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    P.O. Box 38741 Wellington M.C.67 Hankey Street, Mt Cook,Wellington, New Zealand .Ph : (04) 381 8750 Fax: (04) 381 8777

    RESPONSE OF TE KOHANGA REO NATIONAL TRUST BOARD TO ECE TASKFORCEREPORT, AN AGENDA FOR AMAZING MOKOPUNA, 2011

    20 December 2011

    [To be published alongside Introduction to the Report if published by chapter]PURPOSE OF TE KOHANGA REO NATIONAL TRUST BOARD'S RESPONSE TOTHE ECE TASKFORCE REPORT

    1. Te Kohanga Reo National Trust Board ("the Trust Board"} represents 471 KohangaReo throughout New Zealand and 9,140 Mokopuna (as at 1 November 2011 ). In thisdocument, we respond to comments made in the ECE Taskforce ("the Taskforce")Report, An Agenda for Amazing Mokopuna, 2011 ("the Report"), about Kohanga Reoand the Trust Board.

    2. The Trust was not consulted on the Report prior to its release for public comment on 1June 2011 . This was despite assurances to the contrary and the inclusion of adversecomments and findings about the Trust Board and Kohanga Reo in the Report.

    3. In recognition of the unfair process adopted by the Taskforce, the Ministry of Educationhas agreed that our comments in response to the Report will always appear alongsidethe Report whenever it is published .

    4. The following statement should always be published in order to explain the need for theTrust Board's comments to appear alongside the Report:

    Te Kohanga Reo National Trust Board's response to the ECE Taskforce Report appears asa separate addendum to the ECE Taskforce Report. Te Kohanga Reo National Trust Boardwas not consulted in relation to the ECE Taskforce Report despite being an interested partyand despite adverse statements being made about the Trust and Kohanga Reo in theReport. Te Kohanga Reo National Trust Board has therefore put this into its response andrequested that its comments be read alongside the ECE Taskforce Report.

    5. The Trust Board is very aggrieved with the contents of the Report. It suggests thatKohanga Reo are of poor quality and that there are accountability issues relating to theTrust Board itself. The Taskforce also questions whether the Trust Board is a "keybarrier" to the Kohanga Reo movement.

    6. The Trust Board has worked long and hard over the past three decades to ensure thatthe importance of the Kohanga Reo kaupapa for our people, our language andmokopuna is understood. However, the Report illustrates that there continues to be alack of understanding regarding the nature and purpose of Kohanga Reo and theirkaupapa.

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    7. The Taskforce has failed to adequately inform itself through consultation or accessingrelevant expertise. As a consequence, it was not in a position to make the findings andcomments about Kohanga Reo and the Trust Board that it did. This is reflected inreadily identifiable mistakes of fact and a lack of probative evidence to support itsassertions.

    8. The statements made in the Report have caused unwarranted reputational damage toKohanga Reo and the Trust Board and serve to undermine the sustainability of theKohanga Reo movement. Kohanga Reo are nga taonga (treasures) in their own rightand as kaitiaki (guardians), we are compelled to set the record straight.

    SUMMARY OF THE TRUST BOARD'S COMMENTS ON THE REPORTStructure of the Trust Board's response

    9. The specific concerns of the Trust Board are set out in detail below. For each chapterof the Report, the specific passages of the Report that the Trust Board does not agreewith are quoted in full (in italics), followed by the Trust Board's comments. In eachinstance, the Trust Board provides an overall response to the Taskforce's findings inthat chapter, followed by addressing the specific comments made in that chapter.

    10. However, our comments can be broadly summarised under the following headings:(a) Failure of the Taskforce to adequately inform itself;(b) Mistakes of fact and absence of context;(c) Lack of probative evidence for key findings; and(d) Consequences for the Kohanga Reo movement and the Trust Board .Failure of the Taskforce to adequately inform itselfLack of understanding and consideration of the nature and purpose of KohangaReo and their kaupapa

    11 . The Kohanga Reo movement was started in 1982 as a whanau (family) developmentinitiative, not an early childhood education (ECE) service, under the auspices of theDepartment of Maori Affairs. The movement was based on Mokopuna acquiring (notbeing taught), as early as possible, te Reo and tikanga Maori (Maori language andcustoms) and the passing down of cultural knowledge (usually from kaumatua (elders)to mokopuna (grandMokopuna)) in a whanau environment setting.

    12. The Kohanga Reo kaupapa is about mokopuna, tamariki (Mokopuna) and whanauworking together or "mahi tahi". This extends from the learning environment, whereeveryone works together to learn from one another, through to whanau taking collectiveresponsibility for managing and governing their Kohanga Reo. The dynamics are notunlike a marae. Unlike ECE, the focus of Kohanga Reo is not simply Mokopuna andqualified teachers, but about revitalising te Reo and tikanga Maori within the widerwhanau context.

    13 . Without consultation with Kohanga Reo, in 1990, Kohanga Reo was forced toassimilate within the ECE regulatory regime, despite the fact that it is not an ECEservice and that this regime is inconsistent with the kaupapa.

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    14. In treating Kohanga Reo as an ECE provider, the Taskforce considered Kohanga Reoagainst an ECE quality framework that does not fit the nature and purpose of KohangaReo and their kaupapa. For example, throughout the Report there is a focus on staffwho hold ECE qualifications as an indicator or driver of quality. 1 But for Kohanga Reo,all of the whanau are responsible for learning. In particular, kaumatua play one of thefundamental roles in passing down knowledge to the Mokopuna, not ECE qualifiedstaff.

    15. Although the Taskforce says that "[w]e unequivocally acknowledge the phenomenalachievements of Kohanga Reo in relation to whanau development and Maori languagerevitalisation"2, the Taskforce failed to evaluate Kohanga Reo against what qualitymeans for Kohanga Reo (i.e ., the very whanau development and Maori languagerevitalisation that the Taskforce claimed to acknowledge). The Report also goes on tomake detrimental statements discussed below.Lack of recognition for the Trust Board's role as kaitiaki (guardian) of KohangaReo and their kaupapa, which are nga taonga

    16. The Trust Board is the umbrella organisation for Kohanga Reo and plays a special roleas Kaitiaki in protecting the Kohanga Reo kaupapa . It represents 471 Kohanga Reothroughout Aotearoa and operates upon the mandate of Kohanga Reo whanau . Inparticular, its objects are to promote, support and encourage the Kohanga Reokaupapa and to provide necessary financial, advisory and administrative assistanceand support for Kohanga Reo whanau . The Taskforce failed to recognise the TrustBoard's kaitiaki status, but nevertheless thought it appropriate to comment specificallyon:(a) The governance role of the Trust Board. In particular, the Taskforce questioned

    the " .. national body leadership for Mokopuna who attend Kohanga Reo andwhether the Trust Board is a key barrier or contributor to the original aspirationof the movement"3 (emphasis added). That comment was of particular concernto the Trust Board given that the Taskforce does not appear to understand theoriginal aspirations of the movement, which (as noted above) are not ECE. Thiscomment was not put to the Trust Board before it was published. However, theECE Taskforce thought it appropriate following the release of the Report to seekpublic comment about the Trust Board from the entire ECE sector in aquestionnaire released for consultation between 15 June and 8 August 2011 ;4

    (b) Previous reviews involving the Trust Board and whether such recommendationsshould be implemented.

