PALMERSTON NORTH CITY
COUNCIL
Memorandum
TO: Council
MEETING DATE: 7 August 2017
TITLE: Council submission on Geographical Areas: Review of Area Unit Names
DATE: 7 December 2017
AUTHOR/S: Peter Crawford, Economic Policy Advisor, City Future
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RECOMMENDATION(S) TO Council
1. That
the draft submission to Statistics New Zealand on Geographical Areas: Review
of Area Unit Names be approved
2. That
the Mayor and Deputy Mayor be authorised to make minor amendments to the
draft submission
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1. issue
1.1 In
2015 Statistics New Zealand undertook a review of the Statistical Standard for
Geographic Areas, the first time the standard had been reviewed since
1992. Population changes since 1992 had resulted in significant variation
in the size of the different geographical areas used. The results of the
review were:
1.1.1 greater standardisation of the meshblocks, the smallest geographical
area used, with meshblocks ideally containing 30-60 dwellings.
1.1.2 Statistical area 1 (SA1) geographies were created to provide Census
data for small communities with a maximum population of about 500 people,
1.1.3 Statistical area 2 (SA2) geographies replaced the existing area
units and have a usually resident population of 1,000-4,000,
1.1.4 Urban/rural geographies were changed, with a focus on areas with a
high population density of 400 per square kilometre or 200 address points per
square kilometre.
1.2 There are limits to the amount of Census data which is released for
meshblocks due to Census confidentiality constraints, so the SA1 and SA2 area
units are the smallest geographical areas where a wide range of Census data
will be available.
1.3 The statistical area units do not determine the names of suburbs or
how the Council refers to broad areas of the City but are a tool for assessing
population and economic trends within the local authority area. Data on
annual employee counts, business numbers and building consents is also
available from Statistics New Zealand on an area unit basis. The Ministry
of Business, Innovation and Employment also uses area units for the publication
of data from its rental bond database. Revisions to the boundaries of
area units have been based on grouping populations with similar levels of
deprivation.
1.4 Statistics New Zealand proposes to review the geographical areas
prior to each Census so will be reviewing the meshblocks, area units and urban
area every five years.
1.5 Council has previously received submissions from the Bunnythorpe
community seeking support for the creation of an area unit for Bunnythorpe to
give the community access to a much wider range of
Census data than is available from Census meshblock data. The request for
this was communicated to Statistics New Zealand prior to the start of the
review of geographic areas. In addition, the Council’s Principal
Māori Advisor had previously identified that Statistics New Zealand had
spelt Papaioea incorrectly as Papaeoia
2. ISSUE
2.1 In February this year Statistics New Zealand presented a map with
its proposal for revisions to the area units in Palmerston North, based on the
new Statistical Standard for Geographical areas, draft changes to names for
existing area units and suggestions for names for the new area units
created. Feedback on the boundaries of area units was required by April
to meet Statistics New Zealand deadlines for planning for the 2018 Census,
while feedback on area unit names is required by 19 August.
3. discussion
3.1 The
review of the SA2 area units resulted in the proposed number of SA2 area units
for Palmerston North increasing from 27 to 41. These took into
account growth in residential areas since 1992, and identified major commercial
and industrial zones in the City and Council future residential growth
areas. This will significantly assist Council with using Statistics New
Zealand data for monitoring of the District Plan and with meeting the
government’s reporting requirements under the National Policy Statement
on Urban Capacity Development.
3.2 Statistics
New Zealand presented the Council with draft names for the 14 additional area
units created and requested submissions on whether the proposed new names were
appropriate. These are attached in Appendix One.
3.3 Council
staff sought input from Rangitāne o Manawatū on the appropriateness
of existing area unit names and the new area unit names proposed by Statistics
New Zealand. This resulted in eight proposed changes to area unit names
to give recognition to historic sites within the City.
3.4 A
comparison was also made with area unit names used by New Zealand Police and a
further six changes have been made to the proposed area unit names to better
align the Statistics New Zealand area unit names with those used by
Police.
3.5 The change to the proposed Palmerston North Central area unit name
was made following consultation with Todd Taiepa, Principal Māori Advisor,
since the proposed name was inconsistent with the location of the centre of
Palmerston North. Since the area unit aligns closely with the
south-eastern portion of the original Papaioea Clearing it was considered
Papaioea South was more appropriate. The Papaioea Clearing existed before
European settlement of Palmerston North. Its location is primarily
covered by the Palmerston North CBD, Papaioea North and Papaioea South area
units. This change is supported by Rangitāne.
