Afternoon roundup

It's been a busy few days. The tabs, they've accumulated. Some worthies:

• Bans on paying surrogates are a bad idea. 


• California might break the internet. 


• Where Rob Campbell is Chair of Health NZ, do we even still pretend that we have a politically neutral public service?


• BusinessDesk on Effective Altruism in New Zealand. 


• A Newsroom roundup on population and immigration, including a bit on Clive Granger's visa difficulties. If I remember right, they'd figured they had no chance of getting through Immigration New Zealand's points system because of age, so were deterred from applying in the first place rather than being turned down after applying. If anything, that's a worse problem - who knows who else might have been deterred from even trying?


• A suggestion that learning Te Reo will become necessary for getting to the front of the queue for working in the public sector. I do remember those sorts of policies causing no small amount of discord in Western Canada, and being part of what got us the Reform Party. 


• Simeon Brown is not wrong about problems in transport policy.


• If the Rail and Maritime Transport Union is right that "KiwiRail is not going to make a profit, not in my lifetime - and probably never", isn't that an argument for ending the thing?


• Sounds like it's time to flip all vehicles onto RUC, including electrics that currently get a free ride.


• The Building Code is bigger than you thought. 1500 pages, plus 20,000 more web pages and documents. 


• The new Google News showcase is decent. Lots of coverage of regional papers I'd otherwise have missed. 
  
  

OCR and other tools

When Susan Edmunds emailed asking about tools other than OCR for controlling inflation, I asked her whether she was suggesting I say Voldemort repeatedly while hoping for the best. 

There are a lot of bad alternatives, some best not spoken.

First Union suggested taxes on the richest. It's the opposite of where you'd want to target taxes aimed at reducing aggregate demand if you followed Keynesian-style arguments around marginal propensity to consume. Stopped clocks, eh?

I noted that monetary aggregates used to be targeted, but increasing difficulty in defining the targeted aggregates, combined with changes in the velocity of money, pointed to price/inflation targeting rather than money supply targeting. I also noted that the Bank's LVR rules a decade ago seemed most easily explained as an attempt to shave the peaks off of asset price appreciation, but that I didn't think it was a great idea. 

An old Labour idea of having Kiwisaver contributions vary over the business cycle also got play. It never made any darned sense: you require higher contributions at the top of the cycle and lower contributions at the bottom of the cycle: buy when high, and buy less when low, doesn't seem like all that great a default setting for Kiwisaver funds. 

Bad times make people reach for bad ideas, which worsen overall economic conditions...

Public transport and getting what you pay for

Carbon News asked me about the government's proposed shake-up around council public transport options. The government figures having councils run bus services again, rather than contracting out for them, would reduce national net emissions while getting better bus service.

They're nuts. But the union isn't nuts for supporting it. They'll probably do well out of going back to council monopolies. 

But will the plans – which could see most public transport back in public hands after a decade-old experiment in privatisation – deliver the promised reductions in carbon emissions?

The response from the NZ Initiative’s chief economist Eric Crampton is as predictable as it consistent: transport is covered by the ETS and therefore the proposals will make virtually no difference to overall emissions.

“Because transport is covered in the Emissions Trading Scheme, bus operators, whether Council- or privately owned, have plenty of incentive to weigh up whether to provide electric or diesel busses,” Crampton says.

“An all-electric bus fleet would simply free up emission credits for others to purchase and use instead.”

Former IPCC lead author and Massey University emeritus professor of energy and climate mitigation, Ralph Sims, on the other hand, says the ETS has done nothing to encourage public transport use to date and there’s nothing to suggest that it’s likely to have much impact in the future.

Yeah, this is one of those "We're all part of the equilibrium" days. If carbon prices going up to $200/tonne (or whatever it gets to) as the ETS cap drops on the path to net zero doesn't encourage flips to public transit, that is perfectly fine. The cap limits net emissions. It finds the most cost-effective ways of mitigating net emissions. We don't have a public transit maximand, we have a net emissions target. I'd expect, with fuel being maybe $0.30-$0.40 more expensive, some folks would flip to public transit. But the binding cap binds regardless. If they don't, that just means emissions reductions in other spots are more cost effective, so the emission reductions happen there instead.

