The Whole Truth deserves to be preserved for posterity.

Soft censorship of dissenting views that contradict the mainstream perspective occurs in subtle but important ways. The Auckland University of Technology’s 2024, 2025 and 2026 Trust in News in Aotearoa New Zealand Report does not cover the Reality Check Radio platform. The authors captures data from Kiwi’s but it also discusses the media landscape. This subtle form of discrimination and exclusion that is not excusable from a public sector institution.

Traditional elective coverage of the political parties focusses on the parties who are in Parliament. This year is different, The Opportunities Party has been covered, and almost automatically it’s slated to exceed the 5% threshold and get into Parliament. But this is likely partly a function of a $400,000 budget that has likely been partially funnelled to media – because as TOP $221,000 donor Alan Wilderland says ‘You have to play the game’.

In other words, you have to pay to play.

The lack of any extensive budget of other smaller parties means that they are simply not seen even if they are engaging in newsworthy activities. They don’t exist until election day, and then the name, because it hasn’t been in mainstream coverage, is not familiar and recognisable. In the age of digital technology and AI, media could cover their election policies, and rank them alongside each other (as I did with Health Policies) - but year after year, our mainstream media do not.

The effect that we continue to see - is the suppression of dissenting views. We’re finding out that the suppression of dissenting views may not be good for the health of democracies – and may not be good for health full stop. This is because of the notions of rights in democracies. If you don’t have the right to say no to a government intervention, this cannot only impact health rights, the knock-on effect can be access to income, safety and security, as we saw in 2021-2023.

THE WHOLE TRUTH ON NZ’S BIGGEST ONLINE PLATFORM

A remarkable body of COVID-19 corporate media reporting remains on New Zealand’s Stuff website. As a time capsule, it provides an historic record of the presentation of a ‘fact-checking project’ directed to the general public on COVID-19, the infection and the injection.

Called The Whole Truth, the series was published from 12 May 2021 to 20 December 2021, and I have accessed it on August 27, 2026.

Stuff’s messaging was tightly controlled. It reveals how a small group of academics and individuals could dominate - through the most dominant online platform in New Zealand - the national understanding on the risk and safety of the COVID-19 coronavirus and the vaccines that the government purchased, and subsequently enacted legislation so that people would be required to comply with the rollout, that was decided prior to April 2021.

The Whole Truth series received funding from the Google News Initiative’s Covid-19 Vaccine Counter-Misinformation Open Fund, and following an application in May 2021, $591,465 was granted in June 2021 to the Whole Truth series from Public Interest Journalism Fund.

The management of information was highly centralised in New Zealand during the years 2020-2023. The Department of Prime Minister and Cabinet (DPMC) coordinated government COVID communications, purchased media/advertising, contracted people to address mis-and disinformation and interacted with media organisations, including Stuff.

I described much of this in a paper presentation ‘Science for Whom?’ at the 2022 Australian Sociological Association conference at the University of Western Sydney. One year later, I gave a conference presentation on the topic and the problem of democratic waning.

The 2021 Auckland University of Technology Media Ownership Report described (pages 46-47) the highly influential role of Stuff:

The incumbents of the central print and online news duopoly—the New Zealand Herald (NZ Herald) and Stuff—maintained their hold on the lion’s share of the print and online audience. Meanwhile, last year’s Roy Morgan Research listed Stuff as the clear leader for digital audiences in New Zealand” (Roy Morgan, 2020), with a total digital audience in an average seven days of more than 1.8 million, well ahead of main rival nzherald.co.nz on 1.55 million. Together, Stuff and the New Zealand Herald are the most popular New Zealand-based online video providers, with little sign of any impact on that status from the pandemic (NZ On Air, 2021e).

THE WHOLE TRUTH - BUTTRESSING THE ROLLOUT STRATEGY

The Whole Truth series can be shown to work to parallel and placate public concerns about the Roll Out Programme, that had been developed earlier in the year, with the goal of vaccinating all New Zealanders above 12, no matter their risk status.

While few documents publicly disclosed the full extent of the government’s sequencing framework, i.e. which would extend to Tier 4 (the healthy population), in a May 2021 the Auditor-General was frank about the extent of the strategy to vaccinate as many people as possible, aged 16 years and over, by the end of 2021.

a sequencing framework has been developed that divides people into four groups. Vaccination of the first two groups is under way. It has been stated that group three will start being vaccinated in May 2021, and group four from July 2021. More detailed plans show that most people in groups three and four will receive their vaccines later than this, over the rest of 2021.

We didn’t know that it would be compulsory.

THE WHOLE TRUTH - CHAPTERS

Each chapter box, containing the chapter section at the top of the article, included this text that encouraged the reader to contact Stuff in the fight against false information:

While each box at the bottom included this text which reaffirmed that the information was part of a fact checking project:

When commenting about these articles we must remember the context, the date and month that they were published.