3.6 In addition to the creation of more SA2 area units, Statistics New
Zealand has created two SA1 area units for Bunnythorpe and Longburn, which will
now give these two communities access to a much wider range of Census data than
previously.
3.7 The review resulted in the creation of four area units that largely
align with Council’s District Plan commercial zones (Palmerston North
CBD, Mihaere, Palmerston North Airport and Tremaine), separating these areas
that were previously combined with residential areas. Statistics New
Zealand will also be creating new SA1 area units within the Palmerston North
CBD area unit to largely align with the Council’s Inner and Outer
Business Zones.
3.8 Previously Statistics New Zealand included all Palmerston North area
units, except for the Turitea area unit, as part of the ‘Palmerston North
urban area’. This was based on the degree of urban influence for
each area unit. The new policy focuses on area units with high population
densities. The proposed new urban area boundary for Palmerston North now
excludes the following Palmerston North territorial authority area units;
Pihauatua, Aokautere Rural, Whakarongo, Newbury, Ashhurst, Bunnythorpe and
Longburn. This urban area boundary is relevant to the Council’s
obligations under the National Policy Statement (NPSS) on Urban Capacity
Development. The reporting requirements for the NPS are based on the
projected ten-year population growth rate for the Palmerston North urban area
and not on the growth rate for the whole of the city’s territorial
authority area.
4. NEXT
STEPS
4.1 It
is recommended that the Council approve the draft submission attached as
Appendix Two
Attachments
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1.
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Appendix One ⇩ 
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2.
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Appendix Two ⇩
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Peter Crawford
Economic Policy Advisor
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PALMERSTON NORTH CITY
COUNCIL
Memorandum
TO: Council
MEETING DATE: 7 August 2017
TITLE: Section 17A Reviews
DATE: 13 July 2017
AUTHOR/S: Andrew
Boyle, Head of Community Planning, City Future
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RECOMMENDATION(S) TO Council
1. That Parks,
Recreation and Sportsfields be governed, funded and delivered by the Council.
2. That Libraries
and Community Development be governed, funded and delivered by the Council.
3. That Roading be
governed and funded by the Council (and NZTA funding contributions), with
service delivery by a mix of private sector and Council.
4. That Refuse and
Recycling be governed, funded and delivered by the Council.
5. That the
Crematorium be governed, funded and delivered by the Council.
6. That a stage 2
review be carried out into the best governance, funding and service delivery
model for Arts and Culture.
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1. ISSUE
Under s17A of the LG Act Councils have
to review the cost effectiveness of their arrangements for meeting the needs of
their communities for good quality local infrastructure, public services and
regulatory functions.
2. BACKGROUND
The legislation sets out options that
must be considered. For governance and funding these are by:
· the
Council; or
· Joint
Committee or other shared governance arrangement.
For service delivery these are by:
· the
Council; or
· a
CCO owned by the Council; or
· a
jointly owned CCO; or
· another
local authority; or
· another
person or agency.
Further opportunities for improving
services or reducing costs can be considered through other Council processes,
including the 10 Year Plan.
The reviews are mandatory but the Act
gives Councils the ability to exempt services if the potential benefits of a
review do not outweigh the costs of undertaking the review.
Councillors workshopped their approach
to the s17A reviews in October 2015 and May 2016. At these Councillors
said they wanted to take a prioritised and two-stage approach to the
reviews. A prioritised approach meant identifying those services with the
most scope for cost-effectiveness improvements. A two-stage approach
meant carrying out high level reviews on these services to see if a second more
resource intensive review was warranted.
At its June 2016 Finance and
Performance meeting the Council decided to carry out s17A reviews by 7 August
2017 for:
· Parks,
Recreation and Sportsfields
· Community
Development
· Libraries
· Arts
and Culture
· Roading
· Refuse
· Recycling
· Crematorium.
It decided to make the
following services exempt from s17A reviews prior to 7 August 2017:
· Leadership
and Decision Making
· Direction
Setting
· Animal
Control and Public Health
· Consent
Planning and Building Control
· Customer
Services
· Civil
Defence
· Cemeteries
· Water
· Stormwater
· Finances
(internal)
· Information
Management (internal)
· Human
Resources (internal).
