetween Limerick City Council and Limerick County Council is 28% in 2010. This means

that traders in Limerick City Councils area pays 28% more in Commercial Rates chargethan in the citys suburbs managed by Limerick County Council. This again leads to acompetitiveness issue for city-centre traders, therefore leading to a worsening of the

doughnut effect with high degrees of vacancy one of these factors. Figure 6belowillustrates how Limerick City Council has made significant strives in reducing this differencefrom a high of 43% in 1998 to the current difference of 28%. A boundary extensionwould ensure that Limericks City centre traders would not be at a competitivedisadvantage to traders in the suburbs as the rates would be equalised across theMetropolitan City.

% Difference Limerick City v's County in Rates Multiplier

28%27%

24%24%

30%

35%37%

38%39%41%

43%43%43%

15%

20%

25%

30%

35%

40%

45%

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Figure 6: Difference between Limerick City Council and Limerick Countys Annual Rate on

Valuation (i.e. Multiplier)

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Limerick City Council has made every attempt in trying to reduce down its Rate Multiplier(ARV), and the Figure 7below illustrates this point. From 1999 to date, Limerick CityCouncil has been equal to or below the National average cumulative increase for RatesCharges.

Rate Multiplier:Cumulative Increase 1999-2010 (base year 1999)

0.0%

10.0%

20.0%

30.0%

40.0%

50.0%

60.0%

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Limerick City Limerick CountyClare County National Average

Figure 7: Cumulative increase in Rates Multiplier (i.e. ARV) from 1999 to 2010 for Limerick City

Council, Limerick and Clare County Council and National Average (source DoEHLG).

Despite Limerick City Councils ongoing attempts to reduce down the ARV (i.e. RateMultiplier) through prudent financial management and continued head-count reduction,the ARV gap between Limerick City Council area and Limerick County Council area still issignificant at 28% in 2010. In contrast for the Gateways of Waterford and Galway therespective ARVs for their County and City Council areas respectively are largely similar. Tointerpret this, there is no significant incentive for businesses to either locate in the City orcounty areas on the basis of the ARV in either Galway or Waterford. Such a factor helps

to avoid the significant doughnut effect that is experienced in Limerick City Councilsarea. The ARVs for these area is noted in Figure 8 , and the clear difference betweenLimerick City Councils ARV and Limerick County Councils ARV can be seen.

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Comparision of Annual Rate on Valuation Budget 2010

66.1266.22

76.46

69.92

66.59

59.92

55.00

60.00

65.00

70.00

75.00

80.00

Limerick

County

Limerick City Waterford

County

Waterford

City

Galway

County

Galway City

Figure 8: Comparison of Annual Rate on Valuation for each Local Authority noted i.e. Rate

Multiplier for Budget 2010 (source DoEHLG).

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Appendix 3

Net Effective Valuation (Commercial Rates base) per head of population

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Appendix(3): Net Effective Valuation (Commercial Rates base) per head ofpopulation for Limerick County Council and Clare CountyCouncil

The measure Net Effective Valuation (NEV) per head of population is a measure of the

general wealth of a local authority i.e. a local authoritys ability to source funding fromlocal commercial rate sources.

The tables below are based on Central Statistics Office population figure from Census2006, NEV figures for Budget 2010 from each Local Authority, and also Limerick CityCouncils Boundary Extension Application 2005 (as revised for 2010). The tables (Tables1 to 4 below) are prepared using local authorities with comparable populations asLimerick County Council and Clare County Council respectively.

Tables 1 and 2 relate to Limerick County Councilpre-proposed boundary extensionand post-proposed boundary extension respectively. As can be seen from Table 1Limerick County Council is ranked at no. 1 pre-boundary extension, and in Table 2,despite a reduction in the Net Effective Valuation due to a boundary extension, LimerickCounty Council is still ranked at no. 1. As noted above, this measure is a measure of thewealth or local revenue generation potential per head of population for a local authorityfrom commercial rates. Therefore, when Limerick County Council is compared to similarlocal authorities by population, it still is better-off than local authorities when using thismeasure post boundary extension, and such comparable local authorities are able to

present a balanced budget each year.