    5For example, it suggested that the recommendationsof the Gal len Report (2001) be revisited and where appropriate, implemented.6

    One of the recommendations of the Galien Report was for devolution of Kohanga

    1 In particular, see Essay on Policy Design 1: Aiming for High-Quality Services, page 40 . The Taskforce notes atpage 49 that "For Maori students, the relationship between teacher and student is the most important thing".However, Kohanga Reo have been hugely successful with whanau all playing an important role.2 Page 57 of the Report.3 Page 146 of the Report.4 See ECE Taskforce Consultation Questionnaire, Part 6 - Te Kohanga Reo National Trust: reporting and compliancerequirements (page 21) .5 Page 145-146 of the Report.6 Recommendation 46, page 135 of the Report.

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    Reo from the Trust Board to iwi to occur. 7 However, devolution is a decision forKohanga Reo whanau ; and

    (c) Alignment of the Trust Board's reporting and compliance requirements with thoserequired in other ECE settings8 . Again, that failed to acknowledge the kaitiakistatus of the Trust Board and an understanding of the kaupapa of Kohanga Reo.Requiring K6hanga Reo to meet ECE compliance requirements undermines thekaupapa of Kohanga Reo and seeks to further assimilate K6hanga Reo withinthe ECE framework.

    Failure to adhere to Terms of Reference through Jack of consultation andrelevant expertise

    17. The Trust Board considers that , in failing to properly inform itself, the Taskforce failedto adhere to its Terms of Reference (set out at Appendix 1 of the Report).9 Inparticular, the Taskforce was requ ired to :(a) Undertake a full review of the value gained from the different types of

    government investment in early childhood education in New Zealand; and(b) Consider the efficiency and effectiveness of Government's current early

    childhood education expenditure, and ways that this might be improved ,particularly for Maori, Pasifika, and Mokopuna from low socio-economicbackgrounds. 10

    18 . Further, the responsibility of Taskforce members was to " ..act in the interests of allstakeholders including Mokopuna and parents".11

    19. The Trust Board does not agree that Kohanga Reo should be defined as an ECEprovider. However, we believe that the scope of the terms of reference required theTaskforce to undertake a full and robust review of the value gained from Kohanga Reoincluding its history and kaupapa and to act in the interests of Kohanga Reo and theTrust Board before making its findings. It did not do so.

    20. The Trust Board was the only national body singled out for criticism by the Taskforce.We were not consulted by the Taskforce or given the opportunity to comment on suchcritical and adverse findings. Had the Trust Board been given the opportunity to do so,it would have provided balanced comments and put necessary information before theTaskforce showing the criticisms lacked probative evidence.

    21 . Having reviewed the Bibliography in the Report, we have not seen evidence that showsthat the Taskforce accessed sufficient literature, expert advice or resources to informitself about Kohanga Reo and the Trust Board to ensure its comments and findingswere accurate and robust. 12Mistakes of fact and absence of context

    22. As a consequence , some of the comments made in relation to the Trust Board arebased on incorrect information or in the absence of wider context.

    7 As noted at page 145 of the Report .8 Page 146 of the Report.9 From page 176 of the Report.10 Page 176 of the Report.11 Page 177 of the Report.12 From page 169 of the Report.

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    No replacement funding23. The Taskforce stated that the recommendation contained in the Galien Report that the

    Government agree a process to support future funding commitments previously met bythe Property POtea scheme (established by the Trust Board to provide funding forcomputers, Maori language training, resource development, health and research) hadbeen actioned .13 While the Government disestablished the Property Putea scheme, itdid not provide replacement funding .Tripartite process

    24. The Taskforce said that the remaining recommendations of the PricewaterhouseCoopers' castings review of the Trust Board were part of the Tripartite Reviewprocess. 14 One of the remaining recommendations as noted in the Report was:

    .. .an examination of the funding and expenditure of the Trust, in light of the early childhoodeducation sector, the Ministry's goals, the philosophies of the Trust and the Kohanga Reomovement and the wider socio-economic environment; to include a comparison with otherparts of the early childhood education sector.15

    25. However, it was never agreed that this would form part of the Tripartite work process .26. The Tripartite parties consisted of the Trust Board, Te Puni Kokiri and the Ministry of

    Education, pursuant to a Tripartite Relationship Agreement 2001.27. Instigated by the Trust Board, a working group was established in 2008: the Funding

    Quality and Sustainability of Kohanga Reo Working Group, which appears to be the"Tripartite Review process" that the Taskforce refers to. The purpose of that WorkingGroup was to support the quality and sustainability of Kohanga Reo by developing athree year agreement between the Trust Board and Ministry of Education and todevelop options for and advise on (a) a plan to support current work by the Trust Boardto ensure high quality provision by Kohanga Reo; (b) a joint sustainability plan; and (c)a review of Kohanga Reo funding .16 It was not intended to be a review of the TrustBoard itself. In any event, that working group failed to furnish a final report in line withits reporting timetable.17

    28. The Taskforce also recommended that the current Tripartite Review be completedimmediately.18 However, that finding failed to take into account the fact that since itsinception, the Tripartite relationship had been dysfunctional and had failed to make anyprogress at all , despite numerous attempts by the Trust Board to re-establish thatprocess. In fact, the Waitangi Tribunal itself recently said :

    99 . .. we do note that the parties acknowledge that meetings have taken place pursuant tothe Tripartite Agreement since 2008 and no progress has been made on establishingsomething as basic as an understanding of the Trust's kaupapa. This suggests that theTripartite Relationship with the Crown is bordering on dysfunctional. . .

    13 Page 145 of the Report.14 Page 146 of the Report.15 Page 145-146 of the Report.16 Terms of Reference, Kohanga Reo Funding, Quality and Sustainability Working Group, page 1.17 See Terms of Reference, Deliverables, page 4.18 Recommendation 46, page 135 of the Report ; page 146 of the Report.

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    100. In our view such a process is unlikely to result in any effective remedy given the state ofI t. h" 19rea 1ons 1ps.

    Lack of probative evidence fo r key findings29. In its summary of recommendations, the Taskforce states that there is a need for :20

    ...an immediate focus on system quality and the effective use of government funds andeffective use of government spending. This includes...

    o Strengthening quality measures for home-based services, education and care forMokopuna under two years of age, group sizes, and accountability measures forKohanga Reo.

    [Emphasis added]30 . This finding resonates throughout the Report. 21 The Trust Board has identified no

    evidential basis in the Report or the submissions to the Taskforce that mentionKohanga Reo for that finding.