It also decided that
recent or current reviews of the following services met the intent of s17A such
that further reviews before 7 August 2017 were not an effective use of Council
resources:
· Arena
Manawatu and Convention Centre
· Economic
Development
· Social
Housing
· Parking
· Swimming
Pools.
Finally, the Council
noted that it will decide on the priority for a s17A Review of Wastewater
following a wastewater workshop in August 2016. At the workshop
Councillors were of a view that no review should be carried out until Council
has more clarity on the best practicable option for wastewater.
The services identified for review
prior to Aug 7 2017 were workshopped in April and May 2017. Each workshop
followed a similar process: Councillors considered information on levels
of service, community satisfaction, achievement of KPIs, costs, and current
governance, finding and service delivery arrangements.
The services were rated on a range of
criteria to consider the best forms of governance, funding and service
delivery. Services with the following characteristics are, in general,
best governed, funded and delivered by Council:
· high
degrees of public interest and accountability,
· high
contribution to Council strategies,
· high
degree of integration with other Council services and assets
· high
degree contribution to Council’s culture and customer service
· require
a high degree of local government knowledge
· long-term
environmental and public health impact
· long-term
asset planning.
Services with the following
characteristics are, in general, best governed, funded and delivered jointly or
externally:
· strong
competitive markets
· external
revenue is available
· economies
of scale
· need
the ability for flexible responses
· need
specialist governance or delivery skills
· have
common strategic issues and levels of service
· have
fair funding criteria
· risks
can be shared.
Councillors also identified other
opportunities for cost effectiveness improvements.
Community views from previous
engagement, in particular Long-term Plans and Annual Budgets; Communitrak
Surveys, and the NRB Focus Groups, were used for the reviews.
Parks, Recreation and
Sportsfields: After considering the
information in Appendix 1 Councillors were of a view that a stage 2 review was
not warranted and that parks, recreation and sportsfeilds as a whole should be
governed, funded and delivered by Council.
This is because, in particular, it has
high degree of public interest and accountability, makes a big contribution to
Council’s strategies, and has a high degree of public good.
Within this overall approach to
service delivery, Councillors want to see more rigour around the service level
agreements (SLAs), with business cases for operational aspects of the service
such as mowing and tree maintenance so that the best means of delivery for
these can be used. Alongside this there should be clearer penalties for
any poor performance. Staff will put more emphasis on annual SLA market
comparisons for these components, with the assistance of external
consultants. Staff will also put more emphasis on monitoring the
performance of the SLAs to ensure that the agreed performance is delivered.
In these considerations staff will
also take into account the utilisation of equipment and facilities. If
Council has expensive equipment or facilities that are not used to capacity
then Council should consider spreading the cost of these by letting other
Councils use them. The co-ordinated regional use of facilities is a major
rationale for the Regional Sports Facilities Plan being developed by Sport
Manawatu.
Councillors also suggested that more
use be made of volunteers and partnerships with other organisation and
Councils. These partnerships are pursued for many projects through the 10
Year Plan. Volunteers are used where appropriate, but there are
increasing health and safety costs to this.
Libraries and Community
Development: These were reviewed together
because of the overlap in the services they offer and in the ways that they are
provided.
After considering the information in
Appendix 2 Councillors were of a view that a stage 2 review was not warranted
and that library and community development services should be governed, funded
and delivered by Council. In particular, this was because of their high
contribution to Council’s strategies, high level of public interest and
accountability, and high degree of integration with other Council services.
Within this overall delivery model
Councillors identified specific areas for further review:
· City Library and Branches: This is occurring through the 10 Year
Plan and the Library of the Future project.
· Community Centres – a report went to Community Development
Committee in June 2017.
· Community Support and Funding – this is being looked at
through the 10 Year Plan, the Community Support plan, a follow-up report from
the Social Well-Being Forum on community capacity and capability, and a report
on Creative Communities Funding.
· Providing library services and community development through a
multi-purpose community hubs model in partnership with other organisations
(government departments, community groups, MidCentral, etc). This is part
of staff ongoing work.
Arts and Culture: After considering the information in Appendix 3 Councillors were of
a view that a stage 2 investigation was warranted into the best form of
governance, funding and service delivery for the cultural organisations.