I swear these people have a billion non-carbon objectives and then damn the ETS for not achieving them. 

And they've fundamentally misdiagnosed the problem, mainly because they just hate private provision through contracting of stuff they think should be provided by government or councils.

And that’s a point of view echoed by the NZ Initiative’s Eric Crampton. 

“People should not get their hopes up that councils taking over bus services will improve outcomes. While there have been obvious deficiencies in service in some places, the problem is not that some bus services are privately owned and operated. The problem rather is that councils have gotten exactly what they have paid for. Councils set contracts with fairly low penalties for missed or cancelled services.

"To win tenders, given council specifications, bus operators ran lean staffing models. Avoiding cancelled services means having enough drivers on staff to provide coverage even if many drivers are out sick or on leave. If Council had wanted fewer missed services, it would have had to set greater penalties for missed services. But it would have had to pay bus operators more to provide the service,” Crampton says.

If there's poor quality service, don't blame the private bus operator. Blame the terms of the tender for service. If council wanted frequent, reliable, non-cancelled, luxury services, they could have contracted for that. But it would have been really expensive. The costs would have been transparent. 

All kinds of worthy-sounding things could have been included in a contract for service:

• Reliable, frequent, non-cancelled services. How? Set a large penalty for missed stops and cancelled services. But the operator would demand to be paid a lot to run the route. A thin staffing model wouldn't have worked.
• Cleaner, more environmentally friendly buses. How? Require that every one of them pass an emissions test (SOx, PM 2.5) every four months (or whatever interval). But the operator would demand to be paid more to run the route, because they might have to upgrade the fleet to meet those requirements. 

Shifting it over to council owner-operators will mean either far higher and more opaque cost, or worse service, and probably greater risk of transit strikes where unions see councils as pushovers. A private bus operator is using its own money. Councils use ratepayers' money. And know what's something that encourages people to keep a car that they might not otherwise need? Threat of transit strikes. 

The few things not currently stupid and broken are being broken. 

Morning roundup

The morning's worthies:

• Treasury are the heroes in this story, where Daalder paints them as villains. Treasury tried to stop the dumbest of the climate spend. GIDI, which either pays companies to invest in tech they were already going to buy, or subsidises them to invest in cost-ineffective ways of mitigating emissions, is such a rort. 


• Justin Giovannetti left New Zealand because of our housing policy disaster. He tells Canadians about the problems.


• Dileepa Fonseca suggests council rates should be apportioned only over land value, rather than land plus capital. I agree - at least for urban councils. For rural ones that don't use user-fees for services provided in towns, there will always be temptation for the townies to screw over the farmers by loading them with costs for services they rarely use. 


• Auckland Council bans people from building infill housing in places where people want to live through special character designations. Allowing infill housing where people want to live is the single most cost-effective thing that councils can do to reduce demand for carbon emissions. Meanwhile, Auckland Transport puts up aspirational plans of how many people they'll force out of cars. If you run a comprehensive price on carbon, you don't need this micromanaging BS. But those who know they are your betters want to dictate how you live. Just letting prices work within an ETS with a binding cap isn't good enough for them. Instead, NZTA is advertising for a Principal Advisor on reducing vehicle kilometres travelled. That just shouldn't be a goal. NZTA should be making sure that road users pay the costs of their road use rather than try to stop it. Maybe the advisor will suggest even worse maintenance on the roads, so the threat of broken axles will discourage driving. 


• Meanwhile, Minister Wood thinks breaking the public transport contracting model is needed to push up wages for bus drivers, among other worthy-sounding outcomes. It's all nonsense. Greater Wellington set a contracting model with trivial penalties for cancelled services and then was shocked! and aghast! that the bus companies ran lean staffing models, eating the fees for cancelled services rather than paying enough for staff to ensure reliable services. Council could have contracted for different outcomes, if it had been willing to pay for them. It'll be interesting to see what they do when they no longer have a scapegoat I suppose. 


• The Auditor General warns about some implications of the proposed 3 Waters Reforms.