    31. The Taskforce appears to rely on the number of supplementary Education ReviewOffice (ERO) reviews received by Kohanga Reo, which it states is one indicator of poorquality.22 The Taskforce appears to have placed disproportionate weight on thisindicator. The Trust Board has many concerns regarding the ERO process andwhether many supplementary reviews received by Kohanga Reo were, in fact,warranted. The Trust Board's concerns are set out in detail below.23

    32 . As stated above, the Taskforce did not take into consideration what quality means forKohanga Reo, which is not an ECE service.

    33 . Similarly, the Trust Board has not been able to pinpoint any foundation for theTaskforce's pejorative questioning of whether the Trust Board is a key barrier orcontributor to the Kohanga Reo movement.Consequences fo r the Kohanga Reo movement and the Trust Board

    34. Kohanga Reo and the Trust Board have suffered substantial and irreversible prejudiceas a consequence of these failings of the Taskforce and the publication of the Report.

    35. In particular, the Report and subsequent comments made by Taskforce members haveresulted in reputational damage that risks future enrolments at Kohanga Reo.

    36. This will, in turn, accelerate the decline in the number of Mokopuna acquiring fluency inte Reo Maori, since that is directly linked to the numbers participating in Kohanga Reo.

    37. In addition, the Trust Board is concerned that the Crown will implement reforms basedon the Taskforce's ill -informed recommendations - further assimilating Kohanga Reointo the ECE framework and undermining their ability to operate according to theirkaupapa and tikanga. The Crown has already taken actions and decisions, followingthe ECE Taskforce Report, to:

    19 Decision on an Application for Urgency of Deputy Chief Judge C L Fox, Presiding Officer, the Hon Sir Douglas Kiddand Mr Kihi Ngatai , QSM, Wai 2336, #2.5.13, paras 99-100.20 Page 32 of the Report.21 See, for example, pages 36, 57 , 58, 82, 134, 146 and 148 of the Report .22 See Report, page 58.23 See paragraphs 52-64 of the Trust Board's response for the problems with ERO reviews and Kohanga Reo .

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    (a) Focus on three issues (improving ECE services, ECE for Mokopuna under twoand transition from ECE to school) arising out of the ECE Taskforce Report andestablish an advisory group on each of those issues. Two of those advisorygroups begin work next month ;

    (b) Review the ECE curriculum, Te Whariki, as recommended by the ECETaskforce; and

    (c) Develop a new funding system , as recommended by the ECE Taskforce.38. We can only hope that our comments go some way towards correcting comments and

    errors made by the Taskforce and therefore prevent further damage being done to thetaonga that are Kohanga Reo.

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    PART ONE: THE ROLE OF GOVERNMENT IN EARLY CHILDHOOD EDUCATION

    Approach - Page 17

    Alongside this process we also sought and received further ongoing comment and feedbackfrom these submitters and many others; in particular, individuals and groups who preferred tocommunicate orally rather than in writing. We also undertook field visits to selected earlvchildhood education services and met with various sector stakeholders.All of these sources of information and advice, along with the considerable breadth ofknowledge and experience of our members, and many vigorous discussions, were vital inhelping us answer many of our questions. We have been able to reach evidence-basedconclusions about what kinds of improvements and changes are needed to redesign keyaspects of early childhood education policy and services.[Emphasis added]

    39. The Trust Board is an expert on Kohanga Reo, an interested party in the Report, andthe Report contains adverse findings in relation to the Trust Board and Kohanga Reo.But the Taskforce did not seek comment and/or feedback from the Trust Board , eventhough the Trust Board was promised that it would be consulted.

    40 . For the following reasons, we do not agree that the conclusions made in the Reportabout Kohanga Reo and the Trust Board are "evidence-based conclusions":(a) The Trust Board and Kohanga Reo were not consulted;(b) There is nothing in the Report to tell us whether the Taskforce consulted an

    adequate range of resources, including expert advice, so that it fully understoodthe Kohanga Reo kaupapa and role of the Trust Board. The Bibliography for theReport (Report, page 169) references little which would provide the Taskforcewith detail in relation to the history, nature and purpose of Kohanga and itskaupapa or the quality of Kohanga Reo; and

    (c) None of the submissions released to the Trust Board under the OfficialInformation Act 1982 that mention Kohanga Reo contain any criticism of theirquality or the accountability of the Trust Board. To the contrary, they suggestthat Kohanga Reo should be better funded , or subject to more flexible regulatoryrequirements.

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    Our Recommendations -Page 32An immediate focus on system quality and the effective use of government spending. Thisincludes:

    strengthening qualitv measures for home-based services, education andcare for Mokopuna under two years of age, group sizes, and accountabilitymeasures for Kohanga Reo

    reduced tolerance for variability and under-performing services - intensivesupport followed by decisive action for services receiving supplementaryEROreviews

    The Rationale for Sequencing- Page 35Phase one will focus on immediate quality improvements . These do not need to be costly tothe Government. but we consider them to be urgent to safeguard Mokopuna's welfare and toensure the sector is performing how it should. Important actions from this phase will also bethe establishment of support mechanisms for Maori and Pasifika early childhood educationservices. This phase will also include some immediate regulatory change.Figure 7: The Change Process: phased recommendations- Page 36

    Phase 1 Start Work, Focus on Immediate Quali ty MeasuresWork with Kohanga Reo

    [Emphasis added]41 . The Report suggests that phase one will focus on immediate quality improvements,

    which the Taskforce considers urgent to safeguard Mokopuna's welfare. It is clear fromFigure 7 on page 36 of the Report that this is a reference to Kohanga Reo, as KohangaReo are the only institution referred to by name.

    42. Having regard to subsequent comments made in the Report about the high rate ofsupplementary ERO reviews for Kohanga Reo, it appears that the recommendationthat there should be a "reduced tolerance for variability and under-performing services- intensive support followed by decisive action for services receiving supplementaryERO reviews" relates to Kohanga Reo. The Trust Board does not agree with thisrecommendation given its comments in relation to supplementary ERO reviews, as towhich see paragraphs 52 to 64 below.