1. Does the speed the vaccine has been developed and rolled out make it less safe? 12 May 2021

2. Why the “priority groups” aren’t guinea pigs 12 May 2021

3. Does the vaccine actually work - what’s the evidence from one of the world’s most vaccinated countries? 12 May 2021

4. Why urgent legislation was required to mandate the vaccine rollout 10 May 2021

5. Prescription drugs, flu jabs and the Covid-19 vaccine 20 May 2021

6. How does an mRNA vaccine work? 22 May 2021

7. Severe reactions to the Covid-19 vaccine are not common 25 May 2021

8. How Māori and Pasifika are more at risk from Covid-19 1 June 2021

9. What Medsafe’s vaccine conditions mean 3 June 2021

10. No, we haven’t run out of vaccine 11 June 2021

11. How the vaccine measures up against the variants 13 June 2021

12. Covid-19 vaccination isn’t a simple yes or no for everyone 14 June 2021

13. I’m under 16: when can I get the Covid-19 vaccine? 16 June 2021

14. Protecting the people vaccination could leave behind 21 June 2021

15. Declining the vaccine is far riskier than having it 24 June 2021

16. Pregnancy and the Covid vaccine 30 June 2021

17. Will the vaccine stop me getting Covid? 1 July 2021

18. What is population immunity, and will we reach it? 6 July 2021

19. The Covid-19 vaccine’s ingredients: mRNA, fats, sugar, salts 8 July 2021

20. The danger of Delta 9 July 2021

21. What we know about the Janssen Covid vaccine 15 July 2021

22. Why larger arms need a larger needle for the Covid-19 vaccine 20 July 2021

23. There’s a simple reason why in the UK more vaccinated people are dying of Covid-19 22 July 2021

24. Why a sore arm after vaccination can be a good thing 26 July 2021

25. The vaccine and your breasts 28 July 2021

26. Myocarditis: A rare and mostly mild side effect of the Pfizer vaccine 29 July 2021

27. The future of Covid vaccines 4 August 2021

28. Why do people believe Covid-19 vaccination myths? 5 August 2021

29. The latest science behind the Covid-19 “cures” 9 August 2021

30. How the Covid-19 vaccines got to market in record-breaking time 11 August 2021

31. Why the time between Covid-19 vaccinations is being doubled 12 August 2021

32. How well does the vaccine protect you against Delta? 18 August 2021

33. The case for vaccinating children and teenagers 19 August 2021

34. Covid vaccines, health insurance and ACC: yes, you’re covered 26 August 2021

35. Worried about vaccine administration errors? You shouldn’t be 27 August 2021

36. Covid-19 is more likely to cause myocarditis than the vaccine is 30 August 2021

37. How to interpret reports of adverse events following Covid-19 vaccination 2 September 2021

38. What would a Delta outbreak look like with higher vaccination rates? 8 September 2021

39. Can a 12-year-old give consent for the Covid-19 vaccine? 9 September 2021

40. I’m immunocompromised: is the Covid-19 vaccine right for me? 16 September 2021

41. It’s biologically impossible for the vaccine to give you Covid-19 23 September 2021

42. If you care about your gonads, get vaccinated 24 September 2021

43. Immunity from Covid-19 vaccination versus the virus 27 September 2021

44. The Pfizer vaccine is effective, regardless of your ethnicity 30 September 2021

45. What is in the Pfizer Covid-19 Vaccination? 8 October 2021

46. Almost everyone can have the Pfizer Covid-19 vaccine 11 October 2021

47. If you’re breastfeeding, getting the Covid-19 vaccine can also help protect your baby 12 October 2021

48. Kids and the Covid-19 vaccine 14 October 2021

49. Why some people struggle to change their minds about vaccination 15 October 2021

50. ‘Long-term’ side-effects of Covid vaccination are not a thing 21 October 2021

51. Vaccination reduces the likelihood of new variants emerging 29 October 2021

52. Why the second Covid-19 vaccine packs a bigger punch 12 November 2021

53. I’m fully vaccinated. Can I still get Covid-19, and pass it on? 17 November 2021

54. What we know about the AstraZeneca vaccine 25 November 2021

55. The risk of Covid-19 far outweighs the risk of the vaccine 15 December 2021

56. Can different Covid-19 vaccines be mixed? 22 December 2021

57. How to spot misinformation 29 December 2021

58. Three persistent kinds of Covid misinformation — 30 December 2021

The PDF embedded below publishes the content and reflects the layout in the original series published by Stuff, with each of the chapters enclosed in each box.

Stuff Nz 2021 The Whole Truth Fact Check Series

1.78MB ∙ PDF file

Download

Download

THE THEMES OF ‘THE WHOLE TRUTH’: AN AI SUMMARY

We cannot establish that government funding directed to Stuff determined the content of The Whole Truth series or its wider reporting. What we can examine is the resulting pattern. I asked an AI to identify the main themes that were repeated across the 58 articles.

A dominant theme in the coverage was risk reassurance coupled with repeated affirmation of vaccine effectiveness. Articles addressed concerns about myocarditis, severe reactions, long-term side-effects, fertility, breast health, administration errors and the unusually rapid development and rollout of the vaccines. Alongside these were articles emphasising effectiveness against infection or severe disease, protection against variants, population immunity and the comparative risks of vaccination and Covid-19. The overall communication pattern was therefore not limited to explaining the technology. It repeatedly identified potential sources of vaccine concern, sought to reduce those concerns, and reinforced vaccination as the safer or preferable course of action.

A second prominent feature was audience segmentation and targeted communication. Separate articles addressed children, teenagers, people under 16, pregnant and breastfeeding women, immunocompromised people, Māori and Pasifika, and people designated as priority groups. Other articles targeted particular anxieties, including concerns about fertility, vaccine ingredients and adverse reactions. Rather than communicating to a single undifferentiated public, the coverage anticipated concerns that might discourage vaccination within particular demographic or clinical groups and provided tailored information intended to reassure those audiences and support vaccine uptake.

A third theme concerned misinformation, vaccine hesitancy and the management of competing claims. Articles instructed readers how to identify misinformation, described particular claims as myths or misinformation, discussed why people believe vaccination myths, and examined why some people struggle to change their minds about vaccination. This moves beyond conventional product or public-health education into the management of how readers interpret competing sources of knowledge. The coverage therefore operated at two levels: communicating claims about vaccine safety and effectiveness, while also providing a framework for distinguishing information considered authoritative from information characterised as unreliable, misleading or false.

PROFESSOR JOHN IOANNIDIS STANFORD UNIVERSITY

Professor John Ioannidis was historically recognised as one of the world’s most brilliant, and hence esteemed, epidemiologists. His public health training made him particularly attentive to differences in epidemiological risk across population subgroups. This meant distinguishing risk according to factors such as age, sex, underlying health status and comorbidities, rather than treating the population as though risk were uniformly distributed.

This was traditionally fundamental to epidemiology: understanding how population risk varies in response to an environmental exposure or event, and identifying which population subgroups are most susceptible, was central to epidemiological training, research and publication.

Before Stuff’s series even began on 12 May 2021, Ioannidis had already published peer-reviewed work questioning undifferentiated population-risk assumptions, examining dramatically lower mortality risks among non-elderly populations, estimating IFR from seroprevalence, examining the heterogeneity of the pandemic, questioning lockdown evidence and calling for rigorous evaluation of social interventions.

The government never seemed to incorporate any debate on Ioannidis work, at Cabinet level, in the science communication data, and in the technical advisory group communications.

During the period in which Stuff published its 58 articles, Ioannidis published further work on the model-dependence of NPI estimates, COVID mortality attribution and, importantly, the risk-benefit considerations surrounding vaccination of children and university students.

It can only seem that this eminent epidemiologist, at the top of his game, with an extraordinary citation record and h-index, and who was well known throughout the world of epidemiology, was effectively blacklisted by the media and the New Zealand government. Some of Ioannidis papers are listed in the references at the end of this article.

THE SILENCING OF DISSENT

If the information or interpretation you held differed from the New Zealand Government’s position during 2020–2023, even as a subject-matter expert, you had little standing in mainstream public debate. We might assume that in a democratic country experts remain free to question government policy and have their evidence considered on its merits. Yet much of the mainstream media that dominated online news, supported the Government’s population-wide vaccine rollout.