Market Studies and Section 43

My column in the Herald last week, ungated here, on the Commerce Commission's market studies powers and their ability to look into previously forbidden places.

I wish they'd have just kept my title: The Spice of Competition Must Flow. 

In Frank Hebert's classic Dune series, the Bene Gesserit sisterhood's supernatural abilities extended only so far. There was a place where their powers could not see – a place that repelled and terrified them.

Over thousands of years of careful influence over royal marriages, the Bene Gesserit sought the birth of the Kwisatz Haderach – the one able to look where they could not and shorten the way.

The Commerce Commission's relatively new market studies powers may not quite make them the Kwisatz Haderach.

Nevertheless, there are parallels.

The Commerce Commission has long been able to pursue anti-competitive activity. Cartels are illegal. Some cartel conduct can draw criminal penalties.

Anti-competitive activity running short of cartels is also prohibited.

But there has been a place the commission has not been able to look.

Section 43 of the Commerce Act exempts activities authorised by government. If a law or Order in Council authorises an activity, that activity is allowed even if it appears to be anti-competitive.

There is some sense to the Section 43 exemption if you think that government generally works well. Parliament and the ministries, at least in theory, will have weighed the public interest and considered any effects on restraint of trade when setting laws and regulations.

A statutory regime may have anti-competitive effects but still be desirable on balance.

In an ideal world, ministries overseeing these regulatory regimes would be running rolling reviews to ensure the regimes continue to be beneficial.

But successive governments have done an abysmal job in ensuring that regulatory and statutory regimes remain fit for purpose.

Reviews of regulatory regimes, when undertaken, tend to have a narrow focus. They do not look at how a regime intertwines with other agencies' regulations and practices and its effects on competition.

Statutory regimes have been the place where the Commerce Commission has been unable to look.

I conclude:

In both its review of grocery retail and building materials, the commission turned its gaze to the place it had not previously been able to look: statutory regimes exempted by Section 43 that combine to thwart real competition. And it found things in serious need of remedy.

Like Dune's Kwisatz Haderach, the commission's market studies authority is powerful and just a bit dangerous.

The commission's very detailed work documenting what had been well understood by sector observers at a high level was not without cost.

Supermarket executive teams would have been tied up for months responding to requests for information while also trying to run supermarkets during a pandemic.

Some future ill-intentioned minister could direct the commission to undertake market studies on areas he wishes to punish. The study process itself imposes a substantial cost, regardless of its findings.

The commission would do well to provide its minister with a list of areas most in need of future investigation. And top of that list should be the places where it previously has been barred from action by Section 43.

Conditions of competition in the provision of medical services would make for a superb market study.

Earlier this year, it was reported that some 150 foreign-trained doctors living in New Zealand have been unable to practice because the rules require them to take up a supervised training position first.

Those positions do not exist for foreign-trained doctors.

The simplest explanation for regulations setting impossible conditions is that the medical professionals who help to set the standards wish to prevent competitors from entering the market.

If we are to have a Kwisatz Haderach, best it be directed in beneficial ways. Let the spice of competition flow.

I chose not to elaborate on the risks of jihad and war that could engulf the known universe, in part because the Commission is only resourced to do one of these a year. 

Three waters and revenue bonds

Will be up at Select Committee tomorrow, along with Nick Clark, to talk about three waters reforms.

The Initiative is a member of the Local Government Business Forum - a peak body of organisations that interface with local government. The Initiative didn't put in a submission on the Three Waters bill (there's just so much on) but the Forum did, and I helped a bit with that. Nick Clark is the Forum's secretary and did much of the drafting. 

The Forum's submission is here. As always, not all members of any peak body outfit will agree with every word on a consensus document - some will be part of organisations that have decided to stay out of the fray on 3 Waters. But it isn't far from my own views either.

We just don't see any of the proposed reforms as being necessary. 

There's a real problem that the legislation is trying to address, but it's gotten itself bogged down in piles of other issues. 

The real problems are water quality enforcement and monitoring, which is already being dealt to by a new regulator, and access to funding and financing tools to ensure that the pipes are up to spec and can be rolled out to support urban growth. 

