REVIEW OF PART OF THE BOUNDARY BETWEEN THE COUNTIES OF CEREDIGION AND PEMBROKESHIRE IN THE AREA OF THE COMMUNITY OF ST. DOGMAELS

REPORT AND PROPOSALS

INTRODUCTION
EXECUTIVE SUMMARY
SCOPE AND OBJECT OF THE REVIEW
DRAFT PROPOSALS
SUMMARY OF REPRESENTATIONS RECEIVED IN RESPONSE TO THE DRAFT PROPOSALS
THE AFFECT OF ANY PROPOSALS ON THE COUNTY OF CEREDIGION
ASSESSMENT
PROPOSALS
CONSEQUENTIAL ARRANGEMENTS
ACKNOWLEDGEMENTS
RESPONSES TO THIS REPORT

Edwina Hart AM MBE

Minister for Finance, Local Government and Communities

The National Assembly for Wales

1. INTRODUCTION

1.1 We, the Local Government Boundary Commission for Wales (the Commission), have completed the review of part of the boundary between the Counties of Ceredigion and Pembrokeshire in the area of the Community of St. Dogmaels and present our proposals for a new boundary.

2. EXECUTIVE SUMMARY

2.1 It is our view that, in the interests of effective and convenient local government the village of St. Dogmaels should be combined within one principal council area. Having considered the evidence available to us we have concluded that the Community of St. Dogmaels should be in the principal council area of Pembrokeshire.

3. SCOPE AND OBJECT OF THE REVIEW

3.1 Section 54(1) of the Local Government Act 1972 (the Act) provides that the Commission may in consequence of a review conducted by them make proposals to the National Assembly for Wales for effecting changes appearing to the Commission desirable in the interests of effective and convenient local government.

Procedure

3.2 Section 60 of the Act lays down procedural guidelines, which are to be followed in carrying out a review. In line with that guidance, we wrote on 2 March 2000 to Ceredigion County Council, Pembrokeshire County Council, Cardigan Town Council, St. Dogmaels Community Council, the Members of Parliament for the local constituencies, the Assembly Members for the area, the local authority associations, the police authority for the area and political parties to inform them of our intention to conduct the review, to request their preliminary views. We invited the Ceredigion and Pembrokeshire County Councils to submit suggestions for changes to the boundary. We also publicised our intention to conduct the review in local newspapers circulating in the area and asked the councils to display a number of public notices.

4. DRAFT PROPOSALS

4.1 We received representations from Ceredigion County Council, Pembrokeshire County Council, Cardigan Town Council, St. Dogmaels Community Council, Jackie Lawrence MP, Simon Thomas MP, Elin Jones AM, 2 councillors and 189 other interested bodies and residents. These representations were taken into consideration and summarised in our Draft Proposals published on 15 December 2000.

4.2 Our Draft Proposals recommended that the whole of the village of St. Dogmaels be combined within one unitary authority and that the authority should be Pembrokeshire. We proposed that the boundary between the Counties of Ceredigion and Pembrokeshire in the area of the Community of St. Dogmaels should be realigned as shown in green on the map at Appendix 9 to include the areas marked Area A and Area B within the County of Pembrokeshire.

4.3 Copies of the Draft Proposals were sent to all the councils, bodies and individuals referred to in paragraph 2.2 seeking their views. A copy was also sent to anyone who had submitted preliminary comments. By public notice we also invited any other organisation or person with an interest in the review to submit their views. Copies of the Draft Proposals were made available for inspection at the offices of Ceredigion County Council, Pembrokeshire County Council and the Commission and were also deposited at the offices of the Dyfed-Powys Police Authority.

5. SUMMARY OF REPRESENTATIONS RECEIVED IN RESPONSE TO THE DRAFT PROPOSALS

5.1We received representations from Ceredigion County Council, Pembrokeshire County Council, Cardigan Town Council, St. Dogmaels Community Council, Cilgerran Community Council, Jackie Lawrence MP, Dr Richard Edwards AM, Delyth Evans AM, Glyn Davies AM, two County Councillors, 3 Community and Town Councillors, 11 other organisations and 572 residents. A letter was also received on behalf of residents of the additional areas to the south east of St. Dogmaels that Pembrokeshire County Council suggested be transferred from Ceredigion to the Communities of Cilgerran and St. Dogmaels in Pembrokeshire. All of these representations were considered carefully before formulating our proposals.

5.2 Ceredigion County Council submitted a report. The full text of this report may be found at Appendix 1. The main points of the report are as follows:

The Council believes that the Boundary Commission has not addressed the main issue, namely the provision of effective and convenient local government services in the combined St. Dogmaels village by one local authority. The Council agrees that the village should be “combined within one authority” and notes that both Councils have indicated that they “are confident that they would be able to provide an appropriate level of service to the combined village of St. Dogmaels”.

The Council however takes issue with the reasons given in the Commission’s Draft Proposals for stating that the combined village should be placed within Pembrokeshire as follows:

Paragraph 3.12 of the Draft Proposals Report lists improvements in areas of service delivery, which, it is claimed, would follow if the combined village was located in Pembrokeshire. However, the same principle is true if Ceredigion administered the area.
Paragraph 3.13 states that “It is clear that some degree of cross-boundary provision of services would still be required whichever county the new community was in”. The County Council is at a loss to understand, should the combined village be placed in Ceredigion, which services its population would need to receive from Pembrokeshire County Council.
It is the crux of the County Council’s case that the residents of the village currently turn to the town of Cardigan for services such as the library, leisure centre, swimming pool, secondary education etc and, with Ceredigion providing all the other services such as Social Services, Education, refuse collection, highways etc to a combined village, there would be no need for the population to be provided with any services at all by Pembrokeshire County Council, thus resulting in more effective and convenient local government.
In Paragraph 3.14 the Commission considered that the level of council charges was not “a primary reason for wanting the combined village of St. Dogmaels to be included within Pembrokeshire”. However, Ceredigion County Council pointed out that this is listed as the SECOND point made by St Dogmaels villagers. This hardly suggests that it isn’t one of the main reasons for them opting for the combined village to be placed in Pembrokeshire rather than Ceredigion.
The Council contend that the Commission’s statements that the River Teifi is a natural boundary (Paragraph 3.16) and that Bridgend is an integral part of Cardigan Town are contradictory. The suggested break-up of the area south of the river Teifi, in the view of the County Council, is therefore highly inconsistent and does not lead itself to effective and convenient local government.
It is the Council’s view that the Commission has given more weight to emotion than to effective and convenient local government. It is the contention of the Council that the people currently living on the Pembrokeshire side of St. Dogmaels are regular users of the services provided by the Ceredigion County Council in Cardigan Town, and paid for by Ceredigion Council Tax payers, and that it is the intended purpose of the St. Dogmaels Community Council to wish to continue to see its people benefit from these services yet pay their Council Tax to another Authority. The people of St. Dogmaels would therefore benefit from paying lower Council Tax and still enjoy the services provided in Cardigan Town by the Ceredigion County Council and paid for by the people of Ceredigion.
The differing Council Tax levels in Pembrokeshire and Ceredigion are the product of a national formula, which is used to distribute resources between unitary councils. The formula is frequently reviewed and a recent review has seen the reduction in the differential between levels of Council Tax. As Ceredigion has consistently set its Council Tax levels below the National Assembly guidelines, in time, this is likely to result in an equalization of Council Taxes between the two authorities.
Ceredigion County Council contend that the people of St. Dogmaels make full use of the services provided by Ceredigion County Council and that it is only reasonable for them to contribute to the costs of service provision. There is no evidence to suggest that this cost of service provision is higher in Ceredigion - on the contrary, it is the Revenue Support Grant distribution formula, which governs the level of Council Tax. It is undoubtedly more accountable if residents pay the Council, which provides the services. This is the essence of effective Local Government and public representation.
The County Council States that if St Dogmaels is transferred to Pembrokeshire, there will be a significant, and disproportionate switch of resources in favour of Pembrokeshire at the expense of the Council Tax payers of Ceredigion and it cannot be equitable to expect the Council Taxpayers of Ceredigion to meet the additional tax burden.

The Council noted that the Commission (in a letter of 17 January 2001 in response to the Council’ s initial response to the Draft Proposals) states that the County Council did not provide any evidence that losing part of its administrative area would be detrimental, in terms of effective and convenient local government, to the Authority as a whole. The Commission’s proposals, in the view of the Council, by making more users of the Cardigan–based services Council Taxpayers in Pembrokeshire, would exacerbate the situation and create more inequality and bad feeling in the area.

In conclusion, the Council considered that the proposed changes would therefore have a detrimental effect on the ability of Ceredigion County Council to provide the current level of services throughout the County. It would adversely affect effective and convenient Local Government not only in the environs of Cardigan but throughout the whole County.

5.3 Pembrokeshire County Council submitted a report that was considered and approved by the Policy & Resources Committee. The full text of this report may be found at Appendix 2. The report resolved that: -

Pembrokeshire County Council propose to the Local Government Boundary Commission:

that this Council expresses strong support for the proposals made by the Boundary Commission to unify the St Dogmaels community within Pembrokeshire by including Area A and B (on the map at Appendix 6 of the Draft Proposals report).
that in the interests of effective and convenient local government and based on very strong local support, Areas C and D (on the map at Appendix 7 of the Draft Proposals report) become part of Pembrokeshire, contained within St Dogmaels and Cilgerran Community Councils respectively.

The Council also brought to our attention, the questionnaire that Cardigan Town Council had circulated to all residents in the area of Cardigan town. A number of concerns have been expressed by the local member and residents of St Dogmaels regarding the way this exercise has been carried out and this Council made the following comments:

the covering letter for the questionnaire is emotive and makes a number of statements that could be interpreted as scare mongering.
the questionnaire was distributed to all residents living in the area of Cardigan town. Residents were not asked to supply their name/address details. A space was provided for a postcode to be entered but this is not mandatory. It is considered that this is unrepresentative to the boundary issue in question and is therefore invalid.

5.4 Cardigan Town Council submitted a report (Appendix 3) making the following points:

The Commission has failed to give due attention to the evidence presented to it.
The Commission has failed to give legal reasons to support their findings as effective and convenient.
The Commission has failed to consider the impact on both sides of the proposed boundary, Cardigan, Ceredigion and St Dogmaels. Further, the precedent set will make the future Cilgerran-Pembrokeshire boundary review almost impossible to counter.
The maps (see enclosure 1) show quite graphically that Cardigan Town will reduced in area by some 45%. The maps used by the Commission were misleading as they failed to show the whole town and the impact on it by their proposals. Map number 2 demonstrates what will happen if St Dogmaels and the ‘extra bit’ wanted by Cilgerran and Pembrokeshire is transferred to Pembrokeshire. If St Dogmaels is lost then Cilgerran will obviously have to go the same way for the same reasons. Future growth of the town will be limited due to the geographic constraints of the proposed remnant of Cardigan town.
The map (number 1) shows that the outline of Cardigan forms almost a circle. St Dogmaels forms about l2° of that 360° and for the unification of St Dogmaels approximately a 120° slice is to be removed from the circle (180° when including the Cilgerran proposals). Surely it would be more convenient to include the small area into the much larger area, as shown in map number 3. This clearly shows a discrete administrative area that is indivisible and in the same valley.
The town council take the view that this combined area should be in Ceredigion for the reasons stated within and before.
Historically there has been a failure of cross boundary co-operation from Pembrokeshire County to support both service provision and development in Cardigan. Had this support been forthcoming then there would have been more and better services available for the mutual benefit of both communities.

5.5 St. Dogmaels Community Council submitted a report (Appendix 4) in which they consider that the case for re-unification under the authority of Pembrokeshire is overwhelming and feels that the following points illustrate this conclusion:

Pembrokeshire Services are perceived to be more reliable, efficient and cost effective; they also have a service depot in Fishguard.
The Pembrokeshire area of the village has the larger population.
The Stabilisation Drainage Programme, following the St. Dogmaels landslip of 1994, is ongoing, expensive to maintain and requires continuity of expertise.
St. Dogmaels is historically and intrinsically rooted in Pembrokeshire.
St. Dogmaels is detached and has a separate identity from Cardigan Town.
Village organisations receive continued support from the Community Council.
Many current projects are reliant on Pembrokeshire funding.
Pembrokeshire’s planning policy is considered to be more aesthetically sensitive.
Objective 1 applications (two feasibility studies have recently been conducted).
Over 90% of the population of St. Dogmaels wish to have the village re-unified under the authority of Pembrokeshire.