(Cultural organisations covers Te Manawa, Regent Theatre, Globe Theatre,
Caccia Birch, Square Edge and Creative Sounds.)
Options include the status quo, new
CCOs, a different mix of CCOs, or in-house.
To do this Council and the arts and
cultural organisations need to work together to determine the most
cost-effective forms of governance, funding and service delivery. Issues
that need to be considered include the most cost-effective ways to:
· Ensure that the services have strong vision and leadership to
contribute to Council’s strategic aspirations
· Retain and better recognise the contribution of volunteers to the
services (in terms of their time and donations of arts resources)
· Futureproof the services so new responsibilities can be included
and, if Boards are retained, put more emphasis put on Board succession
planning
· Get greater efficiencies through shared back of house activities
such as HR, marketing and promotions, IT, and ticketing.
Roading: After considering the information in Appendix 4 Councillors were of
a view that a stage 2 review was not warranted and that roading services as a
whole should be governed and funded by the Council (with NZTA funding
contributions), and that service delivery should be by a mix of private sector
contracts and Council. Governance and funding are by Council because of
roading’s strong contribution to Council’s strategic goals, its
high degree of integration with other Council services, and its high public
good. Service delivery is by a mix of private sector and Council:
· Private sector: road maintenance (including
offroad cycle path maintenance), road resurfacing, signage, traffic services
(signals and lighting), road marking and pavement renewals. (This made up 86%
of roading capital expenditure and 68% of operating expenditure in 2015/16).
· Council: asset planning, design work,
footpaths, berms, separate kerb and channel, and vehicle crossings. (This
made up 14% of roading capital expenditure and 32% of operating expenditure in
2015/16).
External contracts
are based on competitive tendering. Under NZTA rules any work that is
subsidised cannot be provided internally.
Within this overall approach to
service delivery Councillors want to consider a more of a collaborative or
shared services approach. This applies in particular, to asset
management, professional services, contract management and road
maintenance.
The Council currently has a four year
road maintenance contract. This aligns with the timeframe for the renewal
of neighbouring Councils’ road maintenance contracts. There will be
ongoing discussions about how the Councils can work together more to align and
or share services. This will include considering a more ‘bundled
up” or shared road maintenance contract when the current contracts
expire. NZTA will be part of these discussions.
Refuse and Recycling: These were considered as separate but intertwined services. This is because there are other companies that offer refuse collections, but the Council is the
only provider of comprehensive recycling services. However, the Council
does need to look at refuse and
recycling services holistically when it is trying to influence peoples’
behaviour to minimise waste.
After considering the information in
Appendix 5 Councillors were of a view that a stage 2 review was not warranted
and that refuse and recycling services should be governed, funded and delivered
directly by Council. In particular, this is because of the strong
contribution these services jointly make to Council’s strategic goals for
waste minimisation.
This maximises the opportunities the
Council has to change people’s behaviour and hence reduce the amount of
waste that they generate. Also, without Council’s involvement there
may be limited recycling collections because of a lack of commercial
opportunities for some recyclables.
Councillors suggested that the
following improvements need to be considered within Council’s service
delivery:
· Provide people the choice of using smaller rubbish bags. (The
June 2017 Finance and Performance Committee agreed to this. The smaller
bags will be introduced in by the end of 2017.)
· Rate every business and provide a recycling service suited to their
requirements. (The June 2017 Finance and Performance Committee confirmed
this should be considered as part of the 10 Year Plan development).
· Add a residential organic pickup, with costs possibly being offset
by changes in the frequency of other services. (The June 2017 Finance and
Performance Committee confirmed that this should be considered further as part
of the 10 Year Plan development.)
· Encourage other Councils and commercial interests to use
Council’s rubbish and recycling facilities, particularly the Materials
Recycling Facility. Staff are having ongoing discussions
with Manawatu and Whanganui District Councils.
· Look at where Council provides a special service. Council
provides a special “at house” pickup service for people who cannot
get their bins to the kerb to about 50 people. Staff could review
the criteria for this and consider charging a fee. A bigger issue is
having to provide special pickup service to access narrow private rights of
way. Staff are currently reviewing this service.
· Try to expand the recycling by promoting the service to areas of the
City that currently do not receive it. Staff will canvas residents support
for this if residents initiate it, but many of these are in rural areas with
relatively low population densities.