That latter problem is serious, but seriously doesn't need forced amalgamation into four enormous water service entities. Just let councils issue long lived infrastructure bonds backed either by special rates on serviced properties, or by user fees, or by volumetric charges, or by connection charges, or any combination of all of them. How? The Local Bodies' Loans Act 1913 isn't a bad place to start. It's how councils used to be able to fund the building of stuff, back when it was possible to build stuff. 

Don't need complex new governance arrangements that open up piles of additional contentious issues. Just let councils issue ring-fenced debt. If solving water's what Parliament actually cares about. If they have some other agenda, they can just keep going as they are - but it won't work and it'll get overturned come a change in government. 

Poachers and gamekeepers

May 2020 seemed like the perfect time to start building on a hospital expansion. 

The Eden-Epsom Residential Protection Society disagreed. 

It's been tied up in the courts for the two years since then. 

Their successes in blocking a hospital expansion, during a pandemic, might seem surprising. Except that their President is sufficiently expert in Resource Management law that he's the guy that Labour asked to head up their review of the Resource Management system. 

Randerson's involvement with an organisation working to oppose a private plan change that would allow a hospital expansion was disclosed by Randerson before his appointment.

My column in the Stuff papers.

Auckland Council notified the proposed plan change on March 21, 2019.

The Eden-Epsom Residential Protection Society organised meetings to block it.

A spokesperson for the society, who did not want to be named, was quoted on March 31, 2019: “We are not opposed to hospitals per se and part of our case is there are suitably zoned areas of the city laid down under the Unitary Plan which could accommodate this activity.”

Hospitals are fine, you see, but Not In My Backyard – even if they are situated on a reasonably major thoroughfare.

Auckland Council approved the plan change in May 2020, with a few modifications.

Think back to May 2020.

New Zealand had just finished its first substantial lockdown.

Building more hospital capacity, so we would be ready if Covid got here, is the kind of thing that a sane place might do.

And May 2020 is exactly when the Government, and a lot of economists, were expecting unemployment to be heading toward double-digits. The Government planned a lot of make-work projects, some of rather dubious value, to ensure that construction workers would not flee overseas.

The hospital project could have been shovel-ready. It would have been a perfect project for May 2020.

Alas.

The Eden Epsom Residential Protection Society appealed the decision.

It has been working its way up through the courts. The High Court is scheduled to hear the case in September of this year – more than two years after Auckland Council had provided its initial stamp of approval.

In its submission of May 9, 2022 to the unitary plan team, the Eden Epsom Residential Protection Society highlighted the importance of the three affected properties to the designated special character area.

Later in that same submission, the society argued that “intensification is best directed to the CBD and metropolitan centres rather than the fragmentation and ultimate destruction of irreplaceable areas of special character”.

Allowing a hospital in the area would not just affect properties considered significant, it might also set a precedent of allowing people to build things.

It is an indictment of our resource management system that a hospital expansion can be tied up in the courts for two years during a pandemic.

Can a country that worries more about a special character designation than about hospital capacity in a pandemic really be considered sane?

The Government has wished to progress an ambitious urban growth agenda, including a National Policy Statement on Urban Development requiring councils to enable more housing, and the Enabling Housing Supply legislation requiring Tier 1 cities to allow far more intensification.

David Parker, the Minister for the Environment, launched a comprehensive review of the resource management system in July 2019.

Tony Randerson, QC, chaired that review, which was completed and has been reported back to the Government. He is eminently qualified. There will not be many who better understand the system.

His panel’s review forms the blueprint for the Government’s approach to resource management reform.

The Eden Epsom Residential Protection Society’s submission of May 2022 lists Tony Randerson, QC, as the society’s president.

In answer to a written Parliamentary question on any potential conflicts in Randerson’s appointment to chair the RMA review, Minister Parker stated that, “Hon Tony Randerson CNZM QC declared that he was the president of an incorporated society that was going to oppose a private plan change request by Southern Cross Hospitals. A management plan was put in place to address the potential conflict and the treatment was that Hon Tony Randerson will not be involved in any hearings.”