5.6 Cilgerran Community Council considered that in the interests of efficiency of effective local government that Areas C and D on the map at Appendix 7 of the Commission’s Draft Proposals report be considered for transfer to Pembrokeshire. They consider that Area D should become part of the Cilgerran Community as the vast majority of residents have for some time been eager to become part of Pembrokeshire. Pembrokeshire County Council already, on a weekly basis, collect the refuse of some of the residents even though they reside in Ceredigion.

5.7 Jackie Lawrence MP expressed her full support for the views of St Dogmaels Community Council and the residents of St. Dogmaels in their wish for the village to be reunified according to the Commission’s Draft Proposals report.

5.8 Dr Richard Edwards AM wrote in support of the proposal to reunify St Dogmaels within Pembrokeshire. He considered that a variety of factors militated in favour of St. Dogmaels being reunified under the county of Pembrokeshire, including historical circumstances, and the will of the people of the community itself.

5.9 Delyth Evans AM expressed her support of the proposal to reunify St Dogmaels within the county of Pembrokeshire.

5.10 Glyn Davies AM, after looking into the matter and discussing the issue with several people in the area, is of the opinion that St Dogmaels should remain in Pembrokeshire.

5.11 County Councillor Stephen Watkins (St. Dogmaels, Moylegrove and Nevern electoral division, Pembrokeshire County Council) supported the Commission’s Draft Proposals and also supported Pembrokeshire County Council’s suggestion that Area D should also be moved into its area.

5.12 County Councillor Mair Morris (Aberteifi/Cardigan electoral division, Ceredigion County Council) was disappointed at the conclusion reached by the commissioners in their draft report. She did not believe that it was going to provide efficient and convenient local government, for the following reasons:

as Cardigan Town is but a stone throw from St. Dogmaels, how can it be more convenient and efficient for the residents of St. Dogmaels to be administered by an Authority with which the nearest town is some 20 miles away?
Ceredigion is already a smaller authority than Pembrokeshire, this decision can only exacerbate the situation. Less funding for Ceredigion will inevitably lead to less finance for the provision of services in Cardigan. Services that will continue to be needed by the residents of St. Dogmaels, whether they are in Pembrokeshire or Ceredigion.
Cheaper Council Tax and free bin liners should not be considered as a good enough reason to influence the decision of any of the residents affected.
In the Draft Report, the Commission seems to misunderstand the implications of the loss of precept for Cardigan Town Council. The money that is spent on services and projects in Cardigan benefit both Cardigan Town residents AND the residents of St. Dogmaels.
Councillor Morris does not understand how, in the report, the Commission can state that the river Teifi “represents a clearly defined natural boundary”, and then go on to say that the Bridgend area, on the other side of the river Teifi “is an integral part of Cardigan Town”. Councillor Morris is of the opinion that St. Dogmaels is also an integral part of Cardigan Town as there is a pavement linking the two areas and also over the past few years, new housing built along the Cardigan-St. Dogmaels road very nearly links the two communities.

Councillor Morris considers that the proposals as they stand would be to the detriment of Cardigan Town, and ultimately will have a negative knock-on effect on a very wide area including the residents of St Dogmaels.

5.13 Councillor Bob Doyle (Cardigan Town Council), in a letter sent to the local press, considered that at a time when the base industry of the area is going through a crisis and money is scarce; resources need to be pulled together rather than splitting the main area of population and therefore the source of potential revenue, into two separate local authorities. Councillor Doyle stated that the best result for all would be to leave it as it is.

5.14 Councillor Graham Thomas (Cardigan Town Council) considered that allowing the boundary change in favour of Pembrokeshire would do more harm to Ceredigion than good to Pembrokeshire. He was of the opinion that the status quo should prevail. Councillor Thomas expressed the view that it is Pembrokeshire’s intention to eventually take over the area of land on the bank of the River Teifi which would cause Cardigan and Ceredigion to lose the abattoir, Pentood industrial estate, the cattle market and the historic buildings, one of which houses the Heritage Centre. Councillor Thomas also stated that houses are continually being built along the main road between Cardigan Town and St Dogmaels and the two will become indistinguishable within twenty years.

5.15 Councillor Valerie Fletcher (Vice Chairman, St Dogmaels Community Council) stated that she and many Pembrokeshire residents of St Dogmaels serve on committees and make financial contributions to Cardigan Town’s many organisations. The Councillor also reported that feedback from the village-based organisations is that the support from Cardigan has not been of equal measure. Whilst organisations do receive donations from the Town Council, likewise Cardigan receives donations from St Dogmaels Community Council, whose precept is around 90% less. Councillor Fletcher also noted that whilst the Community Council has reduced its precept for two years in succession, Cardigan increased its precept last year. Councillor Fletcher acknowledged the efforts that Cardigan Town has made to improve the Town and access vital funding, but she emphasised that very large majority of the entire population of St Dogmaels wish to be re-unified within Pembrokeshire. She considered that that both Cardigan Town and Ceredigion County Council should respect these wishes.

5.16Plaid Cymru Ceredigion Regional Committee stated that there as there was no unanimous view over this boundary, and that a reduction in Ceredigion’s rateable value would mean a reduction in the services provided by the town of Cardigan for the public either side of the river in Cardigan; they felt strongly that the present boundary should not be changed and that St Dogmaels should remain within Ceredigion.

5.17 Rhys Sinnett, (Prospective Parliamentary Candidate, Plaid Cymru Preseli-Pembrokeshire) having spoken to the St Dogmaels Community Council and taken soundings from local persons, found that there was a clear and overwhelming feeling in favour of the unification of the whole of the village of St. Dogmaels. He considers that the present arrangements cause considerable confusion and not inconsiderable disquiet amongst a significant proportion of village residents. He found that the feeling was overwhelmingly in favour of the village being unified within Pembrokeshire for historical, administrative and social reasons. Mr Sinnett asked that full weight be given to these views and he stated that it is his belief that residents clearly appear to identify with the county of Pembrokeshire.

5.18 Ordnance Survey reported that a small team of Boundary Specialists visited the area of St Dogmaels to consider the boundaries proposed in the Commission’s Draft Proposals report. They suggested several minor amendments to the proposed boundaries in order to avoid the boundary following poor ground features.