· Provide more split rubbish and recycling bins in parks etc, with
education to change peoples’ behaviour so that the recycling bins are not
contaminated with waste. Through the 10 Year Plan staff are reviewing
what style of bins best promote and assist recycling.
· Encourage food vendors to use compostable packaging at events.
Officers are developing polices for this, supported by amendments to the Waste
Management and Minimisation Bylaw.
· Encourage supermarkets not to use plastic bags. Council
is supporting a Local Government New Zealand remit for a levy on plastic bags
· In general work with people to encourage them to recycle, rather
than enforcing it through bylaws. Staff are looking for the best balance
of behaviour change and enforcement, particularly around illegal dumping.
Crematorium: After considering the information in Appendix 6 Councillors were of
a view that a stage 2 review was not warranted and that the crematorium should
be governed, funded and delivered directly by the Council. In particular,
this is because the demand is for cremations rather than burials and because
the service contributes to Council’s social goals.
Within this Councillors requested
staff look at changing the funding split to reduce the rates funding component
by increasing the cremation fee. (There is currently a funding split of
about 70:30 between user charges and rates.) They also suggested an out
of town surcharge so non-Palmerston North cremations are not subsidised by the
ratepayer. These will be considered through the Revenue and Financing
Policy and the setting of Council fees and charges, both prior to the 10 Year
Plan.
Councillors also noted that the
crematorium has capacity for about 1000 cremations per year but actually does
about 450. Hence they requested staff promote the service to other
Councils who have a crematorium so they use ours rather than having to maintain
their own. Plus staff should promote the crematorium to local funeral
directors. This will be part of the ongoing maintenance of the cremator.
The crematorium is earthquake prone
and needs about $500K spent on it to remedy this. Councillors requested
information on the timing and likelihood of the crematorium’s consent
being renewed. This will be provided as part of the programme information for
the 2018 10 Year Plan.
Councillors also said that the wider
Cemeteries Activity needs to be part of the next round of s17A Reviews.
3. NEXT
STEPS
The actions
identified above will continue, either through the 10 Year Plan or as ongoing
staff actions. This includes the review of Arts and Culture.
Council should
identify the services for the next round of s17A reviews.
4. Compliance
and administration
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Does the Committee have delegated authority to
decide?
If Yes quote relevant clause(s) from Delegations
Manual <Enter
clause>
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Are the decisions significant?
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No
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If they are significant do they affect land or a
body of water?
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No
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Can this decision only be made through a 10 Year
Plan?
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No
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Does this decision require consultation through the
Special Consultative procedure?
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No
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Is there funding in the current Annual Plan for
these actions?
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Yes
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Are the recommendations inconsistent with any of
Council’s policies or plans?
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No
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Attachments
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1.
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S17A templates ⇩
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Andrew Boyle
Head of Community Planning
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PALMERSTON NORTH CITY
COUNCIL
Memorandum
TO: Council
MEETING DATE: 7 August 2017
TITLE: Inquiry into the 2016 Local Authority Elections
DATE: 24 July 2017
AUTHOR/S: John Annabell, Legal Counsel, City Corporate
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RECOMMENDATION(S) TO Council
1. That
Council consider whether or not to make a
submission to the Justice and Electoral Select Committee concerning the
Inquiry into the 2016 Local Authority Elections.
2. That
if Council decides to make a submission, the Mayor and Deputy Mayor be
authorised to approve the content of the submission on behalf of the Council.
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1. ISSUE
Public
submissions have been invited on the Inquiry into the 2016 Local Authority
Elections. This memorandum addresses whether or not a submission should
be made on behalf of the Council.
2. BACKGROUND
The closing
date for submissions is Tuesday 22 August 2017, which is understood to be the
day that Parliament rises for the general election. Originally, a date
later for this year had applied.
The terms of
reference for the Inquiry are fairly broad based, and state that the Inquiry
“will examine the law and administrative procedures for the conduct of
Local Authority elections in light of the 2016 local elections.”
The Inquiry will also consider the matter raised in petition 2014/0060 of
Andrew Mark Judd. In his petition, Mr Judd suggested that the
establishment of Maori wards on district councils follow the same legal
framework that applies for establishing other wards on district councils.
I recently
sent emails to elected members inviting suggestions on the contents for a
possible Council submission. Only one response was received, that
response supporting a submission being made, with a focus on the following
matters:
· Online voting In
2019.