This ironic coincidence has not previously been reported, but has been open secret in some parts for at least a year. 

Funny old country, New Zealand.

Rent controls and vacancies

In the latest edition of the Journal of Urban Economics, some evidence that easing rent controls reduces vacancies. 

One housing paradox in many markets is the simultaneous presence of high costs and high vacancy rates. India has expensive housing relative to incomes and an urban housing vacancy rate of 12.4%. We show how insecure property rights in India, as a result of rent control and weak contract enforcement, increases vacancy rates. Using a two-way linear fixed effects panel regression, we exploit changes in rent control laws in the states of West Bengal, Karnataka, Gujarat, and Maharashtra to find that pro-tenant laws are positively related to vacancy rates. A pro-landlord policy change liberalizing rent adjustments could potentially reduce vacancy rates by 2.8 to 3.1 percentage points. Contract enforcement measured by density of judges is negatively related to vacancy. We estimate that a policy change in rent control laws would have a net welfare benefit and could reduce India’s housing shortage by 7.5%.

If the risk of being expropriated by a tenant goes down, landlords are more likely to rent out a vacant spot. 

The Vogons Return

In 2015, New Zealand's Vogons killed iPredict.

Money laundering was implausible, but considered too great a risk.

Today, the CFTC announced its withdrawal of its no-action letter for PredictIt, the US-facing site that Vic Uni maintained after iPredict went down. They haven't noted which of the conditions of the no-action letter was violated. I don't trade on PredictIt; not straightforward for Kiwis to do so. So I've no insights.

It's just a shame. 

Around the traps

A few bits from me in these:

• Charlie Mitchell on the IDI. I note that we still need something like an IPUMS front-end to enable greater confidentialised access. I also wish that IDI weren't an afterthought for the government. I'm still annoyed that they wasted time and money on a completely pointless Indicators Aotearoa New Zealand project rather than fixing up systems that should be considered core. Even Infoshare fell over for a few hours yesterday. 


• A chat with Sean Plunkett on student loans, student cost of living, and the case for charging interest on student loans.


• Talked with the Environment Committee about the Emissions Reduction Plan - about 20 minute in on this video. I'd thought I'd seen Brent Edwards in the room. My submission is here.


• Chatted with Jenée Tibshraeny about government debt.


• Anne Gibson noted my submission on building materials supply in her piece in the leadup to yesterday's release of the ComCom draft report. I really liked the report - at least on a quick look through. It hits very well, in detail, on the horrible regulatory and consenting mess facing anyone considering using unfamiliar materials. 


• Had a chat with Hosking about the unemployment numbers, in advance of their release. I don't do unemployment figure forecasting though.
  
  

Stadium co-governance

Oliver Lewis over at BusinessDesk had a look through Treasury documents on the Christchurch Stadium.

Treasury suggested a Council-led approach, both to reduce the fiscal risks to the Crown, and to avoid the challenges of a co-governance approach with Council.

As for a co-led approach (like the city rail link project in Auckland, with the council and the crown both holding shares of City Rail Link Ltd), the Treasury recommended against it, especially if the council had a majority shareholding in the jointly held special purpose vehicle.  

The crown would be assuming risk, officials said, but may not have sufficient influence. 

"Experience working with council to date indicates that a co-governance approach is likely to continue to be challenging and could result in time delays and cost overruns,” the briefing said. 

Later in the year, following meetings between Woods and council officials, the Treasury was tasked with providing advice on two options: a collaborative approach between the council and crown delivered via an autonomous vehicle, or a locally-led option. 

In an October 2019 briefing, the Treasury again affirmed its preference for local leadership on the project and referred obliquely to potential relationship issues should ministers opt for the co-led approach.

There may be some parallels to water.

Under the Three Waters proposal, the Crown takes on enormous backstop risk. They're effectively guaranteeing debt issued by the new entities. 

Treasury warned that Crown-Council co-governance over a stadium may be fraught. 

“For this approach to succeed, crown and council would need to reach alignment on the investment objectives, prioritisation of time, cost and quality, and the best path forward for the project,” officials said. 