5.19 The following comments have been received from local associations in the St Dogmaels/ Cardigan Town area:

The Parochial Church Council of St Thomas stated that the village church and the vicarage are in Pembrokeshire and the church hall is in Ceredigion, and it considered that being administered by two local authorities was a waste of money. They considered that the village should be united in Pembrokeshire. The views of the Parochial Church Council was supported in a separate representation by the Vicar of St. Thomas who whilst noting the views of the church, also reports of the inequality of local authority services within his parish, which covers the whole of St Dogmaels. He considered that the village should be in Pembrokeshire because historically the village has always been in Pembrokeshire and the majority of the village are currently in Pembrokeshire. The village was only originally split so that Cardigan could gain politically. In the vicar’s opinion the village would receive better services from Pembrokeshire, and Pembrokeshire offer a better advantage with tourism.
Cymdeithas Cadw’r Sân is an autonomous local heritage fishing organisation, who although autonomous maintain strong links with St. Dogmaels Community and Pembrokeshire County Councils. The committee wished to register support for the draft recommendation that St. Dogmaels be re-unified under the authority of Pembrokeshire County Council.
Poppit Sands Surf Life Saving Club, are funded by Pembrokeshire County Council who also own the clubhouse. They stated that it was important that the beach at Poppit should remain within the Pembrokeshire Coast National Park. The Club receives financial support from both Cardigan Town and St Dogmaels Community Council and has members from both Ceredigion and Pembrokeshire and has experience difficulty with this cross-border co-operation. They stated that the present county boundary is untidy and that the unification of St. Dogmaels as one community would be a sensible decision. They considered that a consensus of the residents of St Dogmaels would be a fair way of deciding which county they wish to be administered by.
The Station Branch Management Committee of the Cardigan Lifeboat Station Branch of the RNLI have written to lodge their unanimous support of the draft proposal for the reunification of St. Dogmaels within Pembrokeshire.
The proposal to unite St. Dogmaels within Pembrokeshire has also been received from the Glanteifion Gardening Society, the St Dogmaels Short Mat Bowling Club, the Abbey Shakespeare Players, Clwb Pel Droed Ieuenctid Llandudoch, the St Dogmaels Luncheon Club and the St Dogmaels Eisteddfod Committee.
Llwybrau Llandudoch (St Dogmaels Footpaths), a local voluntary group that maintains footpaths in both Ceredigion and Pembrokeshire, wrote in support of St. Dogmaels Community Council in their efforts to unite the village under Pembrokeshire. The group report that they receive support and materials from Menter Preseli, a sub committee of Pembrokeshire County Council, which enable them to maintain paths in both counties. From their experience, gained in the five years of their existence, they believe that Pembrokeshire are more enthusiastic about the footpath network, which is why they support the proposals.
Mr Beynon-Lewis wrote as a member of the executive committee of Menter Aberteifi; Chairman of the Cardigan Chamber of Trade, Commerce and Tourism; Vice Chairman of the Ceredigion Chamber of Commerce; and a member of the Ceredigion Objective One Partnership Management Board. Mr Beynon-Lewis considered that the proposed changes were being made for emotional and political reasons rather than the economy of the area and the level of services that can be provided by Cardigan to residents in both counties for 15 miles around. He stated that there would be a very real threat to the services and economic viability of Cardigan Town. The considerable effort and public resources invested in Cardigan to try to reverse the catastrophic economic decline of the last decade would be undermined. He stated that the views of the St Dogmaels residents are misguided in their belief that they would fare better under Pembrokeshire. As an owner of properties on both sides of the border, he considered this to be a fantasy. He stated that it is the Commission’s duty to take into account the opinion of all those who could be affected by the change, not just those of who believe they might benefit from such changes. He therefore expects that an official referendum be undertaken of the residents of both St Dogmaels and Cardigan communities. He urged the Commission to reconsider the proposals and maintain the status quo in the best interests of all concerned.

5.20 We received 572 representations from residents of the village of St. Dogmaels, 476 from the Pembrokeshire part and 96 from the Ceredigion part. All of the residents supported the Commission’s proposal to unify the village and all of them supported the proposal that the unified village should be in Pembrokeshire. Most of the 572 representations from the residents of St Dogmaels, both in Pembrokeshire and Ceredigion, were made by pro forma slip stating support for the draft proposals. Of those some 50 letters, which were not, pro forma letters raised the following points in support of the Draft Proposals:

A number of Ceredigion residents of St Dogmaels expressed the opinion that road maintenance, hedge cutting and rubbish collection should be conducted by Pembrokeshire as currently they often are “left out”. Some of the representations considered that there would be more efficient and cost effective services in the area if Pembrokeshire County Council provided them.
Concern was also raised over the ability of Ceredigion County Council accurately to identify which St Dogmaels residents were located in their county in respect of provision of services.
A resident stated that they find ridiculous the fact that one part of their property is in Ceredigion and another part in Pembrokeshire.
A resident stated that he sympathised with the Cardigan view that St Dogmaels’ residents should contribute to the services provided to them by Cardigan Town (and Ceredigion). He pointed out, however, that they must provide services to a large area including not only Ceredigion and Pembrokeshire, but Carmarthenshire as well, and as such did not see the transfer of such a small area to Pembrokeshire having that much effect on Ceredigion.
Another resident stated that they believed Ceredigion County Council to be inefficient, citing the expenditure in narrowing the streets of Cardigan Town where the money, in her opinion, would have been better spent on a multi-storey car park to alleviate traffic in the town.
Many residents commented on the fact that the Pembrokeshire Coastal National Park footpath starts/ends in St Dogmaels, and should retain its identity. Other concerns were raised regarding Poppit and Poppit Sands and the effect of their loss to Ceredigion would have on the local economy.
Others acknowledged fully that the Bridgend ward is an integral part of Cardigan Town and should remain so.
A number of residents pointed out that St Dogmaels was a village in its own right and not a satellite of Cardigan.
A resident noted that Cardigan Meals on Wheels were under such financial pressure in recent years that they could not take on any more clients. Following this, St Dogmaels had set up their own Meals on Wheels service, funded by Pembrokeshire, and supply not only Pembrokeshire residents, but 6 Ceredigion residents as well.
Some residents raised the difference in Council Tax levels, and the differences in levels and quality of services received.
Other residents pointed out that, although are in Pembrokeshire, they do pay for the services they use in Cardigan, for example, £15 per month to be a member of the Cardigan Leisure Centre. A number of St. Dogmaels residents raise funds for local causes, one cited a neighbour who held a coffee morning in her garden and raised a £1,000 towards the Lifeboat Station.
One resident raised the point that there was a rivalry between Cardigan Town and St Dogmaels in sports and social events.
A local businessman commented that because he is in Ceredigion and not Pembrokeshire he is paying, in his opinion, the highest business taxes in Wales, and whilst supporting the Commission’s Draft Proposals, called for larger County Councils to be formed to cut overheads and costs.
Some residents complained about the Cardigan Town questionnaire, which they believe was unrepresentative and misleading, and without the requirement for a signature or address they believe the questionnaire to have lost credibility and integrity.
Other residents took exception to news articles appearing in the Cardigan press attacking St Dogmaels and the Draft Proposals and they resent the terminology used to describe residents of the Community.
Some residents believed Pembrokeshire to be more sympathetic to natural surroundings and Welsh tradition in their planning policies than Ceredigion. One resident feared that if the development and preservation of Poppit Sands at St Dogmaels were left to Ceredigion County Council that it would be turned into a mini-Blackpool.
A large number of residents of both sides of the village questioned Ceredigion’s willingness and ability to monitor the landslip, or that they would have had the monies to rectify the problem when it originally occurred. Those who raised the issue of the landslip all stated that because of the support and confidence given to them by Pembrokeshire County Council, given all other considerations, they believe that the community should be unified under Pembrokeshire. Some feel that if not for Pembrokeshire County Council, then they would have had to evacuate their homes.
A local farmer made representations against the proposals of Cardigan Town, which would “move” 2.17 hectares (1.3%) of his land into Ceredigion so that he would no longer be qualified to claim grants for that portion of land, as it would no longer be in an Environmentally Sensitive Area. The farmer also wanted to state that the 2.17 hectares is in a field of only 4.5 hectares. The farm concerned is also registered in Pembrokeshire to provide foodstuffs, so to continue using the 2.17 hectares for that purpose under Cardigans proposals would involve a considerable duplication of cost to the authorities and the farm.
Residents also reported that the reason behind the area of St Dogmaels being transferred to Cardigan (shire) in the first place was so that the area had a large enough population to warrant a Member of Parliament in the 19^th Century. They considered that this argument is no longer valid.
Another resident commented that if Ceredigion County Council spent more money on services and less money on the Welsh Language then the confidence of residents would improve.
Other residents reported that since the publication of the Commission’s Draft Report, for the first time that they can recall Cardigan Town Councillors have been visiting the village and calling at people’s front doors.

5.21 A letter was received on behalf of residents representing 14 of the 17 dwellings in Area D on the map at Appendix 7 of the Draft Proposals report. This area has been proposed for transfer to Pembrokeshire by Pembrokeshire County Council. Of the three remaining dwellings, the resident of one had no specific views on the matter and the remaining 2 are unoccupied. The residents wrote in support of the proposal, arguing that:

Area D is a rural sparsely populated area, which would incorporate naturally into Cilgerran Community, which is also predominantly rural.
If Area A becomes part if Pembrokeshire, then the residents believe that this strengthens their case, as unless they were also transferred, then they would be in the only area of south of Cardigan still in Ceredigion.
Many of the residents feel an affinity with Cilgerran Village and especially Penybryn, which is less than half a mile away from most of their properties.
All residents are adamant that the level of service enjoyed by their Pembrokeshire neighbours is of better quality and more efficient. Pembrokeshire seem to achieve better value for taxpayers’ money.
Most of the children residing in Area D attend Cilgerran Primary School.
Many of the Ceredigion services, such as Social Services are based in Aberystwyth 40 miles to the north, where as Pembrokeshire Headquarters 25 miles away in Haverfordwest.
All public transport currently enjoyed is provided by Pembrokeshire Council. Any senior citizen residing within Area D is unable to use a Ceredigion Pass on the buses that service our dwellings at least 5 times a day (one direction).
The A478 (Ceredigion part) that services Area D is in winter salted by Pembrokeshire gritters based at Crymych 4 miles to the south. The nearest highways depot for Ceredigion is in Llandysul, which is 14 miles to the northeast.
One resident in Area D at Nantperchellan, reported that their farm was 10 metres on the Ceredigion side of the Afon Piliau. The farm lane that services the farm is 95% in Pembrokeshire, and they have their rubbish collected by Pembrokeshire. A Pembrokeshire school bus passes the end of the access lane and generations of children from Nantperchellan had attended school in Cilgerran, Pembrokeshire. They also noted that though their immediate neighbours only have travel 2 miles to vote, they must travel 4 miles to Cardigan Town, despite never receiving any Cardigan or Ceredigion electoral material.
Residents of Glanpwllafon, a similarly placed property to Nantperchellan, highlight the problems regarding a disused road bridge, which, due to a right of way, is maintained by both Highways Authorities. They believe it more sensible for Pembrokeshire authority with its Highway Service based at nearby Crymych to maintain the bridge. They also note that on the disused bridge is a Parish Boundary Stone, which states Parish of Bridell Pembrokeshire/Parish of St Dogmaels Pembrokeshire. They consider that history should be allowed to repeat itself for the benefit of local residents.
Another Area D resident expresses her concern that Ceredigion Social Services are too removed from the residents of Ceredigion South, and Area D would, in her opinion, be far better served by Pembrokeshire Social Services.

6. THE EFFECT OF ANY PROPOSALS ON THE COUNTY OF CEREDIGION

6.1 In their representation Ceredigion County Council made the statement:

“If St Dogmaels is transferred to Pembrokeshire, there will be a significant, and disproportionate switch of resources in favour of Pembrokeshire at the expense of the Council Tax payers of Ceredigion. The main services in Cardigan will continue to be provided and funded by Ceredigion and it cannot be equitable to expect the Council Taxpayers of Ceredigion to meet the additional tax burden.”.

In their representation, Cardigan Town Council also made reference to this issue :

“The rates in the rump of Cardigan and across Ceredigion would have to rise by some £10 compensate for this loss”. [of St. Dogmaels].

6.2 We considered that this was an important issue and accordingly we asked Ceredigion County Council to provide their calculation of the effect of the Commission’s Draft Proposals on Ceredigion’s Council Tax and budget and to include details of how the figures are calculated. We also asked for similar information in respect of Cardigan Town’s precept and budget.

