The annual report is now available at the DCC website and below.
It is provided by sections in .PDF format.
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Standard & Poor’s
Standard & Poor’s Financial Services LLC, provides independent financial information, analytical services, and credit ratings to the world’s financial markets. For more information go to Standard & Poor’s.
● S&P Full Analysis Dunedin City Council (PDF, 321 KB)
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Annual Report Documents
Annual Report 2012/13 Full version (PDF, 1.2 MB)
Organisational and Financial Management Report, Significant Activities Report and Council NZIFRS Financial Statements
Annual Report 2012/13 Section 1 (PDF, 399.4 KB)
Organisational and Financial Management Report
Annual Report 2012/13 Section 2 (PDF, 448.8 KB)
Significant Activities Report
Annual Report 2012/13 Section 3 (PDF, 361.1 KB)
Council NZIFRS & Financial Statements
Annual Report 2012/13 Appendix (PDF, 172.6 KB)
Community Outcome Monitoring, Supplementary Information
Annual Report 2012/13 Summary (PDF, 531.8 KB)
Dunedin City Council Annual Report Summary
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OPEN MEETING ABOUT DCC FINANCES
When: Wednesday 27 November 5:30pm-7:00pm
Where: Meeting Room One, Municipal Chambers
ALL WELCOME – hosted by DCC Finance Committee
Related Posts:
23.11.13 DCC: Finance Committee [public forum] 27 November
17.11.13 DCC Finance Committee: Public meeting 27 November [INVITE]
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Posted by Elizabeth Kerr
What if? Dunedin... 
Standard & Poor’s say:
(page 4) Outlook
The negative outlook reflects our view that there is a one-in-three chance of a downgrade in the coming two years. This is based on our opinion that Dunedin may not achieve the financial targets outlined in its Long-Term Plan, with its after-capital account deficits not improving as quickly as forecast. If this scenario were to materialize, we consider that Dunedin would have limited budgetary flexibility to improve its financial position without deferring asset renewals, which may lead to future infrastructure backlogs.
Further downward pressure could be placed on the ratings depending on the Auditor General’s investigation into the management of Dunedin’s CCTO–Delta Utility Services–which may weaken our assessment of Dunedin’s management of CCTOs; or if there were a change in policy direction, such as the introduction of a hard rates cap, or a revised capital-expenditure program without an offsetting increase in revenue, which would result in Dunedin’s after-capital account deficits not improving as forecast.
The ratings could be revised to stable if the council’s budgetary performance strengthens as it forecasts, specifically if the council achieves after-capital account deficits of about 2% of consolidated operating revenues in 2014 and beyond, while maintaining its current budgetary flexibility and a stable political setting.
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(pages 3 & 15) Ratings Detail (As Of November 28, 2012)
Dunedin City Council — Issuer Credit Rating AA/Negative/A-1
(page 3) Major Rating Factors
Strengths:
• Predictable and supportive institutional framework
• Very positive financial management, reflecting NZ’s strong institutional settings
• Modest contingent liabilities
Weaknesses:
• High debt burden relative to international peers
• Low debt-servicing ratio
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The detail of the S&P report isn’t rocket science, we already know the weaknesses. An interesting read, all the same.
The fun lies inside and outside the council’s Annual Report (some of it rigorously reported and, of course, some not). A few good souls will be cranking through as much as they can of the report before Wednesday evening’s ‘Open Meeting’ about DCC Finances.
I have now had a chance to look at the annual report. As many may know I have an interest in how the Council borrows its money and especially in its recent use of derivative debt instruments (primarily interest rate swaps) instead of bonds. The following comments may be useful.
1) The general layout of this document represents a considerable improvement on its predecessor. The late CEO’s influence is apparent.
2) Last year’s document included details of outstanding bonds and their maturities. I have looked hard, but cannot find a similar summary in this year’s version, although it may be in there somewhere.
3) However on page 152 in the table ‘TERM LOANS’ the nature of the DCC’s debt (may?) be laid out. In 2013 98% of all the consolidated (DCHL+DCC) debt was in the form of something called a ‘secured multi-option note facility’. I have no idea what a ‘secured multi-option note facility’ is, and I’ve been around a bit. Astonishingly Google didn’t know either. A similar trawl through the global academic accounting literature using the exact term ‘multi option note’ also pulled up nothing. I can therefore only presume that the term ‘secured multi-option note facility’ is a financial term that is both novel and unique to this document. As only 2% of the DCC’s $610 million declared term debt is not in a ‘secured multi-option note facility’, it may be reasonable to assume that the DCC has retired any bonds that it may have had outstanding. Oddly, the core DCC commitments and consolidated commitments on this table do not appear to reconcile. There appears to be an extra $200 million flying around above the bottom line.