Across this 58-article series, in the documents released by the Disinformation Project, in the failure to provide the coroner with resourcing, in the absence of clear risk data held by the Children’s Commissioner by age and gender, and in reporting on academics and doctors who departed from Ministry of Health guidance or prescribed outside it, dissenting expertise was rarely treated as an opportunity to examine competing evidence, while ignorance perpetuated the status quo.

People that independently and extensively reviewed the scientific literature were frequently positioned as outsiders: characterised through the language of misinformation, subjected to professional and reputational criticism, and, at times, publicly shamed rather than substantively engaged.

Medical doctors and clinicians were strongly aware of the warnings coming from the New Zealand Medical Council, and the increasing numbers of doctors reported for scrutiny.

We should not believe that COVID-19 is done and dusted, because the political and legislative precedents remain, and the media coverage requires scrutiny.

I have written at length about the absence of consideration of stratified risk by age, gender and health status, and I am strongly aware of the ongoing concerns in New Zealand (including through the Health Forum and NZDSOS) and in international scientific communities where there is the resourcing to undertake such enquiry. I have tipped my hat to the brave whistleblower Barry Young who highlighted the regional variation in adverse events in New Zealand and was consequently raided and arrested.

Consider also, Cranmer’s recent Substack, outlining the speed of passage of medical decisions into legislation. Towards the end of that Substack Phil Crump asked a couple of pertinent questions:

The current Government has promised that, in a future pandemic, key advice behind decisions affecting people’s rights will be released within five working days. That is an important safeguard. But transparency does not answer the harder question exposed by the booster rollout: who should have the power to authorise population-wide use outside Medsafe’s approved terms, and what safeguards should apply when they do?

Nor does it answer a more specific question: should an off-label use authorised by the Director-General for a population-wide vaccination programme then be capable of becoming a condition of employment?

Subscribe now

Share

WERE MANDATES EFFECTIVELY LOCKED IN, PRIOR TO SARS-COV-2 ARRIVING IN NEW ZEALAND?

The governments intended the entire population over 12 would be injected, regardless of health risk by age, gender and health status at an early stage. A 11 December (health report no. 20202266), Memo titled Auckland COVID-19 vaccine event from Ashley Bloomfield to Chris Hipkins, confirmed that at that date there was ‘currently no community transmission’, it discussed the ‘National Immunisation Solution’, that the border and MIQ workforce and healthcare workers would be the first to be injected with the Pfizer/BioTech gene therapy product BNT162b2.

The report also confirmed that a ‘sequencing framework’ had been developed and that the COVID-19 Immunisation Programme was designed to reach everyone.

Bloomfield detailed the event the key points would be covered off:

• Prime Minister to introduce the event and cover high level messaging on our COVID-19 response, the two new Advanced Purchasing Agreement announcements, Medsafe timing, what immunisation will mean for our borders, and how important our Pacific neighbours are.

• Minister of Research, Science and Innovation to cover more detail on the Advance Purchasing Agreements, the expected delivery schedules, manufacturing, and announce the $75 million in dedicated funding for the Pacific.

• Minister for COVID-19 Response to cover the planning for COVID-19 immunisation, including distribution, workforce, the National Immunisation Solution and sequencing.

In Cabinet minutes the sequencing framework for tiers 1-3 were disclosed (e.g. CAB-21-MIN-0052; OIA response H202106406; In Confidence release 8t605jj9dp 2021-03-31 16:19:52). However, the Tier 4 plan, which would oblige the generally healthy population to be injected, was not generally disclosed to the public.

However, it was well established. Tucked inside the Auditor-General’s May 2021 paper: Preparations for the nationwide roll-out of the Covid-19 vaccine.

Yet this was no conventional vaccine technology, it was a gene therapy.

STIGMATISING DOCTORS & EXPERTS

The media played as considerable role in the social ostracism and stigmatising of doctors. I believe that many doctors and academics attempted to raise attention to the risk, particularly to pregnant women and healthy, especially younger populations over the years 2020 and 2021, including through media and by approaching the mainstream media Stuff and NZHerald directly. Dozens of doctors have been called up in front of the Medical Council and required to undergo behaviour modification training, even for, for example, prescribing ivermectin. The fact that the literature on the safety of ivermectin is extensive, was not the issue. It is that these doctors departed from government guidelines – no matter the evidence for safety.

It’s noteworthy that the Medical Council has spent 5 years investigating medical doctors, based on their deviation from the Ministry of Health guidelines. The Medical Council in this role, effectively acts as a proxy or sub-agent for the New Zealand government. Yet it is outside the Official Information Act. We cannot conduct a request to understand its internal mechanisms, its international connections and its decision-making – including to ascertain the precise numbers of doctors under investigation, the vast majority of whom had an exceptional record before they raised their heads above the parapet (i.e. no complaints had been laid in 20-30 years of practice).

Dr Bernard Conlan faced years of investigative inquiry because he questioned the rollout of the vaccine to youth and pregnant women.

The New Zealand Medical Council in 2026 continues to attempt to sanction doctors for prescribing ivermectin in the past five years. Ivermectin has an historic record of shortening the duration of a virus, including Covid-19. Because of the low incidence of side effects, doctors judge the cost-benefit positively: the uncertainty concerned efficacy, not risk, and it had a well-established safety record (especially when combined with other medication).

The 56 articles failed to discuss why doctors would choose a therapeutic pathway involving nutrients and medicines with a long history of safe use, and speak publicly about their choice.

During COVID-19 I wrote extensively on the relationship between policy, science and media:

JR BRUNING: COVID-19 PAPERS: https://www.talkingrisk.nz/covid-19-papers/

These papers, as well as information on PSGRNZ’s website provide extensive documentation regarding the extent of information that was known at the time the Stuff articles were being written.

(Please don’t send me more Covid information, even if you have the best will in the world – I’ve got other projects on and insufficient bandwidth).

SAFETY COULD NEVER BE ASSURED, & PFIZER UNDERSTOOD THIS

The gene therapy was a biologic drug; however, for the purpose of COVID-19 it was reclassified as a vaccine, therefore evading traditional carcinogenicity and mutagenicity trial requirements.

It’s noteworthy that the product supplied to participants in the trials was not the product produced and sent out to the world.

The mechanism created risk. As I discussed in a 2022 paper presentation: The biologic vaccine contained genetic information. The injectable coded for the spike protein. Vaccine recipient cells would then read the injected code and produce a viral antigen – the spike protein in an uncontrolled release. This technology had never been approved before this and early trials had been largely unsuccessful…. The 95% claim of efficacy was based on 7 days of no symptoms post-vaccination. Safety was based on data supplied by the manufacturer. Cardiac risk was identified from early days.