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    PART TWO: MAKING CHANGE HAPPEN: ELEVEN ESSAYS IN POLICY DESIGN

    ESSAY ON POLICY DESIGN 1: AIMING FOR HIGH-QUALITY SERVICES

    Abstract - Page 40

    Long-term outcomes for Mokopuna can include attainment of higher levels of education, moreemployment opportunities and higher incomes, more stable relationships and reduced crimeand welfare use. These benefits onlv result from participation in qualitv early childhoodeducation. Experiencing poor-quality early childhood education can have negative effects onMokopuna. Quality is a multi-faceted concept that describes those inputs that can causepositive outcomes. It is most likely to occur when early childhood education services connectfamilies with staff who are adequately qualified and view themselves as professionals, and whowork in settings enjoying good governance and management.[Emphasis added]Figure 2 - Domains of nfluence and outcomes of early childhood education - page 49CultureResponsiveness to culture and variation in outcomes across ethnic groups

    For Maori students, the relationship between teacher and student is the most important thing.[Emphasis added]

    43. We do not agree that long-term outcomes for Mokopuna only result from participation inquality ECE. Kohanga Reo are not an ECE service, but have experienced widesuccess in developing whanau and mokopuna as a whole, together with revitalising thelanguage and culture. This is what the movement was intended to do

    44. Throughout the Report, the Taskforce focuses on "quality ECE".24 It does not considerthe nature and purpose of Kohanga Reo and its kaupapa and a suitable qualityframework for Kohanga Reo. 25

    45. The Report focuses on qualified teachers in considering what is a quality ECEservice.26 This focus reflects an entirely different world view and detracts from thenature and purpose of Kohanga Reo and their kaupapa. For example, collectiveresponsibility, whanau development and the value of kaumatua. Kaumatua are expertsas recognised repositories of cultural knowledge and do not require ECE qualifications.

    24 See pages 2-6, 40-42 and 55-58 for examples.25 Discussed above at paragraphs 11 to 16 and below at paragraphs 59 to 64.26 Pages 40-49.

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    ESSAY ON POLICY DESIGN 2: REPRIORITISING GOVERNMENT EXPENDITURE

    Some Kohanga Reo -Page 57Te Kohanga Reo is the largest and oldest Maori immersion early childhood educationinstitution in New Zealand. The first Kohanga Reo was established in 1982. Te Kohanga Reois different to other Maori immersion earlv childhood education settings in that it has asignificant national governance structure, called Te Kohanga Reo National Trust. Of the 472 teReo Maori immersion services. 463 operate within Te Kohanga Reo National Trust.The ECE Taskforce wants to acknowledge the incredible contribution Te Kohanga Reo hasmade to Maori immersion early childhood education. The mission of Te Kohanga ReoNational Trust is the protection of te Reo, nga tikanga me nga ahuatanga Maori by targetingthe participation of mokopuna and whanau into the Kohanga Reo movement and its vision is tototally immerse Kohanga mokopuna in te Reo, nga tikanga me nga ahuatanga Maori. Weunequivocally acknowledge the phenomenal achievements of Kohanga Reo in relation towhanau development and Maori language revitalisation. As we see it, there are also somerealities that need to be urgently addressed - in particular the steady decline of Kohanga Reoenrolments and the disproportionate number of supplementary ERO reviews of Kohanga Reo.Figure 5 shows that Kohanga Reo enrolments have not increased as most other service types'enrolments have, but rather, have slightly declined.[Emphasis added]

    46. It is incorrect to describe K6hanga Reo as the "largest and oldest Maori immersionearly childhood education institution in New Zealand". When the K6hanga movementwas established in 1982, it was established as a whanau development initiative,operating under the former Department of Maori Affa irs, not an ECE service. In 1990,without consultation, all K6hanga Reo were brought within the ECE framework underthe Ministry of Education, despite the fact that the nature and purpose of K6hanga Reoand their kaupapa are inconsistent with that framework.

    47. The description of the Trust Board as a "significant governance structure" fails toacknowledge the Trust Board's important role as kaitiaki of the K6hanga Reo kaupapa.

    48. The Taskforce says that of 472 te Reo Maori immersion services, 463 operate withinthe Trust Board. The Trust Board only represents K6hanga Reo, not te Reo Maoriimmersion services. It is also not clear what date those figures have been taken from.Currently, the Trust Board has 471 K6hanga Reo chartered to it.27

    49 . The Taskforce raises concerns with the steady decline of numbers in K6hanga Reo.The Trust Board has raised those very concerns on many occasions over the course ofa number of years.

    50. However, the Taskforce does not appear to have taken any steps to evaluate thereasons for that decline. It is not clear whether the Taskforce is implying that this mayhave something to do with the quality of K6hanga Reo and/or the Trust Board.

    51. The Trust Board has raised concerns that a major contributor for the decline is thekaupapa of K6hanga Reo not being adequately supported and being forced to

    27 Trust Board data as at 1 November 2011 .

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    assimilate within the ECE framework. Kohanga Reo therefore have to meetrequirements for ECE services rather than being allowed to operate on the basis oftheir own kaupapa. We also refer to our comments at paragraphs 11 to 16 above.

    Page 58One indicator of low-quality services is a supplementary review from ERO. Once ERO hasundertaken a regular review of a service on its three-year cycle, it may choose to undertake asupplementary review, usually around a year later. A supplementary review is undertaken atthe discretion of a National Manager in ERO. A supplementary review evaluates the extentand effectiveness of actions a service has taken towards addressing issues specified in aprevious education review and/or any additional areas identified since that review.Supplementary reviews are therefore a possible indicator that a service is suffering from qualitydifficulties in one or more aspects of ts operation.Kohanga Reo have an extremely high rate of supplementary reviews - over a third of al lsettings received them between 2007-2010. Figure 6 notes the percentage of different servicetvpes with supplementary reviews. The dark blue line represents the overall average.

    This is not intended to reflect badly on the Kohanga Reo movement as a whole. There aremany reasons why whanau could struggle. Poor access to appropriate development orresources. lack of funding, and the availability of whanau members. kaumatua or kuia can al limpact on a Kohanga Reo's operation. These are difficult situations, and they must change.But nonetheless, our primary concern has to be for the welfare of the mokopuna in theseKohanga Reo. Government must think seriously about the way it invests in Kohanga Reo.This is discussed further in Essay 4: Achieving Access for All Mokopuna.A dollar figure applied to 34% ofKohanga Reo is around $19m in 2009/2010.

    Page 59Provision of ECE Mokopuna under two years of age

    Low-quality early childhood education is particularly harmful for under two-year-olds, and therecan be long-term poor outcomes when they [sic[ exposed to poor quality which are costly toremediate Oower educational achievement and increased crime. for example). So a proportionof the $268m noted above could potentially be the poorest investment across the earlychildhood education portfolio.[Emphasis added]

    52 . The Trust Board does not agree with the Taskforce's comments in relation to thenumber of supplementary ERO reviews for Kohanga Reo being indicative of poorquality, as:(a) The Trust Board has reviewed all of the supplementary ERO reviews for

    Kohanga Reo from June 2007 to June 2010 and is concerned, for the reasonsset out below, that the grounds upon which many Kohanga Reo were givensupplementary reviews were unfounded and relate to a lack of understanding ofthe Kohanga Reo kaupapa and wider Maori concepts; and

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    (b) The use of ERO reviews cannot accurately measure the quality of K6hanga Reoas it is not an ECE service and ERO does not adequately understand thekaupapa of Kohanga Reo and what quality means for Kohanga Reo.