“This has not been achieved to date and has proved challenging.”

I'm not sure why co-governance in waters would prove simpler. 

Afternoon roundup

Another long-overdue closing of the browser tabs:

• Tower Insurance is now offering parametric flood insurance. I'd love to know more, including the maximum sum insured and how they've dealt with regulatory issues. 
• New Zealand doesn't have any price gouging laws. Suppose that you can't keep up with demand for your product - everyone in the country is short of it. Normal drill would be to increase prices, right? Surely it's better to ration by willingness-to-pay than by queuing and leaving people short. Alas.
• The Climate Commission notes that, at a carbon price of $150, rebating 54% of ETS revenues back to households as a carbon dividend would fully offset the median increase in food and fuel costs. See Section 5.8. Now imagine the politics of carbon prices if they dispersed 100% of it, instead of letting Grant Robertson use it for industry subsidies. 
• Germany's fantasy energy policy. The Gods of the Copybook Headings limp up to explain it once more. 
• In praise of Corsi-Rosenthal boxes
• The short-term effects of a minimum wage hike may differ, substantially, from the longer-term effects. Hurst, Kehoe, Pastorino and Winberry over at NBER. 
• The Lake Onslow project: an analog solution in a digital age? I still wonder about allowing Korean-style small modular nuclear reactors. If an investor wanted to stick some at Huntley to plug into the existing distribution grid, would it be possible? 
• Minister David Clark wanted to push through a government flood reinsurance scheme. Subsidising people to live on flood plains encourages more people to want to live on flood plains. And then you wind up in stupid second-best worlds where Councils try to zone to keep people from living in places where they wouldn't be living in the absence of that insurance subsidy, or try to pay for flood-protection works that developers would have had incentive to put in on their own so that properties would be insurable. Dodged a bit of a bullet if that one's been avoided. 
• Remember how I said that the RUC discount scheme for diesel drivers invited rorts? The predictable has happened. 
• Take blood, run gene sequencing, predict height, BMI, educational attainment and more. 
• The CDC is failing in its response to Monkeypox. 
• Roger Bootle on the return of the Gods of the Copybook Headings in inflation.
• Smell loss seems the best current predictor of long-term post-covid cognitive impairment. Makes sense to this non-physician: the olfactory nerve is a direct pathway to the brain, right?

LSAP Review?

Geoff Mortlock lays out what's needed for a review of what the RBNZ has been up to, in an open letter to Finance Minister Grant Robertson, cced broadly. 

Jenny Ruth reported on his first open letter at Business Desk:

Reserve Bank governor Adrian Orr is performing an increasingly political role, risking the credibility of the central bank and hurting rather than helping the New Zealand economy, according to former central banker Geof Mortlock. 

In an open letter to finance minister Grant Robertson and RBNZ chair Neil Quigley, Mortlock particularly takes issue with Orr’s “favourite theme of portraying the RBNZ as the Tāne Mahuta of the financial landscape”. 

Mortlock, who spent 24 years at RBNZ through to 2007 and five years at the Australian Prudential Regulation Authority through to 2013, and who has consulted for the World Bank, International Monetary Fund and KPMG Australia, said Orr’s continued prominent references to Tāne Mahuta “have become a source of considerable embarrassment”.

I copy Mortlock's most recent missive here, with his permission:

Dear Mr Robertson,

In a recent open email to you, I made a number of criticisms of the Reserve Bank's performance, governance and management. As you are aware, I am not alone in making these criticisms. Many people with deep knowledge of central banking, economics and financial sector policy have made similar criticisms. The focal points of these criticisms have included:

-  the inadequate quality of governance and management at the RBNZ by reference to relevant foreign benchmarks (e.g. Reserve Bank of Australia, Bank of England, Bank of Canada);

-  the extraordinary preoccupation of the governor with largely irrelevant maori cultural issues, as opposed to doing the job of governor to pursue an effective approach to monetary policy and financial sector regulation;

-  the very costly LSAP program, with a growing taxpayer burden via the government indemnity of the RBNZ;

-  the highly questionable use of macro-prudential policy and the distortions it is creating in bank lending to the housing market when compared to the alternative of using more granular (but less distortionary) risk-weighted capital ratios;

-  the lack of robust cost/benefit assessments of RBNZ policy initiatives, including the major increase in bank capital ratios to levels not seen in comparable countries and which will inevitably exacerbate recessionary pressures next year and possibly beyond; 

-  the extraordinary loss of highly qualified and experienced staff from the RBNZ and the resultant erosion of its intellectual capacity; and

-  the lack of robust performance metrics and independent performance monitoring of the RBNZ.