There were more deaths in the BNT162b2 injected arm than in the placebo arm – and cardiac arrests were the major cause of death.

PREGNANCY

When the vaccine was authorised there was no data on vaccine effectiveness for pregnant women, however at this stage, the sequencing framework had been established. For example, the risks and benefits for pregnant women failed to take into account that the risk for generally healthy pregnant women, judged against a novel gene therapy remained unevaluated (H2023022968), and that the BNT1262b2 trial results for pregnant women, which strongly signalled pregnancy risk would only be disclosed at a later date. A June 2021 NEJM paper reported the relatively high rate of side effects:

Among v-safe participants, 86.5% had a known pregnancy at the time of vaccination, and 13.5% reported a positive pregnancy test after vaccination. Among v-safe pregnancy registry participants, 28.6% received vaccine in the first trimester, 43.3% in the second trimester, and 25.7% in the third trimester.

Among 827 registry participants who reported a completed pregnancy, 104 experienced spontaneous abortions and 1 had a stillbirth. A total of 712 pregnancies (86.1%) resulted in a live birth, mostly among participants who received their first vaccination dose in the third trimester. Among live-born infants, the incidences of preterm birth (9.4%), small size for gestational age (3.2%), and congenital anomalies (2.2%) were consistent with those expected on the basis of published literature. There were no neonatal deaths. These are reassuring data based on reports from pregnant women mostly vaccinated in the third trimester.

This sort of data was not discussed by Stuff. But this was the sort of data that would be required for a healthy pregnant woman, to judge whether the BNT162b2 injection might present an adverse risk.

MYOCARDITIS

As at 30 December, Stuff continued to claim that there was ‘outsized fear about side effects’, linking back to a 30 August article claiming that Covid-19 itself is more likely to cause myocarditis than the vaccine is.

The linked Stuff article does not evaluate the vaccine risk against the risk of COVID-19 by age, gender and health status, but discussed a few articles, linking to EMA information, now outdated, from July 2021, and selected the Barda Israeli study. However, Israel’s shift to active surveillance was prompted by the myocarditis signal. There was a plethora of warning signals in the literature by then. Stuff does not review the published literature on the risk.

A 21 July 2021 Science Memo from Ian Town stated that there was a higher risk for male children and adolescents over 12 years for pericarditis and myocarditis risk. Within a week, the Stuff communication of 29 July, and later articles on 30 August and 30 December, would downplay myocarditis risk. There was no evaluation of the risk from peri or myocarditis by age, gender and health status.

I am currently waiting on an OIA response to the Ministry of Health to identify to what extent myocarditis was raised by people in response to the amendment act consultation. There was no mention of myocarditis in the summary report to the health select committee.

LIPID NANOPARTICLES

The public were told by Stuff that the novel technology only contained ‘Fats, salts, sugar and the actual ingredient that protects you.’ It told the public that there was no microchip in the vaccine. While explaining that that the lipid nanoparticles were ‘Tiny bubbles of fat surround the mRNA like a protective wall, helping to transport and protect it’, Stuff did not inform the public that the reason the mRNA was surrounded by the lipid nanoparticles (which were not a ‘natural fat’) – was because the bodies defense systems would try to prevent the gene therapy from entering inside human cells.

There was reason to be cautious about chemical ingredients that had never before been used in a medical product, nor registered for medical use. The European Medicines Agency had signalled that the novel excipients (ALC-0315 and ALC-0159) they were risky.

OUTSIDE OF STUFF’S 58 ARTICLES: THE IMPLICITLY BLACK LISTED THERAPIES

It is telling what was not discussed in The Whole Truth series. Across the extensive 58 articles, there was not a single substantive discussion of vitamins and minerals in supporting cellular and immune health, nor of established medicines such as ivermectin that had a long history of use and an extensive safety record and may have shortened the duration of infection.

Nor was there any meaningful attempt to balance established integrative, medical and nutritional therapies against the uncertainties associated with the newly introduced BNT162b2 vaccine.

For example, vitamin D, vitamin C and zinc have well-established roles in normal immune and cellular function, while N-acetylcysteine supports glutathione production and has antioxidant and anti-inflammatory effects. Used appropriately, these established nutrients and therapies did not present the same novel or incompletely characterised risk profile as BNT162b2.

Ivermectin and many nutritional interventions had been used in human populations for years or decades, providing a substantial body of information about their safety. BNT162b2, by comparison, was a new vaccine using lipid nanoparticles to deliver modified mRNA containing genetic instructions that caused human cells to produce the SARS-CoV-2 spike antigen. Its development and authorisation occurred over an exceptionally compressed period, so longer-term safety evidence could not yet exist when the vaccination campaign began.

Moreover, after emergency authorisation, the pivotal trial was progressively unblinded and placebo recipients were offered the vaccine, weakening the continuing randomised placebo-controlled comparison from which longer-term safety signals might otherwise have been assessed.

These differences in the maturity of the evidence deserved explicit consideration. Questions remained about the duration and distribution of vaccine-derived mRNA and spike-antigen production, while emerging safety signals, including myocarditis, demonstrated the importance of continued scrutiny.

Yet rather than placing these uncertainties alongside discussion of established therapeutic and nutritional approaches, The Whole Truth overwhelmingly framed vaccination as the appropriate response while directing considerable attention towards reassuring the public about vaccine risks and countering competing claims.

ARE YOU A CONSPIRACY THEORIST?

Perini and van Schie (2024) described the portrayal of conspiracy theorists:

conspiracy theorists are frequently portrayed as irrational and unscientific (Butter & Knight, 2018), gullible (Cassam, 2016), potentially violent (Lamberty & Leiser, 2019) and supporting of violence (Jolley & Paterson, 2020), paranoid (Hofstadter, 1965), delusional (Husting, 2018, p. 115), narcissistic (Golec de Zavala & Federico 2018), schizotypal (Georgiou et al., 2019), magical thinkers (Ferguson, 2020), neurotic (Bowes et al., 2023), pathological (Kumareswaran, 2014), alienated (Lamberty & Leiser, 2019), motivated by supernatural, paranormal, and Manichaean (good vs. evil) thinking styles (Oliver & Wood, 2014), and, overall, epistemologically crippled (Sunstein & Vermeule, 2009).

Let’s go back in time to September 2020. RNZ and Stuff published the article: COVID-19: Can New Zealanders tell the truth from conspiracy theories?

‘While the questions covered most of the main conspiracy theories surrounding COVID-19, the strongest beliefs were around the theory that the disease was created in a lab.’