    Supplementary ERO reviews for the period June 2007-201053. During this period, there were a total of 169 ERO supplementary reviews conducted

    involving 137 Kohanga Reo, which means that a number of Kohanga Reo had morethan one supplementary review during the period . The 169 supplementary reviews canbe broken down into two types: 118 supplementary reviews reported regulatory noncompliance ("Compliance Reviews") and 51 supplementary reviews hadrecommendations only, i.e. they do not raise any issues of regulatory non-compliance("Recommendations Only Reviews").

    54. Accordingly, 30% of Kohanga Reo receiving supplementary reviews during the periodreceived Recommendations Only Reviews. Nearly all Recommendations Only Reviewsrelated to administration and governance (19%); human resources (0.5%); financialmanagement (0.4%); curriculum, management and staffing (30%); and Te Korowai(41%) where the majority of these Te Korowai recommendations stated that 'thekohanga whanau work with their kaupapa kaimahi to address all areas for improvementidentified in this report '.

    55. Kohanga Reo whanau treat this process as a means of self-review and often makesuggestions themselves. For example, in a Supplementary review dated September2010 (IDC09C043 onsite June 2010, Rohe 09) the ERO found that the Kohanga Reohad addressed all of the issues identified in 2009 and commented positively. However,whanau themselves identified professional development of staff and leadership asareas for improvement. ERO accordingly recommended that the whanau work with thekaupapa kaimahi to access professional development and set down anothersupplementary review to monitor progress within 24 months.

    56. The Trust Board considers that, in treating supplementary reviews as an indicator ofpoor quality, the Taskforce has served to undermine this self-review process.

    57. Some examples of misunderstanding the kaupapa of Kohanga Reo and theinadequacy of ERO reviews are set out below:(a) In a Supplementary Review dated September 2010 (ID02F064 onsite May 2010,

    Rohe 002) the Report states "6.3 further develop their strategic direction as aKohanga Reo whanau", even though whanau have Te Ara TOapae, a strategicplan developed by the Kohanga whanau themselves alongside the Trust Board.Another recommendation is "6.4 improve self review practices in order to identifyareas for ongoing development across the Kohanga", even though self review iscarried out each month at whanau hui 28 and also through TOtohinga review.29

    28 Whanau hui are regular formal monthly meetings which all whanau members are encouraged to attend and wheredecisions are made on the management and operation of the Kohanga. At the hui, the Administrator/Secretary willprovide previous minutes and the AdministratorfTreasurer will provide Financial Reports for previous months and/orforward-looking plans for whanau approval of budgets. Kaiako/Kaiawhina will give a report on the activities ofmokopuna for the previous month and what they intend to do the following month .29 TOtohinga Review involves a review of the Charter between a Kohanga and the Trust Board, and a reaffirmationof the whanau's commitment to the kaupapa . The norm is to review different parts of the TOtohinga (or charter) so

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    (b) Many of the "non-compliance" issues in Compliance Reviews relate to aninconsistency between the regulatory framework and the kaupapa of KohangaReo. For example, in relation to a marae-based Kohanga Reo that has beenoperating for 28 years, in a Supplementary Review (2007, 1001 E047, Rohe 01)non-compliance was cited due to "R32 ECC Regs 1998 - plan a range ofactivities that cater for the learning and developmental needs of Mokopuna"(page 23). Yet, in the same report it stated:

    Mokopuna have a strong sense of belonging and identity and are secure in anenvironment that upholds the teachings of their ancestors. Mokopuna are ableto identify landmarks that are of spiritual significance to the ... region throughpepeha, waiata and whakapapa. Routines and tikanga for eating, toileting,sleeping and hand washing are well established and managed . Mokopuna arelearning about positive social behaviour and enjoy the structured way in whichroutines flow. (Page 16)

    (c) Individual ERO reviewers seem unable to reconcile the purpose of the reviewwith the kaupapa of Kohanga Reo. The Trust Board has attempted to work withERO so that they understand the kaupapa of Kohanga Reo, but it is clear to theTrust Board that they are ill-equipped or often fail to have the expertise todetermine the ''fitness" of Kohanga Reo. In this respect, we note that, based onthe Trust Board's experience, very few ERO officers are fluent te Reo Maorispeakers.

    (d) The ERO has identified a number of "poor quality indicators" that unfairlyimplicate good practice at Kohanga Reo. For example, ERO states that "rotelearning methods", "rigidly implemented routines" and "interactions that directand control Mokopuna" are all indicators of poor quality.30 Models of learning inKohanga Reo that support the acquisition of te Reo Maori and the involvement ofwhanau frequently involve repetition and routine -language , history, waiata, forexample.

    58 . Had our reasonable expectation of consultation been met, we would have had theopportunity to avail the Taskforce of these details . However, we were not afforded thatopportunity before the Report was published.Quality of Kohanga Reo

    59. The use of ERO supplementary reviews is not a full and accurate measure of quality ofKohanga Reo. Over the years, the Trust Board has raised many concerns with theERO process itself and ERO's inability to adequately assess and review Kohanga Reoupon its own quality criteria, rather than those of an ECE service. Specifically:(a) They do not take into account the unique and holistic approach taken by the

    Trust Board and Kohanga Reo;(b) They generally focus on the implementation of the Ministry's ECE curriculum, Te

    Whariki;

    that over a 1 or 2 year period , the whanau will have fully reviewed their TOtohinga. The updated TOtohinga issubmitted to District Managers and is ultimately approved by the Trust Board at one of its bi-monthly meetings.30 Ed ucation Review Office, Quality in Early Childhood Services, 1 August 2010, at page 5.

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    (c) The majority of the sector they deal with do not use te Reo Maori as the onlylanguage of instruction, as is the case for Kohanga Reo; and

    (d) ERO does not have the expertise to adequately assess matters such as the useof te Reo and tikanga Maori within Kohanga Reo.

    60 . The four broad criteria that the Trust Board uses for measuring the quality of KohangaReo are very different from an ECE framework, as follows:(a) Total immersion in te Reo Maori and tikanga Maori;(b) Management and decision-making by whanau;(c) Accountability to the Creator, mokopuna, Kohanga Reo and whanau; and(d) Commitment to the health and well-being of mokopuna and whanau.

    61 . Had the Trust Board been consulted it could have advised the Taskforce in relation to aquality framework for Kohanga Reo.

    62 . The Report infers that there are welfare concerns for mokopuna due to the highnumber of ERO supplementary reviews, and that there is a lack of quality oraccountability in terms of the Trust Board . However, the Taskforce chose not to obtainthe Trust Board's view on these issues, nor did they identify or address thefundamental issues the Trust Board has with the process for ERO reviews . Contrary tothe Taskforce's comments, the welfare of mokopuna in Kohanga Reo is a primaryconcern of Kohanga Reo and the Trust Board, as set out above in relation to qualitycriteria for Kohanga Reo.

