Comptroller Seeks Fiscal Justification and Detailed Cost Analysis of Proposed “Declaration of Need” Financing

City Comptroller Barbara Miller Williams

City Comptroller Barbara Miller Williams has sent a letter to Mayor Sean Ryan requesting additional information and a detailed fiscal analysis of the proposed “Declaration of Need” debt financing arrangement between the City of Buffalo and the Buffalo Fiscal Stability Authority (BFSA), identified as Common Council Item No. 26-000830. The letter raises concerns regarding the proposal’s necessity, timing, costs, and potential impact on the City’s finances.

The Comptroller is requesting an explanation of why the arrangement is being pursued now, particularly since the BFSA has not filed on the City’s behalf since 2007. The Administration is also asked to explain why direct City borrowing would not adequately address the proposed capital needs and to quantify any anticipated savings against the full costs of BFSA-issued debt.

The letter also highlights concerns regarding the consultation and capital planning process. A previous Declaration of Need, submitted in 2021 under Common Council Item No. 21-359, expressly called for consultation with the City Comptroller regarding the timing, terms, and amount of BFSA bond issues and to date, this has yet to occur regarding the proposed borrowing. The current proposal does not provide for the same consultation. Additionally, the letter notes that the Citizens Planning Council’s Recommended Capital Budget and Four Year Capital Improvement Program, due October 7 under Section 20-23 of the Buffalo City Charter, had not been filed as of October 9, 2026.

The proposed financing seeks up to $20,060,000 for authorized capital costs and related expenses. The Comptroller’s 2026 Estimate & Report identifies FY 2026 2027 debt capacity of $36 million. The letter requests clarification on whether the proposed financing would count toward that capacity or be in addition to it, and how the transaction would affect the City’s remaining borrowing capacity and future capital needs.

The Administration is also being asked to provide the projected interest rate savings, repayment period, annual debt service, total borrowing costs, and a comparison of BFSA issued debt with direct City borrowing. Additional information is requested regarding the potential extension of the BFSA’s authorization beyond June 30, 2037, for any debt that exceeds beyond eleven years, and the cost of issuance with this transaction. Furthermore, if the BFSA borrows on behalf of the City, will additional services increase the BFSA’s existing $1 million budget; moreover, will the anticipated new debt have an effect on City property tax revenues and future budgets.

“The City must have a clear understanding of why this financing is necessary, considering the Comptroller’s Office has been successfully borrowing on the City’s behalf for almost two decades. In addition, I am requesting a detailed analysis of what this capital borrowing will cost, and whether it provides a measurable financial benefit compared with borrowing directly through the existing City Charter established channels,” stated Comptroller Miller Williams. “Any proposed financing must be supported by a documented fiscal need, provide appropriate financial oversight, and protect the City’s long-term financial flexibility.”

The correspondence requests supporting resolutions, financing documents, debt-service schedules, cost estimates, revenue projections, the 2021 Declaration of Need, the current proposal’s supporting materials, and the status of the required capital planning submission.

The Department of Audit and Control remains committed to transparency, responsible fiscal management, and independent financial oversight on behalf of Buffalo residents and taxpayers.