That 2020 article contained several messages. It communicated to the public that they were a conspiracy theorist if they believed that COVID-19 was the result of a lab leak. It messaged the public that they could be considered a conspiracy theorist if they speculated a little too much or departed from the government message. The Stuff articles did not evaluate the literature, nor look at preprints, to understand the extent to which the origin of this coronavirus, with its strange etiology, might have come from a lab leak.

That hasn’t aged well. It’s 2026 and Fauci recently invoked the Fifth Amendment 111 times to avoid a wee chat. The lab leak hypothesis has evolved into a mature theory.

The lab leak theory was first excluded from the public and expert discourse, as it was situated in antisystem narratives and popularized mostly by fringe actors. Over time, however, it was decoupled from the illiberal, antisystem framing and reformulated as an expert hypothesis by various established political and scientific authorities. (Vorlíček 2026)

What also hasn’t aged well was the failure to highlight risks of the mRNA injection versus the benefit, by age, sex and health status. This is now particularly galling in light of the evidence that myocarditis risk was downplayed by the Ministry of Health, who failed to raise the fact that by age, sex and health status, younger people could be far more at risk from vaccine-induced peri or myocarditis than the respiratory virus.

In addition to the Stuff articles other platforms tended to overemphasise the anti-vax narrative. The NZHerald republished a 2023 syndicated AP article titled ‘‘Died suddenly’: Anti vaxxers twist tragedies to push vaccine lies.’ that said: Some claims about those who’ve suffered heart issues also weaponize a kernel of truth - that COVID-19 vaccines can cause rare heart inflammation issues, myocarditis or pericarditis, especially in young men. Recent articles by the NZHerald are paywalled.

Subscribe now

Share

NO, SCIENTIFIC CLAIMS ARE NOT DETACHED FROM SOCIETY

Harambam and Aupers (2015) apply some insight:

More than merely mimicking modern science in order to augment epistemic authority, conspiracy theorists wish to purify it and re-install its free spirit of inquiry. Their critique is targeted at the dogmatic nature of scientific assumptions, the authority of scientific institutions, and, indeed, the epistemic and social boundary work performed by scientists to sustain this authority.

Academic scholars have shown that the “public image” of science as detached from context is difficult to maintain when we look at the “messy” “back-stage” of science that is vulnerable to political influences and interests (cf. Collins and Pinch, 1993; Latour, 1987; Law, 2004). Scientific knowledge is not transcendent, but the product of particular people, in a particular setting, and in a particular time (Doyle McCarthy, 1996; Gieryn, 1999; Shapin, 2008). Conspiracy theorists popularize such notions: they deconstruct the public front-stage image of science and want to reveal the social, economic, political powers that color its findings.

The adaptation of sociological insights by conspiracy theorists is a good example of what Giddens (1984) describes as the “double hermeneutic” (p. 20). This trickling down of academic knowledge in everyday life, and of social critique in particular, may be yet another reason for academics to furiously demarcate their “scientific analyses” from “conspiracy theories.” We argue therefore that this elective affinity posits conspiracy theories not outside of science, but right in the middle of its most fierce battle: the science wars. … Conspiracy theorists are thus subjected to a double form of boundary work: they are excluded by academics defending the positivistic ideals of science and by scholars coming from the social studies of science.

The challenge people face when talking about taboo subjects might be informed by Miranda Frickers work on injustice and expertise. Fricker saw testimonial injustice as occurring when one persons’ account is given less credibility because of prejudice about who is speaking, rather than the strength of what they are saying.

Frickers concept of hermeneutical injustice went deeper: people can struggle to explain or even make sense of their experience because the shared concepts and language needed to describe it have not yet developed, or have been excluded from authoritative knowledge. In both cases, people are wronged in their capacity as knowers.

COVID-19: SPEED OF LEGISLATIVE PRODUCTION ENHANCED THROUGH SECONDARY LEGISLATION, NOT VIA PARLIAMENT

Finally, as I have attempted to draw attention to (here, here, here, here), the public checks and balances on the Orders that resulted in increasing obligations to get vaccinated in order to access workplaces and small businesses, and there do not appear to be published documents that accompany each order demonstrating the reasoning - for example – risk by age, gender and health status, did not appear to exist.

It’s unclear whether officials ever pointed out the need for a vaccine to be safe by age and gender, a simple function which should, have reasonably and transparently, underpin the production of each order, when never before in the history of New Zealand was a medical treatment mandated at population level. Instead, the decisions were confined to a small group in Cabinet.

But the corporate media did not ever, draw attention to this wrong.

If I circle back to The Opportunity Party - is the media coverage and hence their slated entrance into the bullring predicated by a tacit agreement - to not prod the globalist, neoliberal, austerity-loving Net Zero bull?

COVID-19 Response (Management Measures) Legislation Bill. 6 days Introduced May 5 2020 received Royal Assent 15 May 2020. Minister in Charge: Hipkins

1. COVID-19 Public Health Response Bill. No public consultation 1 day. Introduced May 12, Third reading and Royal Assent May 13 2020. Minister in Charge: Parker

2. COVID-19 Public Health Response Amendment Bill. No public consultation. Introduced July 29, received Royal Assent August 6 2020. Minister in Charge: Woods

3. COVID-19 Response (Further Management Measures) Legislation Bill (No 2). No public consultation. Introduced & passed August 4, 2020, Royal Assent August 6 2020. Minister in Charge: Hipkins

4. COVID-19 Response (Management Measures) Legislation Bill. No public consultation (some private consultation). 4 days. Published October 1, closing date for submissions October 5 2020. Minister in Charge: Hipkins

5. Inquiry into the operation of the COVID-19 Public Health Response Act 2020. One month. Published May 21, closing date for submissions June 28 2020.

6. COVID-19 Recovery (Fast-track Consenting) Bill. 5 days. Published 16 June, closing date for submissions 21 June 2020, Royal Assent 8 July 2020. Minister in Charge: Parker

7. COVID-19 Public Health Response Amendment Bill. No public consultation. Published and passed 1 December, Royal Assent 7 December 2020. Minister in Charge: Hipkins

8. COVID-19 Public Health Response (Validation of Managed Isolation and Quarantine Charges) Amendment Bill. No public consultation. Introduced 20 May, Royal Assent 24 May 2021. Minister in Charge: Hipkins

9. COVID-19 Public Health Response Amendment Bill (No 2). 11 days. Published 30 Sept closing date for submissions Oct 11 2021. Minister in Charge: Hipkins

10. COVID-19 Response (Vaccinations) Legislation Bill. No public consultation. Bill introduced November 23, Royal Assent November 25 2021. Minister in Charge: Hipkins

REFERENCES

Ioannidis JPA. Coronavirus disease 2019: the harms of exaggerated information and non-evidence-based measures. Eur J Clin Invest. 2020 Mar 23:e13223. doi: 10.1111/eci.13223. Epub ahead of print. PMID: 32202659

Ioannidis JPA. Global perspective of COVID-19 epidemiology for a full-cycle pandemic. Eur J Clin Invest. 2020 Dec;50(12):e13423. doi: 10.1111/eci.13423. Epub 2020 Oct 25.

