Submissions

To: Ministry for Regulation
Date: August 2024

Purpose

This submission’s primary purpose is to strongly oppose wholesale deregulation of the Early Childhood Education (ECE) sector, arguing that such a move would negatively impact disabled children by compromising safety, accessibility, and quality learning environments. DPA aims to ensure that the government upholds its commitments under the UNCRPD, New Zealand Disability Strategy, and Te Tiriti o Waitangi regarding the inclusive education of disabled children.

Summary of DPA submission

DPA supports the rights of families/whānau of disabled children to choose early education options that best suit their child’s needs for an inclusive education. DPA notes that the core ECE curriculum, Te Whāriki (2017), has a more inclusive focus on disabled tamariki, and that inclusive practices are best delivered by qualified teachers. DPA supports the current regulatory settings in ECE, believing they are working to deliver safe, quality learning environments for both disabled and non-disabled children.
 
However, DPA is concerned about any moves that would compromise providing safe, accessible, and quality learning requirements, even if they increase choice for some families. DPA specifically states that the way to resolve issues faced by the ECE sector is not through wholesale deregulation, as this would disadvantage and greatly harm disabled children. DPA is alarmed by proposals to weaken existing regulations under various Acts (including Education and Training, Children’s, Health and Safety at Work, Fire and Emergency, Food, and Building Acts) that uphold education quality, child wellbeing, fire safety, food hygiene, and accessible public buildings. DPA believes that deregulation will compromise government commitments to disabled children and their whānau under the UNCRPD, New Zealand Disability Strategy, and Te Tiriti o Waitangi. DPA identifies underfunding as the key problem facing the ECE sector, not over-regulation. Deregulation could lead to inaccessible premises, substandard equipment, untrained educators, and centres "cherry-picking" students, excluding those with significant impairments or charging higher fees for quality care. Such changes could result in poorer educational outcomes, increased risk of abuse, serious injury or death from fires, and exposure to unsafe food for disabled children. Research shows that disabled people (including children) are at a higher risk of death in fires.
 
Key Recommendation:

DPA recommends that the review of ECE be withdrawn and that the sector be funded adequately to meet the demands being placed upon it.
 
Supporting Statement 1:

DPA agrees with the independent Office of Early Childhood Education that Budget 2024 only gave the ECE sector 'crumbs from the Education Table,' with no new funding for pay parity or to keep up with rising teacher salaries in other sectors.
 
Supporting Statement 2:

Full deregulation would not resolve the issues described, nor would it address the fact that some learning centres are physically or environmentally inaccessible for disabled children and their families/whānau.