4) I suspect, but I do not know for sure, that a ‘multi option note’ may be a local avatar of a derivative debt instrument. If it is, then the addition of the term ‘secured’ may have ominous implications.
5) In 2010/11 and 2011/12, the DCC racked up some pretty hefty losses (c. $35 million) on what were described separately and bluntly as ‘interest and currency rate swaps’. My questioning of these figures and their implications on National Radio last year led to some uncomfortable moments for the DCC hierarchy.
6) This year, the figures for gains and losses on derivatives are incorporated into tables on pages 124, 146 and 170. They also appear separately in a table titled ‘cash flow hedge reserves’ (a large negative number – which makes it an odd sort of reserve) on page 146. The general rules by which they are accounted for are given on page 135 (third column), but not the instrument details or specific valuation procedures used.
7) The figures appear to indicate that the DCC made a profit of c. $10 million on its derivatives portfolio last year.
So there we have it. I may be being uncharitable, but it would not be in the least surprised if the meeting tomorrow evening is not going to be used as a platform to trumpet this ‘profit’ and to pretty much say: “Move along now, move along, there’s nothing to see here. Ignore the shouting – the man’s mad!”
I remain unconvinced. The following observations are pertinent:
1) The reversal still leaves us massively ($24 million +) awash with regard to these instruments over the last three years.
2) A fluctuation of profit/loss from $20 million plus negative to $10 million plus positive ($30 million plus variation) in a single year in which nothing really happened vis-a-vis interest rates and currency exchange rates internationally indicates that the DCC’s exposure to these instruments is ENORMOUS.
3) This indicated enormous exposure to derivatives and the 98% share of these mysterious ‘secured multi-option note facilities’ is an uncomfortable coincidence.
4) If anything dramatic did happen internationally, this figure could blow out massively either to our advantage (very nice) or to our disadvantage (catastrophic as the DCC has absolutely nothing in reserve to meet unbudgeted extra liabilities).
5) The exact nature of any liabilities is not known, and may not even by known by the DCC if the instruments involved are manufactured retail products involving bundled swap transactions – most come out of London. These instruments can not only involve a swap of commitments to pay interest, but can also involve currency risk, and also the commitment to repay the principal amount, which turns it into a variety of credit-default swap. Could we be standing guarantor for the ‘Bad Bank of Ireland’? – Sure, it’s possible with these things.
6) Were this to happen, the population of this City may well gain an immediate and painful familiarity with the term ‘secured’ mentioned previously.
Thanks Rob, for crashing through the DCC quagmire to make these observations. Nope, the Finance meeting tomorrow won’t want to dwell on the questions – and there will be no-one at DCC there in an official capacity that has the knowledge, intellect and honesty to “clear things up”. S&P mention paper and not happily – but how deep would they ever go to purify the cesspool, not further than their big toes, if that… while they’re wined and dined by Athol’s stand-ins prior to release of their report.
I can therefore only presume that the term ‘secured multi-option note facility’ is a financial term that is both novel and unique to this document.
That’s assuming it is one term. Which it isn’t.
Invercargill City Holdings Limited has a “multi-option note facility” which is secured (against assets). You might also note the following in the ICHL document, “the issuance of promissory notes upon the multi-option…”
You can then try various combinations of promissory note, multi-option, multioption, and secured in your search.
‘What is a secured multi-option note facility?’ would be a great question to ask tonight – if all of the Finance committee members can’t easily explain in simple words they probably have no business dabbling in them
I did find this definition on line which is as baffling – “Credit lines that are accompanied by option contracts to provide more variety to borrowers in standard currencies. It is typically used for short-term advances and in the euro market. The credit for multi-option financing facilities is assured, and the line of credit is normally syndicated. Also called multiple component facility or multi-option facility.”
Read more: http://www.investorwords.com/16606/multi_option_financing_facility_MOFF.html#ixzz2lmZucG2E
Don’t know if this is pertinent or not.