    63. The Report says that spending on poor-quality early childhood education is a badinvestment.31 Given the comments made by the Taskforce above, Kohanga Reoappear to be placed in that category. Again, that finding was made without consultingthe Trust Board or obtaining a proper understanding of the issues faced by KohangaReo in relation to ERO reviews.

    64. The Trust Board is not suggesting that Kohanga Reo should not be subject to reviews,just that such reviews ought to be specific to the nature and purpose of Kohanga Reoand their kaupapa, not ECE Regulations developed within a different culturalframework.

    3 1 Report at page 56 , penultimate paragraph; page 59 , second paragraph.

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    ESSAY ON POLICY DESIGN 4: ACHIEVING ACCESS FOR ALL MOKOPUNA

    Recommendations - Page 82

    19. work is undertaken with Maori and Pasifika communities to determine ways to providean over-arching governance and management support structure in Maori immersionearly childhood education settings and Pasifika language settings.

    65. As above, Kohanga Reo are not "Maori immersion early childhood education settings".The Trust Board is kaitiaki for Kohanga Reo, and it is for Kohanga Reo whanau todetermine the overarching governance and management support structure, not theTaskforce.

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    ESSAY ON POLICY DESIGN 9: IMPROVING LICENSING PROCESSES ANDPERFORMANCE REPORTING

    Abstract - Page 134The current review of Te Kohanga Reo National Trust should be completed and earlierrecommendations implemented.Recommendations - Page 13446. the current Tripartite Review by Te Kohanga Reo National Trust, Te Puni Kokiri and the

    Ministry of Education is completed47. the recommendations ofthe Gallen Report (2001) and the Pricewaterhouse Cooper's Report

    (2006) on Te Kohanga Reo National Trust are revisited, and where appropriate implemented48. Te Kohanga Reo National Trust's reporting and compliance requirements become the same

    as those required of other earlv childhood education service[Emphasis added]

    66. Contrary to what the Taskforce has noted above, the Tripartite process between theMinistry of Education, Te Puni Kokiri and the Trust Board did not include a review of theTrust Board itself and its governance. The Tripartite process was supposed to beabout how the parties could together take measures to ensure the ongoingsustainability of Kohanga Reo and that Kohanga Reo received appropriate fundingrecognising the nature and purpose of Kohanga Reo and their kaupapa.

    67. The Taskforce is not a party to the Tripartite Relationship Agreement and the TrustBoard does not understand why the Taskforce has chosen to comment on the Tripartiteprocess. Very little eventuated from the Tripartite relationship, so the Trust Boardcannot understand why the Taskforce suggested this mechanism. In any event, it isclear that the Taskforce did not obtain enough information to accurately report on theTripartite Relationship Agreement.

    68. The Trust Board is not saying that it does not need to be subject to any accountabilitymeasures. Rather, it is saying that such measures should not be aligned to those ofECE services, as Kohanga Reo are not an ECE service.

    69. There can be no suggestion that the Trust Board does not account appropriately. Ithas never had a qualified audit report. The Ministry of Education even commissioned acastings review of the Trust Board, the Pricewaterhouse Coopers' review (seeparagraphs 80 to 81 below). That review showed that the costs incurred by the TrustBoard were reasonable and its record keeping processes robust. In fact, the onesubmission received by the Taskforce that mentions the accountability of Kohanga Reostates thae2

    32 Submission 30 to the ECE Taskforce dated 8 December 2010, released to the Trust Board under the OfficialInformation Act 1982 on 9 November 2011.

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    Nga Kohanga Reo have always had strict guidelines with their spending and have loads ofpaperwork before their funding is released why haven't the MOE centres[?]

    70. The Trust Board, as kaitiaki of K6hanga Reo and kaupapa, is also accountable toK6hanga Reo whanau.

    71. The purpose of the Trust Board is to protect the K6hanga Reo kaupapa. Making theTrust Board's reporting and compliance requirements the same as those of other ECEservices would undermine the role of the Trust Board as kaitiaki, whanau management,value of kaumatua and the kaupapa of K6hanga Reo.

    72 . The Trust Board's comments in relation to implementing the recommendations of theGalien report and Pricewaterhouse Coopers' report are dealt with below alongsidespecific comments in the Report related to those issues.Te Kohanga Reo- Page 145As we have mentioned in Essay 4: Achieving Access for all Mokopuna we unequivocallyacknowledge the phenomenal achievements of Kohanga Reo in relation to whanau developmentand Maori language revitalisation. Having said that, the disproportionate number ofsupplementary ERO reviews of Kohanga Reo suggest concerns must be addressed.[Emphasis added]

    73. See the Trust Board 's comments above at paragraphs 46 to 56.

    Te Kohanga Reo National Trust Reviews- page 145The Gal/en report resulted from a working group set up by the Minister in 2001 in response to arequest from the Trust for a direct relationship with the Crown. The Working Grouprecommended:

    A tripartite relationship agreement be drawn up between the Trust, theMinistry of Education and Te Puni Kokiri, to enhance the Trust's currentrelationship with Government.

    That the Trust allow Kohanga Reo to receive capital funding through theTrust from the Ministry of Education's Discretionary Grants Scheme withoutincurring repayments by them to the Trust. and that the Government agreesto a process to support future funding commitments previously met by theProperty Putea including. specificallv. funding for Te Arahiko. MaoriLanguage Training. Resource Development and Research.

    Devolution of Kohanga from the Trust to iwi within five years. facilitated bythe Ministry of Education and Te Puni Kokiri.

    Support for the Trust to redefine its future role was to include professional development,curriculum development, advocacy and professional leadership. The first two recommendationswere actioned. but the third was not.[Emphasis added]

    74. The second recommendation of the Galien report was not actioned .75. From 1982-1989, there was no capital funding provided to K6hanga Reo until the

    Ministry of Education required "approved" buildings that were aligned to ECErequirements.

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    76. The initial capital funding received by K6hanga Reo was termed "discretionary grantsor loans" (1990) and this led to the establishment of the Property POtea scheme by theTrust Board. This scheme was mandated by K6hanga Reo nationally to generatefunds for K6hanga Reo developments around computers, training, staffing, resources,health and whanau assistance where government funding was not available. TheGovernment then disestablished the Property POtea scheme following the Galienreport. On cessation of the scheme, the Trust Board had been led to believe thatK6hanga Reo would have funding set aside to compensate what the Trust Board hadlost through the disestablishment of the Property Putea scheme.

    77 . The Trust Board received no additional monies to support the establishment of newK6hanga Reo. K6hanga Reo were then forced into the contestable round with all ECEproviders and received no special consideration. The Trust Board has not receivedany funding for computers or resource development to date.