6.3 In response to our request Ceredigion County Council provided a report detailing the effect of our Draft Proposals on Ceredigion County’s council tax and budget and estimate of the effect on Cardigan Town’s precept and council tax. A copy of the report can be found at Appendix 5. Copies of the report were sent to Pembrokeshire County Council, Cardigan Town Council and St. Dogmaels Community Council. On 11 June 2001, officers of the Commission met with representatives of Ceredigion County Council where the Council expanded and clarified the comments made in their report.

6.4 Pembrokeshire County Council wrote making observations in response to Ceredigion County Council’s report. A copy of this response can be found at Appendix 6. The following is a summary of the response:

Pembrokeshire County Council consider that the council tax base issue taken on its own would not have any significant impact on either Council, and certainly not to the effect of £6.32 (Band D) suggested in Ceredigion’s report.
The Council also consider that it is misleading to suggest that any boundary change would, by virtue of changes in the Local Government Revenue Settlement, cause any increase whatsoever in council tax levels.
The Council question the assumptions made by Ceredigion County Council in respect of the estimated reductions in expenditure.

6.5 St. Dogmaels Community Council also wrote in response to Ceredigion County Council’s report. The Community Council wished to take issue with the number of council tax paying households (261) stated in the report. The Community Council believe there are 199 council tax paying households. The Community Council also noted that Ceredigion mention that the population involved is 400 whereas they had previously agreed with the Community Council’s figure of 307. The Community Council stated that the council tax finance issue is irrelevant and should not have any bearing on the proposed boundary changes in St. Dogmaels. They maintained that “efficient and convenient local government” is not dependent on how one county balances its books.

6.6 A resident of St. Dogmaels having read Ceredigion’s report and Pembrokeshire’s response noted the difference in their Council Tax estimates. He stated that this aspect should not influence the decision. He considered that the total wealth of the area would remain unchanged. He added that if, in the course of time, one county can demonstrate that it has been financially disadvantaged by the minor population shift, surely some means of redress can be negotiated? He stated that, given the number of respondents in favour of unification under Pembrokeshire, the prime factor should be the will of the people.

6.7 We considered that in order to form an informed and independent view of this important issue, the services of an expert in local government finances should be employed by the Commission to conduct an investigation. A report was commissioned from Rita Hale & Associates Ltd. A summary of the report can be found at Appendix 7. We provided a copy of the report to Ceredigion County Council, Pembrokeshire County Council, Cardigan Town Council and St. Dogmaels Community Council.

6.8 Following the receipt of comments on the report prepared for the Commission by Rita Hale & Associates Ltd. it was discovered that the figures contained in the report were distorted by the double-counting of the reduction in the local taxbase. This resulted in:

an overestimate of the Ceredigion County Council’s likely income from Revenue Support Grant; and
an underestimate of the amount Ceredigion County Council would need to raise from Council Taxpayers – and thus the level of the Council Tax.

6.9 The figures were reworked using;

the actual data for 2000-01;
the adjusted expenditure and SSA figures coupled with Ceredigion County Council’s original estimate of the likely effect of the proposed boundary change on the Council Taxbase – ie a reduction of 251 Band D equivalent properties – Calculation 1; and
the adjusted expenditure and SSA figures coupled with Ceredigion County Council’s revised estimate of the likely effect of the proposed boundary change on the Council Taxbase – ie a reduction in the Council Taxbase for grant distribution purposes of 169 Band D equivalents; and a reduction in the Council Taxbase for tax setting purposes of 162 Band D equivalents – Calculation 2.

6.10 The revised figures, set out in the tables at Appendix 8, show:

increases in Council Tax for Ceredigion of £6.82 Band D (Calculation 1) and 6.36 Band D (Calculation 2);
cuts in Council Tax for Pembrokeshire of £3.17 Band D (Calculation 1) and 3.23 Band D (Calculation 2).

6.11 Ceredigion County Council were themselves unable to confirm the potential savings if the proposed boundary change were to proceed. They estimated these savings to be between £25,000 and £40,000 and have used £30,000 for calculation purposes (Paragraph 1.4 Appendix 5). For the reasons given in the Rita Hale Report (summarised in Appendix 7 at paragraph 10) we consider that it is likely that a detailed examination of the potential reduction in expenditure by Ceredigion County Council may lead to the identification of further savings in expenditure so that the actual increase in Council Tax would be less than the figure estimated. As we do not expect the savings in expenditure to match the estimated reduction in the County Council’s SSA however, we conclude that the likely effect of the boundary change would be a small increase (about £6) in Ceredigion’s Council Tax. This represents an increase of approximately 1% to the existing Council Tax.

7. ASSESSMENT

7.1 It is evident from the representations we have received from all parties that there is an overwhelming majority in favour of uniting the village of St. Dogmaels under one unitary authority. It is also evident both from the representations we have received and the information that has been provided that it is perceived that unification would also be of benefit in terms of effective and convenient local government, if such a change were to be proposed, in terms of the level of services provided to St. Dogmaels. This perception is particularly strong in the population of St. Dogmaels itself.

7.2 The representations in favour of the Community St. Dogmaels being administered by Ceredigion County Council suggest a change to the boundary that would split the main part of the village from the more rural areas of the existing Community of St. Dogmaels that lie to the West and North West of the village. From the representations received, it would appear that the residents of these rural areas consider themselves an integral part of the St. Dogmaels Community. It would appear therefore that although this proposal would meet the aim to unify the village of St Dogmaels, it would also break local ties with the outlying areas.

7.3 From the representations received from residents of the existing Community of St Dogmaels and of the areas of Ceredigion marked Area A and Area B on the map at Appendix 9, it is clear there is widespread support for the proposal for the new community to be in Pembrokeshire. The reasons given for this are manifold and not just because of Council Tax differences as has been suggested (see the representations of Ceredigion County Council at paragraph 5.2 (iii) above). It is significant that a number of representations consider the services provided by Pembrokeshire to be superior to those provided by Ceredigion.

7.4 Cardigan Town Council consider that the views of all Cardigan residents should be sought and attempted to seek these views by means of a questionnaire. Having received only 121 responses from 2,300 questionnaires, they conclude that from such a small number it is not possible to draw firm conclusions. The poor level of response would at least suggest that the majority of the residents of Cardigan do not feel strongly on the matter either way.