Finding out why Athol Stephens was persuaded to say that he “wanted to explore other options” may be a key to finding out more about these financial instruments. One thing is for sure and that is that Richard Thomson’s answers on the subject will be interesting to observe.
“…typically used for short-term advances…” – is “short-term” applicable to what’s been done in our town?
I literally understand about one word in ten and I brain-fog when it comes to accounting even small-scale. So much of it comprises other names for smoke and mirrors, and re-naming a loan/debt/income when it’s shuffled into another account. So I can’t add anything except this – which may seem flippant but isn’t –
Paul Orders did more to disinfect the toxic sludge than we could ever have hoped for, esp in such a short time. At the risk of going a bit weird and hero-worshipful, I think pictures of him captioned “before a decision is made please think what would he advise?” should be on walls throughout the DCC and councillors’ territories for the next 3 years or until it’s been demonstrated that habitual practice has not slumped back to pre-Orders.
I wish he’d contribute now to What If discussions, but his own good manners as well as professional restrictions are sure to prevent that.
If only I believed in lie detector tests, I dream of who now at (greater) DCC I would apply them to – on so many levels, not forgetting DCTL. Meanwhile I’m finally getting to read the Annual Report before the theatre tonight.
Thank you Russell,
The definition you have found is for an instrument that involves futures contracts, currency risk (at least) and by ‘syndicated’ they mean bundled. While it clearly a hard-core and specialist speculative instrument and is not a beast that you would usually expect (or want) to find in local government ownership, its name could very well act as an obscure avatar for a commercially manufactured, bundled derivative debt instrument .
So basically they’re doing well essentially because of currency speculation – the loans must be in another currency, and, of course, the bottom line looks better if the nominal value of the entire debt in NZ$ goes down by 10% because the NZ$ is worth more, but next year, like last year, it could turn the other way – the downside is pretty scary of course – NZ$ diving back to US50c would likely bankrupt the city
If anyone claims this as a carefully planned bonus they’re full of it, because if they could predict the foreign exchange markets that well they wouldn’t be working for the DCC, they’d be investing their own money, rather than ours, and living high on the hog – more likely this $30m paper bonus is luck
In actuality, the bankruptcy of the city could well be a huge advantage to the ratepayers.
It would have the following effects:
1. All of the staff would not be paid
2. The councillors and mayor would not be paid.
All of the accumulated debts would be worn by the bankers who loaned monies to the Otago rugby union and the DCC on the back of the implied requirement of the ratepayers to fund any stupidity and extravagant spending by any council employees or councillors for whatever crazed and imprudent scheme.
The danger is that central government would still require ratepayers to fund the leftover debt and interest which would make your house unsaleable (due to the contingent liability of future rates) and mean a mass exodus from the city.
However, the carrot of minimising the number of staff at the DCC, the streamlining of the administration, and getting back to the core business of running the city’s utilities would be well worth it in the long term as the slow death that Dunedin is going through now, would be better to be quickly put down; and then a possible chance of recovery with a new slimline regime in place dedicated to assisting businesses rather than the current view of stifling any opportunity that does not involve the council itself.
So will we have an instant demise or a tortuous strangulation?
[John]: periodically the Council has passed resolutions that represent the “secured” part of these transactions essentially securing their loans against future rates.
(or is it they are secured against the roads and sewers?)
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{Name correction, ‘Mick’ was used. -Eds}
[Mike], the other side of the coin (so to speak) is, as I am sure Rob will concur, is that we don’t and can’t know in what denominations the various tranches of interest risk lies. Regardless of our rising exchange rate, it is only relative to all the others. It is on a daily basis a seething pot constantly changing. The banks of course only structure these IRS as Derivative contracts on the basis that it is “heads we win tails you lose”. As Rob says, it really is a game for the ‘big boys’ and the ‘wide boys’. Not a lot of them in our Town Hall I wouldn’t think.
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{Name correction, ‘Mick’ was used. -Eds}
The meeting tonight was an interesting one, and renders much of what was written in my last post about the mysterious ‘secured multi-option note facility’ obsolete.
We were informed today, with the support of a slide and without prompting, just exactly what a ‘secured multi option note facility’ is. It is a specific and individual arrangement between DCTL, the DCC and three ‘independent’ (no more is known) banks, apparently for the purposes of circumventing Section 62 of the Local Government Act. This section of the Act reads as follows:
62 – Prohibition on guarantees, etc
A local authority must not give any guarantee, indemnity, or security in respect of the performance of any obligation by a council-controlled trading organisation.