    78. Further, the Galien report's recommendation to devolve K6hanga Reo from the TrustBoard to iwi within five years was not for the Taskforce to comment on. That issue isfor K6hanga Reo whanau to decide and involves a discussion between Te K6hangaReo whanau, lwi and The Trust Board 's mandate comes from the K6hanga Reowhanau throughout Aotearoa

    79 . Since the Galien report, the Trust Board has revisited the devolution idea a number oftimes with K6hanga Reo whanau nationally. Under Article 2 of the Treaty of Waitangi,Maori are guaranteed the right to exercise tina rangatiratanga over taonga Maori,including K6hanga Reo . Accordingly, it is for K6hanga Reo whanau to determinewhether K6hanga Reo should be devolved and, if so , the timeframe and process forany devolution. It is not a matter for the Taskforce to comment on .

    Page 145-146In 2006, the Ministry of Education commissioned Pricewaterhouse Coopers to undertake acastings review of the Trust. The review found that the costs incurred by the Trust werereasonable when compared to similar organisations in the non-government organisation sectorand the record keeping processes were reasonably robust. The recommendations of that reviewextended to the relationship between the Ministry, the Trust and Kohanga Reo, and suggested afacilitated forum to discuss the issues raised in the report. The suggested next steps were:

    an examination of the funding and expenditure of the Trust. in the light of theearlv childhood education sector. the Ministrv's goals. the philosophies of theTrust and the Kohanga Reo movement and the wider socio-economicenvironment; to include a comparison with other parts of the earlv childhoodeducation sector.

    A Tripartite Review of funding, quality and sustainability of Kohanga Reo (by Te Kohanga ReoNational Trust, Te Puni Kokiri and the Ministry of Education) was established in September 2008and was to have completed its report by June 2009. However, recommendations are yet to beproduced. We understand that the remaining recommendations of the Price waterhouse Coopersreview are now part of this Tripartite Review process.[Emphasis added]

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    80. The Trust Board notes that the Pricewaterhouse Coopers' review found that the TrustBoard 's costs were reasonable and robust. The review also found that the Trust Boardwas under-funded for the provision of front line operational support and advice toKohanga Reo. This has not been adjusted in the past 14 years and the Trust Boardcontinues to operate on the same level of resourcing that the Ministry set for it in 1997.

    81. As already noted above, the remaining recommendations of the PricewaterhouseCoopers' review, i.e. a review of the Trust Board itself, was not part of the TripartiteWorking Group process. That was never agreed between the Tripartite parties to bewithin the scope of the Tripartite work.

    Page 146It appears that the te Kohanga Reo movement has, for some time, been viewed as too hot apolitical issue to touch. Added to this, any scrutiny of the institution is difficult because the TeKohanga Reo National Trust strongly objects to what it views as any attempt to diminish itsautonomy. However, while some Kohanga Reo are providing exceptional Maori immersion earlychildhood education, the issues outlined in Essay 2: Reprioritising Government Expenditure raisequestions about consistent quality early childhood education provision , and national bodyleadership for all Mokopuna who attend Kohanga Reo, and whether the Trust is a key barrier orcontributor to the original aspiration of the movement.Political sensitivities in any guise should never trump the safety and well-being of Mokopuna. 6lack of progress in the area of ensuring quality early childhood education provision, targetedsupport and guidance from Kohanga Reo is of great concern to the ECE Taskforce . We discussour view of the nature of quality in Essay 1: Aiming for High-Quality Services. We believemeaningful change is overdue and must be addressed. We need to do whatever it takes for allMokopuna to have access to quality early childhood education in the form that is mostappropriate for them and their community. That is their right.Therefore, we recommend the current Tripartite Review be completed immediatelv. and that thequality of initial teacher training should be added to the Tripartite Review. We a/so think that TeKohanga Reo National Trust's reporting and compliance requirements should be aligned withthose required in other early childhood education settings.We also believe that the recommendations of the Gallen Report (2001) and thePricewaterhouseCoopers Report (2006) on Te Kohanga Reo National Trust should be revisitedand where appropriate, implemented.[Emphasis added]

    82 . The Trust Board and Kohanga whanau was alarmed to read the comments in theReport above, which are without foundation . The Taskforce did not attack any otherorganisation in such a direct matter yet it chose to target the Trust Board and KohangaReo without seeking the Trust Board 's or K6hanga whanau views prior to publication .The Trust Board considers those findings and comments extremely inappropriate, forthe following reasons:(a) The Taskforce suggests that the Trust Board is self-interested. The Trust Board

    refutes that implication. The Trust Board acts upon the mandate of K6hangaReo whanau and, as long as it has the mandate of K6hanga whanau , it willcontinue to represent them to the best of its ability to protect the Kohanga Reokaupapa. It is disappointing that the Taskforce chose to interpret the Trust

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    Board's role in the way that it did. Again, it conveys a lack of understandingabout the role of the Trust Board, as kaitiaki;

    (b) The Taskforce questions consistent and quality ECE provision and national bodyleadership for Mokopuna attending Kohanga Reo. However, Kohanga Reo arenot an ECE service nor should they strive to meet quality requirements of anECE service, which undermines the nature and kaupapa of Kohanga Reo. TheTrust Board is not "a key barrier" to the Kohanga Reo movement and afterdecades of working to promote the Kohanga Reo kaupapa, it was offended tosee this suggestion published without any grounds to support it. Rather, theTrust Board has been instrumental in ensuring the survival of the Kohanga Reokaupapa;

    (c) Further, the Taskforce says that a lack of progress in targeted support andassistance for Kohanga Reo is of great concern. It fails to provide any detailabout this or say whether it might be due to the fact that the Trust Board hasbeen underfunded for the provision of front line operational staff and advice toKohanga Reo, as found by the Pricewaterhouse Coopers' report. As part of itsrole, the Trust Board provides support and assistance to Kohanga Reo whanau,but was not consulted about this;

    (d) As set out already above, the Tripartite Review was not about a review of theTrust Board . The Taskforce is not a party to the Tripartite RelationshipAgreement and it was not its place to comment on that work or to suggestmatters which should be added to that work; and

    (e) Again, suggesting that the Trust Board's reporting and compliance requirementsbe aligned with ECE services fails to recognise the role of the Trust Board askaitiaki and the nature and purpose of Kohanga Reo and their kaupapa.

    83. The recommendations of the Galien report and Pricewaterhouse Cooper's report havealready been dealt with above.

    Cost Considerations -page 148Amending licensing categories and regular review of regulations can be met within the businessas-usual activities of the Ministrv of Education, as can completion of the review of Te KohangaReo National Trust.[Emphasis added]

    84. This is incorrect. Again, the Tripartite did not include a review of the Trust Board and itis not the Taskforce's place to suggest otherwise.

    85. Completion of the Tripartite Working Group cannot be met within "business-as-usualactivities of the Ministry of Education". The Tripartite Working Group did not result inany meaningful progress.