In this open email, I want to put forward some suggestions for how these failings can be addressed.

LSAP review

In the case of the LSAP, there should be an independent review to assess the matter. It should not be left to an internal RBNZ assessment, given that this would lack sufficient objectivity and independence. My suggestion is for the Minister to appoint one or two persons, suitably qualified and non-conflicted, in consultation with the Opposition parties, to evaluate the efficacy and cost-effectiveness of the LSAP. This should be done in a constructive way to draw out key lessons to guide future policy. Such a review would sensibly include an assessment of the following matters:

-  Were the rationale for and objectives of the LSAP sufficiently thought through and precisely specified at the point of its conception?

-  Was the proposal for the LSAP subject to sufficient independent cost/benefit assessment (external to the RBNZ) before a decision was made to implement it?

-  Was the LSAP sufficiently targeted at reducing interest rates at specific time horizons on the yield curve (e.g. as per the RBA version of the LSAP), as opposed to the broader-based asset purchase pursued by the RBNZ?

-  Could the desired interest rate reductions have been achieved more cost-effectively (at much lower cost to the taxpayer) by simply reducing the OCR further than the RBNZ did reduce it, rather than through the LSAP?

-  What is the estimated impact of the LSAP on economic activity relative to what would have prevailed had the LSAP not been used and the OCR reduced further?

-  Were the potential externalities associated with the LSAP adequately assessed - e.g. the potential for the LSAP to contribute to house price inflation to a greater degree than might have occurred had the RBNZ solely relied on the OCR as the monetary policy lever?

-  Would the RBNZ have embarked on the LSAP, and if so, by as much, in the absence of a government indemnity? In that regard, did the indemnity reduce appropriate disciplines on the RBNZ in the design and implementation of the LSAP?

-  Did the Treasury undertake a cost/benefit analysis of the indemnity before a decision was made to implement it, including taking into account the extent to which the indemnity might have reduced RBNZ incentives for appropriate caution in the use of the LSAP?

-  To what extent did the non-executive members of the Monetary Policy Committee engage on the LSAP, and did they raise concerns?

-  Is the proposed exit from the LSAP the most cost-effective strategy, given the alternatives?  Would it have been better for the RBNZ to begin the sale process at an earlier point, such as when the information available to it suggested that there would be a need to raise interest rates?

These are the kind of issues that need to be properly assessed by an independent, objective and transparent review process, overseen by the FEC.

Review of the functioning of the Monetary Policy Committee

It would be timely to review the functioning of the MPC given the experience of the last two years or so. Again, this should be done by an independent review process and not within the RBNZ. The issues that need to be assessed include:

-  Is the composition of the MPC appropriate in terms of executive versus non-executive members?  Would it be more effective if a majority of its members were non-executive (as in several advanced countries with MPCs)?

-  Do the non-executive members of the MPC have sufficient knowledge, experience and capacity for judgement to be effective in their role? It is worth noting that, while the three non-executive members are all able people in their own right, not one of them had significant experience, in-depth knowledge or standing in monetary policy issues upon their appointment. In contrast, non-executive members of the MPCs in other comparable countries are generally selected on the basis of their specific knowledge, skills, experience and capacity for discerning judgement on monetary policy and macroeconomics.

-  Should the qualifications for appointment of non-executive persons to the MPC be lifted to a higher standard, and better anchored to the role that the MPC performs?

-  Is the level of transparency of the MPC sufficient by reference to international standards? It is striking that there is very little information that is publicly released on the views expressed by the members of the MPC and no speeches are given by any of the non-executive MPC members. By comparison with other comparable countries, the MPC lacks transparency and accountability.