7.5 A number of the representations that support the combined village of St. Dogmaels becoming part of Ceredigion refer to the use of the facilities and services in Cardigan by residents of St. Dogmaels. The argument is that as the residents use the facilities provided by Ceredigion and Cardigan Town they should contribute financially to the cost of these services. This argument is countered by representations that point out that Cardigan Town exercises its influence over a large area, including other Pembrokeshire villages. It does not follow, it is said, that because residents of an area use the facilities and services of a local town they should necessarily become part of the town or have to contribute in some way to the town’s precept. The representations also point out that the residents of St. Dogmaels pay the standard charges for using many of the Cardigan facilities such as car parking, leisure centre etc. and that both Pembrokeshire County Council and St. Dogmaels Community Council have assisted with the funding of services either as part of a formal agreement or when requested.

7.6 Ceredigion and Cardigan both question the legal basis of the Commission’s Draft Proposals in that they maintain the Commission has attached greater weight to public opinion than to the consideration of effective and convenient local government. The Commission however have always considered that there is a strong relationship between local identity and effective local government, to which effect should if possible be given. If people feel remote from, or in other ways do not identify with, their local authority then effectiveness could be adversely affected. However, although the Commission have always considered this to be a relevant factor, it is by no means the only, or necessarily decisive, factor, which the Commission has taken into account.

7.7 We have already stated that there are sound reasons to suppose that the interests of effective and convenient local government would be served by unifying the village of St. Dogmaels under one unitary authority. In our Draft Proposals Report we concluded that that authority should be Pembrokeshire: there was strong local support for that course, based upon historical and social factors as well as the perceived quality of the services provided by the respective authorities and the level of local tax. On the other hand despite careful examination of the evidence we were aware of no sufficient countervailing considerations based upon the interests of the adjacent areas – in particular Cardigan Town and Ceredigion County Council. The publication of our draft proposals has again produced representations very similar to those which informed our Draft Proposals Report, including those from Cardigan and Ceredigion expressing strong opposition to the proposed change. That opposition is based upon two principal considerations: first, that the residents of St Dogmaels should not be entitled to use the facilities of Cardigan without contributing to its precept. “Take-up” of an authority’s facilities is obviously a relevant factor, but if applied rigidly we do not find that proposition persuasive either in principle or in practice. Some arguments are to be found in paragraphs 7.5, where we cite the representations which we have received. The fact is that the town of Cardigan is a relatively well developed urban centre which is bound to exert an attraction to those people living in reasonable proximity to it. This must apply to any such centre, but in our view this cannot lead to the conclusion that all persons living in proximity to Cardigan, or visiting Cardigan (and, incidentally, contributing to its economy), should also contribute to its precept.

7.8 Secondly, it is argued that the loss of St. Dogmaels would have serious financial consequences for Ceredigion. We have already noted that the great majority of the residents of St. Dogmaels are already within Pembrokeshire and the areas to be transferred are predominantly rural. As reported at 6.11 the consequences of the loss of a relatively small number of Council taxpayers would appear to have an effect on the finances of Ceredigion County Council which is to an extent out of proportion to the number of people to be transferred. The figures indicate that, without a reduction in the estimated expenditure, an increase in the Council Tax will be required. In considering the interests of effective and convenient local government in relation to the question in which authority the reunited St. Dogmaels should be located, logically the first consideration should be the interests of St. Dogmaels itself. In our view the interest of St. Dogmaels point very firmly in the direction of Pembrokeshire. We readily accept however that the interests of other, adjacent, areas – the rest of Pembrokeshire, Cardigan Town and Ceredigion – are also relevant. (To that extent we do not agree with the representations contained in paragraph 6.5 above). We take into account that in terms of local government finances, a change to the principal authority boundary will inevitably result in degrees of gains and losses in income and expenditure affecting the two areas. We consider that in order to outweigh the positive benefit on the residents of St. Dogmaels, the negative impact on Ceredigion in terms of pure finance would have to be very significant, although not critical. Despite the efforts of all parties to ascertain it, what the effect would be must unfortunately remain imprecise, but it is clear that what is proposed is the transfer from Ceredigion to Pembrokeshire of between 300 and 400 people, representing about 0.5% of Ceredigion’s population. Such a transfer is likely to lead to an increase in the Council Tax of about £6, representing an increase of approximately 1% to the existing level of tax. Proceeding as we do on the premise that the unification of St. Dogmaels within one authority is generally in the interests of effective and convenient local government, and taking account of the effects of those interests within St. Dogmaels, we do not think that the likely financial impact on Ceredigion, either on its own or with the other negative factors, is anything like sufficient to outweigh those interests. In all the circumstances, the Commission confirms the conclusion contained in the Draft Proposals Report, that the village of St. Dogmaels should be united by transferring the two areas of land, shown at Appendix 9, from Ceredigion to Pembrokeshire.

7.9 In considering the consequential changes to the electoral arrangements, Cardigan Town Council do not consider the arrangement whereby the Teifi electoral division would see a decrease to 890 electors to be appropriate. In the Draft Proposals report, The Commission considered that the Teifi division would have one of the highest levels of representation in the county and would have a councillor to number of electors ratio well below the ratio of 1:1,750 specified in the Secretary of State’s directions to the Commission. The ratio would however still be within 50% of the county average of 1 councillor to 1,327 electors (1998 electoral register) and there is an electoral division within Ceredigion (New Quay) with fewer electors. [As the Assembly has not yet implemented the Commission’s December 1999 electoral proposals, Cardigan Town is currently represented by a multi-member division of 3,452 electors represented by 3 councillors.]

7.10 Cardigan Town Council also pointed out the discrepancy between the ratio of electors to community councillors in Cardigan Town and St. Dogmaels under the Commission’s proposals (243 to 1 in Cardigan Town and 90 to 1 in St. Dogmaels). It should be noted that there is wide variation in the ratio of community councillors to electors throughout Wales. This was recognised by the Commission when undertaking the Special Community Reviews in the 1970s. In 1976, the Commission issued guidelines for the representation on community councils and it should be noted that the level of representation proposed for St. Dogmaels is consistent with these guidelines. It should also be noted that the increase proposed in the level of representation for St. Dogmaels Community Council and the decrease in the level of representation for the Teifi ward are proportionate with the existing ratios for each community.