    The Change Process- page 148

    In phase one of our chanae orocess, we urge that all immediate concerns with quality areaddressed. Therefore, reviewing the quality of early childhood education in the home-based part

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    of the sector that for under two-year aids, and accountability of the Te Kohanga Reo NationalTrust should begin as soon as practicable . This may result in regulatory change. We anticipatethat parts of this change may create tension within the sector.Phase one should include the establishment of support mechanisms for Maori and Pasifika earlychildhood education services; support for any service receiving an ERO supplementary review;the completion of the Tripartite Review of Te Kohanga Reo National Trust; the revisiting of thisreview along with previous reviews and an alignment of Te Kohanga Reo National Trust'sreporting and compliance requirements with those required of other earlv childhood educationsettings.Phase one should also include the design of a comprehensive Maori professional developmentand high qualitv advice and guidance programme, by both internal and external providers forKohanga Reo. This process must also include evaluation of the quality of the advice andguidance provided.

    86. See the Trust Board's comments above.

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    APPENDIX 1: TERMS OF REFERENCE

    Role and Scope - Page 176The role of the Taskforce will be to:

    a. undertake a full review of the value gained from the different types ofgovernment investment in early childhood education in New Zealand.

    b. consider the efficiency and effectiveness of Government's current earlychildhood education expenditure, and ways that this might be improved,particularly for Maori, Pasifika, and Mokopuna from low socio-economicbackgrounds

    87. The Trust Board does not agree that Kohanga Reo should be defined as an ECEprovider. However, we believe that the scope of the terms of reference required theTaskforce to undertake a full and robust review of the value gained from Kohanga Reoincluding its history and kaupapa.

    88. As already mentioned above, the Report refers to Kohanga Reo as " .. the largest andoldest Maori immersion early childhood education institution in New Zealand . The firstKohanga Reo was established in 1982" (page 57). That does not adequately reflectthe history and value of Kohanga Reo. At its peak, in 1993, there were 809 KohangaReo that chartered to the Trust for the Kohanga Reo kaupapa, with 14,514 mokopuna.There were 471 Kohanga Reo chartered to The Trust Board, with 9,364 mokopuna asat 1 June 2011 when the Taskforce report was released.

    89. In Wai 262, the Tribunal noted the decline in numbers of Kohanga Reo and Maoriparticipation: 33

    Two clear conclusions can be drawn from these figures. The first is that the revival ofthe Maori language can succeed through programmes of Maori language educationfor Mokopuna. The second is that by the turn of the millennium there was strongevidence that this strategy had stopped working.

    90. Since Kohanga Reo was brought within the ECE regulatory framework, there has beena steady decline in both numbers of Kohanga and numbers of mokopuna. Whatstarted out as a development initiative by Maori people for Maori people has beendriven to conform to an early childhood education model. Policies have beencontinually adopted which deny the kaupapa of Kohanga Reo and tino rangatiratanga.Kohanga Reo is not an ECE service. It is the revitalisation of Maori language, customs,culture within a cultural framework of whanau .

    91 . There is no evidence in the Report demonstrating that the Taskforce understood andrecognised the Kohanga Reo kaupapa.

    92. The Taskforce also failed to adequately describe or analyse:33 Taumata Tuatahi, at p 161.

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    (a) The disparity in funding for Kohanga Reo;(b) The rationale for Kohanga Reo receiving a lower level of funding than other

    education providers referred to in the Report - the Trust Board notes in thisregard that the inequity of funding for Kohanga Reo based on the distinctionbetween "teacher-led" and "whanau-led" centres was raised in two individualsubmissions;34 and

    (c) The negative impact of the disparity in funding on Kohanga Reo and its kaupapa.93. The Taskforce also restated findings from the Galien report (2001) and the

    Pricewaterhouse Coopers' Review (2006). However, it did not undertake any analysisof the findings of those reports nor is there evidence that they undertook any review ofthe value that Kohanga Reo adds.

    94. An example of the Taskforce not undertaking a full review includes the weight that theTaskforce placed on the ERO supplementary reviews as an indication of poor quality ofKohanga Reo.

    95. The Taskforce does not appear to have given consideration, as a possible reason forsupplementary reviews, to the finding of the Pricewaterhouse Coopers' review that theTrust Board was under-funded for the provision of front line operational support andadvice to Kohanga Reo.

    96. The Taskforce also had a responsibility to review and analyse whether there were anyother quality frameworks that could indicate the quality of services for Kohanga Reo.The Trust Board does not believe that Kohanga Reo should have its quality measuredby a quality framework that was developed for early childhood centres. Rather, webelieve that Kohanga Reo should have a recognised quality framework to measurequality and performance that reflects the kaupapa of Kohanga Reo. As identified atparagraph 59 - 64 above, the Trust Board could have provided information to theTaskforce about a quality framework.

    97. The Taskforce should have provided analysis on how quality at Kohanga Reo can beeffectively measured. Instead, it relied on a process undertaken by ERO that gives norecognition to the kaupapa of Kohanga Reo.

    Page 177The Taskforce should consider how this system contributes to education success in schoolingand later life. It should also be mindful of Government's objectives around education success forMaori and Pasifika learners, the status of Ka Hikatia - Managing for Success and the PasifikaEducation Plan as key strategies for these populations, and the prime importance of provisionwhich recognises language, culture and identity as key for increasing participation in earlychildhood education and improving learner outcomes.

    98. The Trust Board does not believe that the Taskforce could consider matters oflanguage, culture and identity without first considering the Trust Board's position askaitiaki of the Kohanga Reo kaupapa, the role of whanau in kohanga reo and the valueof Kaumatua in fostering te Reo Maori as a living language. The Taskforce did not

    34 Submission 260 to the ECE Taskforce dated 22 December 2010 and Submission 311 to the ECE Taskforce dated30 January 2011 , released to the Trust Board under the Official Information Act 1982 on 9 November 2011 .

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    consider these matters. Nor did it consider the role of whanau development which iskey to increasing educational success and participation by our people.

    Process - Page 177The Taskforce will meet to consider preparation of a report covering the areas above, to bemade available in April 2011 . To support this goal, it may wish to :a. consider information about the current funding and policy settings for early childhood

    education in New Zealandb. consider current data on early childhood education in New Zealand, and national and

    international early childhood education researchc. hear evidence from experts and interested parties. andd. conduct visits and fact-finding activities.Responsibility ofMembersMembersa. must act in the interests ofall stakeholders including Mokopuna and parentsb. should not represent any particular organisation or voice.Members of the Taskforce will provide a breadth of perspectives . ..[Emphasis added]

    99. Given the findings and comments of the Taskforce, the Trust Board and Kohanga Reowere interested parties and stakeholders in the Report but were not consulted or giventhe opportunity to address the adverse comments made about Kohanga Reo and theTrust Board. The Taskforce could have taken steps to hear evidence from KohangaReo experts and the Trust Board, visit the Trust Board or conduct fact-finding activities ,but chose not to do so.

    Takuta TTmoti KaretuCo-Chairperson

    Te Kohanga National Trust Board20 December 2011

    Tina Olsen-RatanaCo-Chairperson