· The Andrew Judd
petition.
· Path to
harmonisation of local government electoral systems to Single Transferable
Voting (STV) Electoral System.
· Means to further activate
voter participation in local body elections.
With regard to
online voting, the Council may wish to make a submission supporting the use of
online voting in the 2019 elections for any local authority wishing to do
so. While it is acknowledged that the introduction of online voting, in
itself, may not significantly improve voting turnout, the introduction of
online voting would at least provide another voting option for those electors
who use computers in their everyday personal and/or working life. The
introduction of online voting will also contribute towards the
government’s wish to make increasing use of websites or other online
facilities for conducting business. Online voting would also provide a
ready opportunity for electors to vote from overseas locations if they do not
happen to be in New Zealand during the voting period. While the
government did not permit a trial of online voting going ahead for the 2016
elections, it was a somewhat surprising outcome given the government’s
preferred use for electronic communications in other areas of everyday life
which involve quite sensitive personal information of people.
For the Andrew
Judd petition, it is for the Council to decide whether or not the Maori ward
option should be brought within the compass of the normal representation
review. Under Mr Judd’s proposal, a decision on whether or not a
Maori ward or wards should be established would be made by the Council at the
same time as it makes its other decisions on representation and in the same
manner. Therefore, for Palmerston North City Council, this would mean
that a decision to establish the Maori ward would be made at the same time as
the Council decides whether or not to maintain the city-wide electoral system
and related decisions, which is scheduled to occur by about August 2018.
If any people were unhappy with the Council decision, they can object firstly
to the Council and then finally to the Local Government Commission which has
power to make a final decision. However, there would be no opportunity
for an automatic poll on the matter should this be requested by citizens.
For the path
to harmonisation of local government electoral systems to STV, this suggestion
acknowledges the present difficulty created by the use of two different
electoral systems on voting documents sent to electors. While local
authorities have the choice of using the First Past the Post (FPP) Electoral
System or STV electoral systems, District Health Boards throughout New Zealand
are required to use the STV electoral system. The effect of this is that,
for most voting papers distributed throughout New Zealand, there is a mix of
the two electoral systems used on the same voting paper. Unfortunately,
the use of the two systems together leads to some confusion on the part of
electors, with a possible consequence of there being a higher informal vote
rate than might otherwise be the case. In its submission sent to the
Justice and Electoral Committee in 2013, the Council stated that it
believed that the STV system was the more appropriate electoral system to
use, as it was a broadly proportional electoral system that provided effective
representation for a wider range of points of view. It also enabled
electors to express preferences for all candidates seeking election regardless
of the number of candidates, and minimisd the opportunity for tactical
voting. The counter-view is that the FPP electoral system is relatively
simple, and easier to explain to electors.
With respect
to means to further activate voting participation in local body elections, the
Council has always maintained that it was appropriate to embark on promotional
opportunities, notwithstanding that some other local authorities and electoral
officers have been less willing to do so because there was no explicit mandate
for such activities provided for in legislation. This is apart from the
publication of candidate profiles and sending them out with voting papers, as
authorised by the Local Electoral Act 2001. To put the matter beyond
doubt, it might be appropriate to request the Justice and Electoral Committee
to agree that the Local Electoral Act 2001 be amended to explicitly provide
local authorities with a mandate to undertake such activities, as they consider
appropriate, that would assist participation in local elections.
3. NEXT
STEPS
If the Council
decides to approve a submission, this will be prepared and submitted to the
Mayor and Deputy Mayor for approval. The next Council meeting date is
after the closing date for submissions. The submission will then be sent
to the Select Committee, together with an indication of whether or not the
Council wishes to be heard in support of its submission. It will be for
the Mayor or Deputy Mayor to decide whether the Council should appear in person
to support its submission.
4. Compliance
and administration
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Does the Committee have delegated authority to
decide?
If Yes quote relevant clause(s) from Delegations
Manual
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N/A
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Are the decisions significant?
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No
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If they are significant do they affect land or a
body of water?
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No
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Can this decision only be made through a 10 Year
Plan?
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No
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Does this decision require consultation through the
Special Consultative procedure?
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No
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Is there funding in the current Annual Plan for
these actions?
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Yes
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Are the recommendations inconsistent with any of
Council’s policies or plans?
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No
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Attachments
Nil
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John Annabell
Legal Counsel
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