Melnick ER, Ioannidis JPA. Should governments continue lockdown to slow the spread of covid-19? BMJ. 2020 Jun 3;369:m1924. doi: 10.1136/bmj.m1924. PMID: 32493767.

Ioannidis JPA, Axfors C, Contopoulos-Ioannidis DG. Population-level COVID-19 mortality risk for non-elderly individuals overall and for non-elderly individuals without underlying diseases in pandemic epicenters. Environ Res. 2020 Sep;188:109890. doi: 10.1016/j.envres.2020.109890. Epub 2020 Jul 1.

Eran Bendavid, Bianca Mulaney, Neeraj Sood, Soleil Shah, Rebecca Bromley-Dulfano, Cara Lai, Zoe Weissberg, Rodrigo Saavedra-Walker, Jim Tedrow, Andrew Bogan, Thomas Kupiec, Daniel Eichner, Ribhav Gupta, John P A Ioannidis, Jay Bhattacharya, COVID-19 antibody seroprevalence in Santa Clara County, California, International Journal of Epidemiology, Volume 50, Issue 2, April 2021, Pages 410–419, https://doi.org/10.1093/ije/dyab010

Ioannidis JPA. Infection fatality rate of COVID-19 inferred from seroprevalence data. Bull World Health Organ. 2021 Jan 1;99(1):19-33F. doi: 10.2471/BLT.20.265892. Epub 2020 Oct 14. PMID: 33716331; PMCID: PMC7947934.

Ioannidis JPA. Benefit of COVID-19 vaccination accounting for potential risk compensation. NPJ Vaccines. 2021 Aug 11;6(1):99. doi: 10.1038/s41541-021-00362-z. PMID: 34381059; PMCID: PMC8358049.

Share

With a general election scheduled for November 2026, I thought I would review the health policies to identify which parties understand that many of our chronic illnesses, many of the chronic diseases now common in New Zealand can be reversed or substantially improved through policies that increase education, support, dietary counselling and access to good nutrition.

12/8/2026: Audio Interview with RCR’s Maree Buscke:

When Health Policy Stops Treating the Causes

Health is key to life quality, to holding a job, sustaining a relationship. Sickness results in lower employment capacity, poorer living standards and greater social challenges.

Every political party says it wants a healthier New Zealand. Yet almost every health policy begins only after people become patients. We debate how to fund diabetes, heart disease, depression and obesity, but devote remarkably little attention to preventing them. If the emerging science on metabolism and brain health proves substantially correct, the greatest opportunity is not building a bigger healthcare system, but creating a healthier population that needs less healthcare in the first place.

Across all the major parties, we are not seeing health policies, we are seeing medical and sickness policies. It’s more of the medicalised, multimorbid … same, with no recognition of the potential for prevention and reversal of these conditions.

Disclosure: I wrote the PSGR white paper Reclaiming Health: Reversal, Remission & Rewiring. Understanding & Addressing the Primary Drivers of New Zealand’s Metabolic & Mental Health Crisis. I also played a role to support the development of the Make New Zealand Healthy policy platform.

Between the Reclaiming Health paper and Make New Zealand Healthy’s proposed solutions, there was more than enough material on the table to fundamentally reshape New Zealand’s health landscape, to move toward an evidence-based approach that supports health at every stage of life.

That’s because a significant and growing body of scientific evidence shows that low-carbohydrate diets, which reduce glucose spikes and high, unstable insulin levels - also reduce the risk of a whole spectrum of common chronic illnesses: prediabetes and diabetes, cardiovascular disease, poor mental health, many autoimmune conditions, and cancer.

What if changing our diets could substantially alter disease risk across that entire spectrum - and improve mental health at the same time? What if broad-spectrum, brain-health-formulated multinutrients could be offered to people for whom conventional anxiety and depression medication isn’t working - people with uncomfortable side effects, children, and pregnant women?

What if there was strong evidence that our current low-fat dietary guidelines, which downplay animal protein, are contradicted by a large body of research suggesting those guidelines were never built on rigorous science? If there was substantial evidence that it isn’t just sugar that’s addictive, that refined, low-fat carbohydrates are part of the craving story too? That would explain why health coaching matters: not just to teach people new dietary behaviours and skills, but to help them navigate craving and temptation that isn’t simply ‘sugar’s fault’ but related to ultraprocessed foods that are engineered to exploit our reward pathways.

What if all of this information simply does not seem to exist for our major political parties?

Most political parties claim to support prevention, but prevention without a plan is simply rhetoric. Few identify the biological drivers of today’s chronic disease epidemic, explain how those drivers can be modified, set out the programmes needed to support people, identify who should deliver them, or define how success should be measured. In effect, the major parties lack a coherent policy framework for preventing and reversing metabolically driven chronic disease.

Subscribe now

YOU DON’T HAVE JUST ONE HEALTH CONDITION

The BBC recently reported that more young women in their 20s are getting type 2 diabetes. We’re seeing increased risk for metabolic conditions including diabetes, heart disease and cancer in younger and younger age groups. If not corrected with dietary support, these people get sicker faster, from a much wider range of conditions.

When people are diagnosed with pre-diabetes, diabetes, heart disease, anxiety, depression, cancer and a wide range of other metabolic and brain-related conditions, they are immediately at risk of the spectrum of conditions in this same list. These are known as overlapping and multimorbid conditions (two or more diagnosed conditions).

This includes metabolic syndrome which includes the overlapping conditions of hypertension, dyslipidaemia, type 2 diabetes mellitus, obesity, and inflammation, and people with these conditions are more likely to be diagnosed with a mental illness or brain-related disorder including depression and anxiety.

Metabolic syndrome, as a cluster of conditions is increasing in prevalence. What the data tells us is that if you are diagnosed with metabolic syndrome you are more likely to suffer from mental illness. If you have poor mental health you are likely to have poor metabolic health. Our young people are being diagnosed with all of these conditions at much younger ages than their grandparents.

CAN POLITICIANS & HEALTH AGENCIES AFFORD TO IGNORE MULTIMORBIDITY?

Multimorbidity is common, and frankly, a scourge on society. More medicine to deal with more symptoms is not health. It’s more common to have multiple health conditions than a single condition, and a recent survey identified 4-10 prescribed medicines per person as common, and a maximum of 53 medications prescribed to one person.