The language, intent and motivation of this section all seem pretty clear. So what has been done to get round it?
The ‘multi-option note facility’ is apparently an umbrella agreement that allows DCTL to borrow in a variety of ways up to a ‘credit limit’ of 850 million dollars (increased from $600 million in 2010).
The ‘secured’ bit seems to refer to the following arrangement: According to the presenters tonight, the DCC have apparently issued 850 million dollars of ‘uncalled capital’ as part of this arrangement. What this means is that if DCTL runs out of money, the amount of uncalled capital can be ‘called’ by the creditors to be used as shareholders equity to settle debts up to the specified amount of 850 million dollars. This amount is in addition to any other assets that might be used to settle debts. As it is uncalled capital, the DCC do not have to have this $850 million, they just have to be in a position to acquire it rapidly if they need to – Guess how?
It isn’t a guarantee on any specific obligation, but as an effective guarantee on the company that holds those obligations, its effect is pretty much the same. This arrangement has apparently been in place for some time, and I am personally astonished that the Office of the Auditor General has not commented upon it, or done something even more directly, as it is clearly subversive to the intent of what appears to be a very sensible component of the legislation that governs local government agencies.
With regard to other details, the accounts also say that interest rate swaps are only used on 30 day variable rate notes (if the sums are correct this looks to be under $100 million of the DCC’s debt). However, if this was the case you would expect profits and losses on any individual swap arrangement to be quite small and to largely cancel each other out over the course of any financial year. It is not obviously consistent with the tens of millions of profits and losses associated with interest rate swaps reported in the last three years’ accounts.
There are some longer term (and larger) notes that may have longer term swap obligations associated with them, but I am not sure that even they would generate this scale of variation. It is possible that other interesting things are going on under this all-encompassing ‘secured multi-option note facility’ arrangement for our collective debt that may be generating these numbers – but who would know?
It would be nice however to know who these three independent banks with apparently wonderful credit rating, and to whom we may end up being mortgaged up to our eyeballs to, actually are, who owns them and where they are based.
As a ratepayer, you could of course put in an LGOIMA request for this information on the basis that it will be you who would eventually end up paying the bills, as was done with regard to the ‘habitual investors’ in DCC bonds some years back. That is if you want yet another ‘refused on the grounds of commercial sensitivity’ letter on DCC headed notepaper to hang in your toilet.
It’s all very ‘clever’, but is it ‘clever’ enough? One genuinely pleasant thought to end with is that this may all pan out quite well from the ratepayer point of view if DCTL went toes-up, the capital was called and the case for the DCC’s non liability was argued by a determined lawyer on the basis that the ‘secured multi option note facility’ arrangement entered into by them was unlawful. If you look at the title of Section 62 it ends up with the word ‘etc’. I think that it could be logically argued that, due to its almost identical outcomes in the case of a CCTO default : ‘secured multi-option note facility’ = ‘etc’ when interpreting the Act with regard to them. Now that would be nice!
Prohibition on guarantees, eh.
There are warnings, there are people who lost nearly everything, from good-heartedly signing as guarantor on someone else’s mortgage because they thought it was nowt but a formality but it turns out that if the person who took out the mortgage [loan] got in the poo and couldn’t pay the guarantor has to.
That’s how it is with individuals. I’m guessing it’s the same with the DCC etc which is the reason behind Section 62 of the Local Government Act which, quoting Rob Hamlin’s post, “reads as follows:
62 – Prohibition on guarantees, etc”.
Slithering around the alleyways to find a way to avoid, evade, pervert or whatever, the intention of the Act looks like deliberately taking big risks and hoping for the best. It’s what bulletproof adolescents and habitual criminals do, backing themselves to be too smart to be caught.
I’m too old and too law-abiding to believe in that. The number of recent high-profile white collar people currently serving sentences should be giving all “cunning, respectable” adults a wake-up call.
DCC’s exposure appears large (derivatives). The council has low liquidity. As established at the meeting “we are all in it”. That means we get no sleep.
Open Meeting about DCC Finances
Well attended. Crs Richard Thomson and Hilary Calvert provided a useful forum; the purpose (they said) to find out what sort of information the public wants from tbe Council. Oh Boy!
Now that we know the process and the tone of approach, there’s a general wish that more meetings should happen – and if so, things are likely to get more interesting as certain avenues/figures/definitions/policies/directions/interpretations/clarifications etc are teased out and pursued for council accountability and transparency.