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Population NEV 2010 NEV per head

Rank

2006 of Population

Limerick County-Pre Extension 124,265 457,804 3.68 1

Galway County 159,256 342,500 2.15 2

Donegal 147,264 294,600 2.00 3

Wexford 131,749 237,670 1.80 4

Wicklow 126,194 217,175 1.72 5Mayo 123,839 196,936 1.59 6

Kerry 139,835 204,843 1.46 7

Louth 111,267 138,476 1.24 8

Table 1: NEV for comparable local authorities to Limerick County Council (Pre-Proposed

Boundary Extension).


Rank

2006 of Population

Limerick County-Post Extension 89,726 263,152 2.93 1

Galway County 159,256 342,500 2.15 2

Donegal 147,264 294,600 2.00 3

Wexford 131,749 237,670 1.80 4

Wicklow 126,194 217,175 1.72 5

Mayo 123,839 196,936 1.59 6

Kerry 139,835 204,843 1.46 7

Louth 111,267 138,476 1.24 8

Table 2: NEV for comparable local authorities to Limerick County Council (Post-Proposed

Boundary Extension).

Tables 3 and 4below relate to Clare County Councilpre-proposed boundary extensionand post-proposed boundary extension respectively. As can be seen from Table 3ClareCounty Council is ranked at no. 1 pre-boundary extension, and in Table 4, despite a

reduction in the Net Effective Valuation due to a boundary extension, Clare County Councilis still ranked at no. 1, and in fact experiences a higher NEV per head of population of4.60. This is mainly due to the area in the proposed boundary extension area beinglargely residential with a small commercial rates base. As noted above, this measure is ameasure of the wealth or local revenue generation potential per head of population for alocal authority from commercial rates, and Clare County Council benefits overall from theproposed boundary extension with reference to this measure.

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Rank

2006 of Population

Clare - Pre Extension 110,950 487,889 4.40 1

Limerick County-Pre Extension 124,265 457,804 3.68 2Kilkenny County Council 87,558 222,362 2.54 3

Wexford 131,749 237,670 1.80 4

Wicklow 126,194 217,175 1.72 5

Mayo 123,839 196,936 1.59 6

South Tippearary 83,221 129,901 1.56 7

Louth 111,267 138,476 1.24 8

Table 3: NEV for comparable local authorities to Clare County Council (Pre-Proposed Boundary

Extension).


Rank

2006 of Population

Clare - Post Extension 104,883 482,901 4.60 1

Limerick County-Post Extension 89,726 263,152 2.93 2

Kilkenny County Council 87,558 222,362 2.54 3

Wexford 131,749 237,670 1.80 4

Wicklow 126,194 217,175 1.72 5

Mayo 123,839 196,936 1.59 6South Tippearary 83,221 129,901 1.56 7

Louth 111,267 138,476 1.24 8

Table 4: NEV for comparable local authorities to Clare County Council (Post-Proposed Boundary

Extension).

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GLOSSARY:

Limerick City The administrative area governed by Limerick City Council

Limerick City Centre The core area of the city as defined in Limerick City Council's City

Centre Strategy'

Limerick Metropolitan City The area identified in national and regional policy documents as the

urban environment encompassing the administrative area of Limerick

City Council and Limerick and Clare County Councils' built up

administrative areas adjoining Limerick City.

Gateway City Similar to Limerick Metropolitan City

Limerick City Environs The area outside the administrative area of Limerick City and within

the boundary of the Metropolitan City.

Limerick City Suburbs The physical built environment outside the administrative area of

Limerick City and within the outer boundary of the Limerick

Metropolitan City.

MWASP Mid West Area Strategic Plan

RPG Regional Planning Guidelines