-  To what extent do non-executive members of the MPC constructively challenge the views of executive members of the MPC in their deliberations on monetary policy?  To what extent do they seek to avail themselves of supplementary information and views from parties outside the RBNZ to better equip them to perform their duties?

-  What performance assessment framework is applied by the RBNZ Board and by the NZ Treasury, respectively, in assessing the performance of the MPC, including in respect of the performance of the MPC itself, assessments of forecasting accuracy (relatuive to forecasts made by other entities at the same time), model dependency, and the weights accorded to price stability versus employment considerations?

Board membership

I and many other observers have expressed concern at the lack of sufficient skills, knowledge and experience on the RBNZ Board given its new responsibilities. In particular, it is remarkably lacking in persons with the expected level of knowledge, experience and capacity for discerning judgement in banking, insurance (other than the one director with a limited level insurance connection, who is arguably conflicted), financial markets, and macroeconomics.

By comparison to the boards of functional equivalence in central banks in comparable countries, the RBNZ Board appears to have a remarkably shallow pool of the relevant experience.  This is concerning.  It is also ironic, given that the RBNZ has made much (rightly) of high quality governance in banks and insurers, and yet has failed to lead by example.

I recommend that additional directors be added to the Board to lift its capacity to the required level, with a particular need for suitably experienced persons in banking, insurance, financial markets and macroeconomics. In addition, there needs to be much stronger focus on the structure of its board committees (including risk management, remuneration, audit and prudential policy) and the frameworks they will use to help the Board perform its governance role. Greater transparency and accountability are needed in these areas.

I also recommend that consideration be given to the establishment of a Prudential Policy Committee as an advisory committee to the Board, comprising non-executive persons with expertise in prudential policy and regulatory issues, who are not conflicted, with therse persons being appointed by the Minister of Finance.  (Why an equivalent of the MPC for financial sector policy was not incorporated into the RBNZ Act is also a question that should be addressed when the Act is reviewed.)

Performance assessment of the RBNZ

For many years the RBNZ has operated largely as a self-contained domain. There has been very little meaningful external monitoring and assessment of the RBNZ Board, senior management, and RBNZ performance of its functions. Treasury has done very little in this area. Successive finance ministers (including yourself) have also been content to leave the RBNZ to do its own thing, with little in the way of structured scrutiny and performance assessment. In this regard, there has been a worrying lack of recognition of the fact that, with operational independence comes the need for robust external performance assessment, transparency and accountability. The greater the operational independence a government agency has, the greater is the need for robust independent performance assessment and associated accountability. There has been plenty of operational independence but very little in the way of effective independent performance assessment, meaningful transparency, and accountability.

What is needed now is a much more focused role by the Treasury in assessing the performance of the RBNZ across all of its functions, including the effectiveness of the Board, the governor and the senior management team. This needs to be done on the basis of transparent performance metrics that are set by the Minister (not by the RBNZ), in consultation with the RBNZ. The performance metrics should be comprehensive and cover in meaningful detail all of the functional areas of the RBNZ and should be anchored to the statutory and policy objectives for each functional area. The performance assessments should be transparent, being tabled in Parliament and subject to robust scrutiny by the FEC.

The work being undertaken in Australia, through the Financial Regulator Assessment Authority, provides a good example of how regulatory agencies (APRA and ASIC in Australia's case) are subject to regular, independent performance assessments. Other good examples of central bank and regulatory agency performance assessment can be found in many other countries, including the United Kingdom, United States, Canada and several EU and Asian countries.

New Zealand needs to lift its game in this area - not solely in the case of the RBNZ, but also in respect of other key agencies, including the Financial Markets Authority and the Commerce Commission. More generally, performance metrics and performance audits need to strengthened across the public sector. There is a woeful lack of rigour in this area, with the consequence that New Zealanders continue to suffer from under-performing government agencies and public sector inefficiency.

I urge you and colleagues to take note of the points raised in this email and take appropriate actions to address the concerns I have raised.

Regards

Geof Mortlock

International Financial Sector Consultant

Wellington