There’s definitely a “going forward” – not re-litigating the past – aspect. This doesn’t in any way reduce the need to address former (did I say, bad) practice, to “unearth” and bring to account – there is the collective expectation for Council to operate in less risky rorty (worse words) ways. We are talking about its debt management practices, and its massive consolidated debt, together with (new) spending programmes upon us via Cull’s council.
Tonight, answers were put to pre-supplied questions, and those received from the floor. How the council is exposed to derivatives. How DCC, DCHL and DCTL are bound and not bound by statutory requirement and or approved council policy began to be teased out. Emphasis here on ‘began’. Some conundrums arose, some moments of gloss, some things unanswered. Food for thought and in many cases rigorous analysis and definition still VERY MUCH required. Yes, we need more sessions – and yes, new QUESTIONS need to be clearly stated and emailed to Richard and Hilary soon as.
Knowledgeable commentators who attended the meeting might offer What if? readers closer perspective, and worries (there are several, pressing!!). Needless to say I took copious notes and have yet to break them down (a job for later).
There is the intention for Q&As/FAQs to be published on the DCC website.
I see Rob has commented almost simultaneously.
We all know there are Serious Matters we may never get answers to from this Council and its Treasury.
VERY SHALLOW REPORTING FROM YOUR LOCAL RAG
### ODT Online Thu, 28 Nov 2013
40 attend public meeting on council finances
By Vaughan Elder
A public meeting to discuss the state of the Dunedin City Council’s finances was hailed a success and is likely to be the first of many.
Read more
The intriguing thing from the ODT story – pitiful that it was – was the comment to Cr Calvert from Cr Thomson in that he thought that “only about 4 people would show up”. Sounds like it was about the same attendance as the far more extensively reported sea wall meeting.
The ODT story on this finance meeting was a complete cop-out in terms of substance, but it does show the sort of attitude of Richard Thomson and gives cause to wonder whether he supports DCC financial activity to bypass the requirements of the Local Government Act.
I can vividly recall Athol Stephens in one of his “explanations” of why things happened the way they do saying that much of the activity was to avoid the payment of tax to Central Government.
But it doesn’t matter when the basic position is looked at. The DCC have incurred debt of amounts that are eye-watering, and they have done so to build things that were promised to give a positive financial return, We all know that people lied, they made money that they were not morally entitled to, they betrayed the community. And Thomson and many of his “colleagues” are not interested in holding anyone to account. The perpetrators know this institutionalised lack of accountability, the agencies given the job of policing the environment are not interested either and so the frauds and dubious practices are simply ignored. Par for the course.
Russell, I sometimes get told this website is negative. And I question why anyone would bother to say that against what I consider to be the massive self-serving fraud and abuses of power perpetuated by Dunedin City Council against the good people of Dunedin – that practice and (cynical ‘bankrupt’) style of local government is more negative than anything anyone here could dream up or action.
What if? has a healthy following that doesn’t seem to dent or drop off – I suspect there are enough people out there (reading this) who simply want to see justice done.
We’re not here twiddling our thumbs. Loyalty to good principles takes us places. Doesn’t mean we don’t push and prod things around, or take out a chicken or two.
Negative – I think it’s a fair comment.
Always moaning on about things.
Things like pointless extravagance; basing decisions on spin, figures that don’t stand up to scrutiny, and wishful thinking; rorts; hypocrisy; leaping onto bandwagons and making someone else pay for the ticket; being compliance-crazed or bending the rules, depending on who the other party is; an associated problem which is being limp where resolute is what’s needed.
And so on.
A terribly negative site, no doubt about it.
So determinedly negative that some contributors go to extraordinary lengths to discover, and then calculate the figures that are normally obscured or distorted for public consumption. Others winkle out other hidden facts and put them into the context of what has been told to the voters to correct half-truths and spin.
Negative! Why can’t people be content with what the Important People want them to know, why do they have to question, pry, criticise?
If reincarnation is true we may come back as mushrooms, so why not embrace the lifestyle now – happy being kept in the dark with a regular supply of “effluent”.
Enormous summary. Mirth, expulsion of doubt, What if? self-analysis – more costic excuses to situate, pound, strangle callow knaves, thieves, likely lads, buffoons. Expensive blight.