7.11 In our Draft Proposals report we noted that the suggestion by Pembrokeshire County Council to include additional areas within Pembrokeshire widened the scope of the review. We considered that it was inappropriate for the Commission to make proposals for those areas at that stage as we felt we had insufficient evidence on which to make a decision. We invited interested parties to comment on Pembrokeshire’s suggestion that additional areas to the south east of St. Dogmaels be transferred from Ceredigion to the Communities of Cilgerran and St. Dogmaels in Pembrokeshire. We have considered the representations we have received concerning this suggestion and it is evident that there may be grounds for the Commission to carry out a full review of these areas. We are of the view however that this suggestion relates to areas that are outside the scope of this review. This matter would therefore need to be addressed as a separate review. Should interested parties wish to pursue this matter we would ask that they make a formal request to the Commission to undertake a review of this specific area.

8. PROPOSALS

8.1 We have undertaken the review in accordance with the directions issued by the National Assembly for Wales and propose that the boundary between the Counties of Ceredigion and Pembrokeshire in the area of the Community of St. Dogmaels should be realigned as shown in green on the map at Appendix 9 to include the areas marked Area A and Area B within the County of Pembrokeshire.

8.2 A detailed map to a larger scale showing the proposed new boundary can be inspected at the offices of the County Councils of Ceredigion and Pembrokeshire and at the office of the Commission in Cardiff.

9. CONSEQUENTIAL ARRANGEMENTS

9.1 Under Section 54 (1) (e) of the Act, the Commission may make proposals for change of electoral arrangements for any local government area, which is consequential on any proposed change in local government areas. A detailed analysis of the proposed changes to the electoral arrangements for the principal areas of Ceredigion and Pembrokeshire and the communities of Cardigan and St. Dogmaels is given below.

9.2 The existing Community of St. Dogmaels has 774 electors (1997 electoral register) and is included with the Community of Nevern in the St. Dogmaels electoral division, which has 1,464 electors, represented by 1 councillor (1997 electoral register). The Ceredigion part of the village of St. Dogmaels is in the Teifi ward of the Community of Cardigan which has 1,198 electors (1998 electoral register) and is part of the Cardigan electoral division which has 3,452 electors represented by 3 councillors (1998 electoral register). In our December 1999 proposals to the National Assembly for Wales for the electoral arrangements for the County of Ceredigion we proposed that the Teifi ward of the Community of Ceredigion forms the Teifi electoral division with 1,198 electors (1998 electoral register) represented by 1 councillor. We are still awaiting a decision from the National Assembly for Wales on these proposals.

9.3 According to the information that has been submitted, there are approximately 300 electors within the area that we propose to transfer from Ceredigion to Pembrokeshire. This would increase the number of electors in the St. Dogmaels electoral division to approximately 1,770 electors. This would result in a level of representation of 1 councillor to 1,770 electors. This level of representation is close to the ratio of 1 councillor to 1,750 electors specified in the Secretary of State’s directions to the Commission for the recent programme of electoral reviews. It is also within the range of plus or minus 50% of the Pembrokeshire county average. We therefore consider this to be an appropriate level of representation.

9.4 Under the existing arrangements for the County of Ceredigion, the proposed boundary change would result in a decrease in the number of electors in the Cardigan electoral division from 3,452 (1998 electoral register) to approximately 3,150. Under the proposals that have been submitted to the National Assembly for Wales, the Teifi electoral division would see a decrease in the number of electors from 1,198 (1998 electoral register) to approximately 890. The Teifi division would have one of the highest levels of representation in the county and would have a councillor to number of electors ratio well below the ratio of 1:1,750 specified in the Secretary of State’s directions to the Commission. The ratio would however still be within 50% of the county average of 1 councillor to 1,327 electors (1998 electoral register). We therefore consider that the arrangement whereby 1 councillor represents the Teifi electoral division should continue.

9.5 St. Dogmaels Community Council has 10 community councillors representing 774 electors. The new Community of St. Dogmaels will have approximately 1,080 electors. We propose that the number of councillors on the St. Dogmaels Community Council be increased from 10 to 12 as we consider this to be an appropriate level of representation.

9.6 The Teifi Ward of Cardigan Town Council is represented by 5 councillors representing 1,198 electors. Under our proposals the number of electors in the Teifi Ward will reduce to approximately 890. We propose therefore that the number of councillors representing the Teifi Ward be decreased from 5 to 4, as this would maintain the level of representation in proportion with the Mwldan and Rhyd y Fuwch Wards of Cardigan Town Council.

9.7 We acknowledge that the existing boundary between the Counties of Ceredigion and Pembrokeshire is also the boundary between the Parliamentary Constituencies of Ceredigion and Preseli Pembrokeshire. It is however outside our remit to recommend changes to Parliamentary Constituency boundaries. These boundaries are changed by Statutory Instrument following a review by the (Parliamentary) Boundary Commission for Wales.

10. ACKNOWLEDGEMENTS

10.1 We wish to express our gratitude to the principal councils, to the community councils and to individuals for their assistance during the course of the review and to all bodies and persons who made representations to us.

11. RESPONSES TO THIS REPORT

11.1 Having completed our review of part of the boundary between the Counties of Ceredigion and Pembrokeshire in the area of the Community of St. Dogmaels and submitted our recommendations to the National Assembly for Wales, we have fulfilled our statutory obligation under the directions issued by the National Assembly for Wales.

11.2 It now falls to the National Assembly for Wales, if it thinks fit, to implement them with or without modifications by means of an Order or to direct the Commission to conduct a further review. Such an Order will not be made earlier than a period of six weeks from the date that the Commission’s recommendations are submitted to the National Assembly for Wales.

11.3 Any further representations concerning the matters in the report should be addressed to the National Assembly for Wales. They should be made as soon as possible, and in any event not later than six weeks from the date that the Commission’s recommendations are submitted to the National Assembly for Wales. Representations should be addressed to:

Local Government Modernisation 2 Division

National Assembly for Wales

Cathays Park

Cardiff

CF10 3NQ

PROFESSOR E SUNDERLAND OBE LL MA PhD LLD FIBiol (Chairman)

E F L FITZHUGH OBE DL (Deputy Chairman)

MRS S G SMITH LLB (Member)

E H LEWIS BSc. DPM FRSA FCIPD (Secretary)

December 2001