The societal cost of multimorbidity is super-additive and multimorbidity occurs a decade earlier in deprived communities. The cost of diabetes alone is extraordinary.

But what if dietary changes (particularly in the first six years) result in the remission of diabetes, and better lipid panels, but also improve mood and wellbeing? What if a major New Zealand study had just been published, showing multiple centres that adopted low carbohydrate support programmes for patients – reporting improvements across pakeha, Māori and Pacific populations?

Evidence increasingly suggests that total daily carbohydrate intake, not simply sugar consumption, influences glucose variability and chronically elevated insulin levels.

These metabolic disturbances are closely linked with mental health and neurological function through multiple biological pathways. This knowledge is increasingly well supported in the scientific literature, is critically important for developing youth, pregnant women and for people who either do not respond to conventional psychiatric medication or who suffer from relatively common, serious side effects.

DOCTORS, SCIENTISTS, DIETITICIANS, PSYCHOLOGISTS & PSYCHIATRISTS SPEAKING UP

This is why a growing international group of clinicians and researchers, including medical doctors (e.g. David Unwin), psychologists (Iain Campbell) and psychiatrists (Christopher Palmer and Georgia Ede) are recommending lower-carbohydrate dietary approaches emphasising nutrient-dense whole foods, adequate protein and healthy fats.

As part of this shift, these people and escalating numbers of scientists, are highlighting that current dietary guidelines vastly overstate the carbohydrate intake, while understating high quality fat and protein intake. Search for low carbohydrate and ketogenic in the scientific literature.

The guidelines are increasingly difficult to reconcile with the modern evidence base. This revolution is exciting, it’s a game changer for public health, and New Zealand scientists and doctors including Professor Grant Schofield, Professor Julia Rucklidge, Professor Caryn Zinn, Dr Marcus Hawkins and Dr Glen Davies are actively publishing their findings in the scientific literature. Yet those findings are not being translated into policy or routine clinical practice.[1] [2] [3] [4] [5] [6] [6]

POLICIES COULD BE ENACTED TO SUPPORT METABOLIC & MENTAL HEALTH

Metabolic health coaching could be integrated into primary care, mental health, and addiction services to reduce diabetes burden, improve mental wellbeing, and lower long-term system costs.[8]

New Zealand’s Professor Julia Rucklidge’s findings should be game changing for our mental health policy. Rucklidge has been involved in researching SSRIs in pregnancy (during and after) and the role of broadspectrum multinutrients (that can be used alongside traditional medications) in reducing risk for anxiety, depression, ADHD, OCD, schizophrenia and – well – safely support brain health in growing children and even help grumpy irritable teenagers to navigate the ups and downs of adolescence.

Well studied broad-spectrum nutrients could easily be a first-line or early-stage intervention option for vulnerable populations, particularly where current treatments carry significant side-effect burdens or are poorly tolerated. ‘Potential priority populations could include children and adolescents with ADHD or mood dysregulation, pregnant women experiencing anxiety or depression, individuals with treatment resistant mental health conditions, and patients who experience severe adverse effects from antidepressant medications’.[9]

Although public good knowledge such as this can and should inform health agencies and political decision-making, these findings continue to be widely ignored by our members of Parliament and the political parties with the greatest influence over health policy.

The Reclaiming Health paper lays out that story and the science behind it, ending with recommendations grounded in published research. Make New Zealand Healthy (MNZH), meanwhile, released a series of policy papers. A few MNZH examples:

End the epidemic of chronic disease focussed on dietary guideline reform; fixing food taxes, restoring quality school lunches to low decile schools and better regulating food advertising.

Put prevention at the heart of healthcare laid out a detailed metabolic health solution which included increasing screening to better evaluate chronic disease risk; implementing health coaching to mitigate and reverse diabetes, diabetes and support mental health; fund multinutrient supplementation to support anxiety, depression, including for pregnant women, youth and treatment resistant people, or people with extreme side effects from traditional treatment; and better support doctors and clinicians.

Implement quality nutrition education throughout the school curricula from primary school all the way to undergraduate health and biomedical studies.

Establish a statutory Institute for Human and Environmental Health Research and ensure that researchers have ring-fenced funding to research metabolic illness, brain health, nutritional health, and research health risks from environmental chemicals that increase disease risk.

Remove Pharmac Barriers to recognised safe nutrients to ensure that nutrients aren’t over-regulated, making them more difficult for people to access.

YES PEOPLE HAVE TRIED TO BRING THIS TO THE ATTENTION OF OUR MPS

All Members of Parliament were emailed an open letter and the Reclaiming Health paper on 22 January 2026. The leaders of the major political parties received an email from Make New Zealand Healthy on 17 April 2026 to advise of the policy platform.

Having now reviewed the health policies of every party - large and small - I’ve summarised what I found, and it’s clear: the major parties, the ones with sitting MPs, have ignored all of our recommendations. Whether individual MPs tried to get traction on any of this behind the scenes, I can’t say.

What I can say is this: the major parties remain focused on more medication and more screening, while some of the smaller parties are at least attempting to grapple with the chronic disease crisis.

While I expected National, Act and Labour to revolve around more medicine I was surprised to see how poor New Zealand First and the Greens approach to health and nutrition was. Perhaps something is in the offing, but it’s late July…

I was most surprised to see the quality of content in the newly named Freedom (former Outdoors and Freedom Party) and New Zealand Loyal* policies. I’ve tried to summarise them, but from my perspective, the Freedom policies deserve to be heard. We have to stop pretending that there are only five political parties.

What we’re left with is a set of dominant parties with no language for the rising tide of chronic illness in younger New Zealanders, and an ethical and moral vacuum where people struggling with illness, unable to live at their full potential, are simply left behind, struggling with multimorbidity and polypharmacy and simply – recommended more drugs.

WHO ARE YOU GOING TO VOTE FOR?

Registered political party

• ACT New Zealand

• Animal Justice Party Aotearoa New Zealand

• Aotearoa Legalise Cannabis Party

• Conservative Party NZ

• Freedom Party

• New Zealand First

• New Zealand Labour Party

• Opportunity Party

• Te Pāti Māori

• The Green Party of Aotearoa New Zealand

• The New Zealand National Party

• Vision New Zealand

• Women’s Rights Party

Other parties awaiting Electoral Commission approval are included. (*)

HEALTH POLICIES OF EACH PARTY

ACT New Zealand

Official policy: Health Policy.