Russell, it is an oxymoron to expect that the Toitu Otago Settlers Museum that does not charge could ever contribute financially. It is a matter of record that the old building which had $50 million spent on it could not return $3.5 million EXTRA to break even on that expense; and historically, in cities much larger than Dunedin with many more potential acts and sporting events (see Olympic stadium Homebush sold for $10 million) all stadia in small cities are loss making facilities.
Therefore the problem with Dunedin’s expenditure is that it is esoteric and the few who purport to understand work for the DCC.
Clearly, Standard & Poor’s can’t work out the strategy that the DCC has and is continuing to employ (see cycle lanes development, again non-productive financially).
If the council is going to continue to invest then it needs to find a commercial model that makes sense to business people not the rarefied air that has been the habitat of the last twenty years.
The alternative is that the DCC gets out of all commercial activities, lets go the staff employed in those failed business models and faces up to the reality that is Dunedin. It is a town bereft of public servants that are able to manage businesses.
John, it is dreaming the un-dreamable when you think of the DCC getting out of all commercial activities. It is something it has specialised in for the last couple of decades, building up a vast reservoir of talent for creating loss making ventures, without exception, it is what it does best and its greatest cheer leaders to date have been our elected representatives. How can you possibly top that? Besides, what other method could they employ to sell the dreams, and keep all the ‘movers and shakers’ in clover. Where indeed would simple folk (I use that term loosely) like Malcolm get their jollies?
@Hype O’Thermia
November 29, 2013 at 4:19 am
You said “…….Others winkle out other hidden facts and put them into the context of what has been told to the voters to correct half-truths and spin.”
We are not alone in this sort of obfuscation, dodging and weaving and hiding. Pertinent today is this extract re this meeting (below) reported on “Bishop Hill” blog.
“The long-awaited meeting between representatives of GWPF and the Royal Society has at last taken place. Nigel Lawson has a brief report on the meeting at the Spectator, revealing little about the content, except for the fact that he is prevented from telling more by a demand for secrecy imposed by the Royal Society fellows themselves.”
The R.S. demanded secrecy!! The Royal Society’s motto ‘Nullius in Verba’ Take nobody’s word for it. Oh! The irony. You couldn’t make it up.
Mick, Nigella Lawson couldn’t have put it better.
Nice as your conflation is Elizabeth, my reference was to Nigel (father) not Nigella (daughter). however some wag suggested that he, Lord Lawson, may have other more pressing matters to consider. (in reference to his daughter’s present plight). Also ironic of course. Weaving and webs come to mind.
Given Charles Saatchi’s recent version of why spousal abuse wasn’t the reason he grabbed his wife round the throat and yelled at her in a public place, he’s pushing it uphill now with these new “revelations” about what went on at a time when he was present, presumably countenancing the “drug abuse” that he now finds so abhorrent he has to blurt at full volume. Some people just don’t get it about credibility. We’ve even seen similar entitlement-to-tell-porkies here in our little provincial backwater, but I’m far too tactful to mention examples.
Yo, Mock Turtle!
I thought “Nullius in Verba” meant “Get it in writing”
Trouble with that is you can’t even believe the written word either. Witness the writings in certain newspapers not too far from here.
Get it handwritten – complete with fingerprints.
At least that way you’ve got someone to go back to who can’t say they knew nothing. May have been sleep-writing or not read it before signing, but those “reasons” tell their own story.
I like the Nigel Lawson story, he had to conceal the facts but he made it known who was responsible for this refusal to allow openness. They must have loved him for that! Not.
Here is a great summary of this fiasco – courtesy Josh
Just read the S&P report. It will be ‘high fives and cream buns’ all round in the building tonight. What a load of “codswallop” that crowd come up with. They can’t even get the population figures correct. It is just a junket to the far south Pacific, to “rhubarb rhubarb rhubarb” with the ‘twinkies’ here who have had years to prepare their story and give the correct “sort” of information. Oh to be a ‘bureaucrat’.
Not sure if any ‘concerned ratepayers and residents’, in the past, have contacted the Standard & Poor’s report writers personally to express their take on the published reports. A good time to start, methinks.
Hmm – interesting idea, Elizabeth. Passing comments through the “usual channels” – letters to the editor, or to MPs – is a waste of time, as are most of the “approved” feedback methods available (allowed) to the important-once-every-3-years populace. Taken to the extreme of frustration that’s why wikileaks got traction, so much traction it became a major enemy.