ACT has not published dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health. It’s health policy centres around three goals:

1. Expand public–private partnerships in health.

2. Remove remaining race-based health policies.

3. Increase transparency and performance measurement.

Alliance Party of Aotearoa New Zealand

Official policy: Education, Health, Housing, Social Security and Media.

Free health care. The Alliance Party lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health.

Animal Justice Party Aotearoa New Zealand

Official policy: Animal Justice Party Aotearoa New Zealand, Policy Browser.

The party has not published a detailed human health policy platform. Its health-related positions are principally framed through the interconnected health of people, animals and the environment.

Aotearoa Legalise Cannabis Party

Official policy: Aotearoa Legalise Cannabis Party, policy platform.

Health policy revolves around cannabis reform.

Conservative Party NZ

Official policy: Conservative Party NZ, policy platform.

The party currently publishes relatively limited detailed health policy. Its health-related positions emphasise personal choice, family authority and preventative care.

New Zealand First

Official policy: New Zealand First, policy platform.

New Zealand First lacks a health policy. New Zealand First lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health.

New Zealand Labour Party

Official policy: Labour’s 2026 election policies, including its health package.

Labour lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health. Labour health policies revolve around lowering barriers and increasing access to medical services and screening treatments.

• Free doctor visits

• Free prescriptions

• Free maternity scans with Medicard

• Free cervical screening

Freedom

Official policy: Health & Wellbeing Policy.

The party proposes a fundamental shift from a treatment-focused health system towards one centred on prevention, whole-person care and informed patient choice. It would invest in high-quality epidemiology to better understand the causes of chronic disease, establish integrative medical centres combining conventional and complementary approaches, expand access to allied health practitioners, functional medicine and nutritional support, and introduce a Real Food Strategy to improve access to affordable, healthy food. The policy also supports greater investment in oral health, pregnancy care, community health initiatives, non-invasive diagnostic technologies, research into alternatives to antibiotics, injury prevention, and regional clinical toxicology services.

In mental health, the party advocates moving beyond a predominantly biomedical model by recognising the psychological, social, environmental and nutritional contributors to illness. It proposes comprehensive physical-health assessments before psychiatric medication is prescribed where appropriate, expanded nutritional and functional-medicine support, longer-term residential rehabilitation services, holistic approaches to addiction recovery, and greater attention to housing, education, employment, financial security and childhood trauma as determinants of wellbeing. It also proposes strengthening patient rights through the Code of Health and Disability Services Consumers’ Rights, increasing the proactive role of the Centre for Adverse Reaction Monitoring (CARM), and reforming abortion law.

Official Policy: Our Objectives

No health policy.

The Green Party of Aotearoa New Zealand

Official policy: Complete Party Policy

The Green Party lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through nutritional and dietary policies that improve metabolic and mental health.

The Opportunity Party

Official policy: Healthy People.

• Develop a process for cross-party planning on a ten year timeframe for the health system.

• Launch ‘spend-to-save’ primary and prevention initiatives, including digital health and AI tools.

• Fund core health services properly, including ambulances, GPs and health infrastructure.

• Increase pay and improve conditions for health sector workers and increase training placements and quality to ensure we have the workforce we need.

• Reinstate smokefree 2025 legislation.

These broad commitments do not have detailed policy information. TOP lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health.

Te Pāti Māori

Official policy: Health Policy.

• Rebuild and strengthen a Māori-led health authority and Māori-led health services. Make services more accessible and culturally safe.

• Shift health-system priorities towards prevention and whānau wellbeing, rather than primarily responding to crises.

These broad commitments do not have detailed policy information. Te Pāti Māori lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health.

New Zealand Loyal*

Official policy: Health

New Zealand Loyal’s health policies focus strongly on the prevention and potential reversal of chronic illness through improvements in metabolic, mental and environmental health. The party proposes a new health framework centred on prevention, patient-centred care, natural and integrative medicine, and greater access to healthcare through decentralised community clinics and hospitals. It supports expanding mental health services, reducing waiting times, increasing community-based support, and moving away from the traditional chemical imbalance model towards a trauma-informed neurodevelopmental approach. The party also advocates research into emerging psychiatric treatments, including psilocybin, MDMA and cannabinoids.

The party places particular emphasis on environmental determinants of health, proposing policies to reduce exposure to environmental toxins through measures such as removing fluoride from public water supplies, banning the use of 1080 poison, and promoting organic farming. It also proposes stronger transparency and accountability within the health system through an independent health watchdog responsible for investigating complaints and improving oversight.

New Zealand National Party

Official policy: Quality, Timely Healthcare

National lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health. National health policies revolve around lowering barriers and increasing access to medical services and screening treatments, increasing cancer drug funding, increasing hospital funding, increasing elective surgery numbers, and increasing crisis/acute mental health services.

Vision New Zealand*

Official policy: Human Rights and Healthcare

Vision lacks dedicated health policies to mitigate and reverse the current epidemic of chronic illness through policies that improve metabolic and mental health.

Vision proposes to increase health professional salaries; to improve GP access and reduce specialist waitlists across local towns; fully fund Plunket and increase financial support for pre-natal and post-natal care for mothers and infants; review and reform existing legislation that endangers the lives of unborn children and to boost funding for university health degrees and provide incentives for domestic students to enter medical professions.

Women’s Rights Party

Official policy: Policy documents

The party has not published a detailed human health policy platform.

It was a surprise to me, that Freedom and New Zealand Loyal would stand out as the only parties with a significant direction to addressing metabolic health issues.

PSGRNZ (and I presume Make New Zealand Healthy) would welcome interviews and discussions with MPs and politicians on the topics of our policy recommendations. As charities we can email parties equally to share information, but we do not lobby individual people or parties.

Elections are ultimately about choices. Voters can decide whether they want another election fought over waiting lists, hospital beds and medicine budgets, or whether they want to ask a different question: why are so many New Zealanders becoming chronically ill in the first place? The scientific literature is increasingly attempting to answer that question. The challenge now is whether our politics is prepared to do the same.

If you share this frustration, don’t just express it in the comments. Please email this article to your MP, the Minister of Health, your local candidate and relevant health agencies, then share it with your family, friends and social media networks. If enough New Zealanders put this evidence in front of decision-makers, it becomes much harder to ignore.

As a final note, I would like to apologise to ‘that friend’ who has been asking me to look at the Outdoors and Freedom policies, - for years. I’ve finally looked!

Originally published in NZ’s Daily Telegraph. July 27, 2026

REFERENCES

^[1] Zinn C, Campbell JL, Fraser L, Davies G, Hawkins M, Currie O, Cannons J, Unwin D, Crofts C, Stewart T, et al. (2025) Carbohydrate Reduction and a Holistic Model of Care in Diabetes Management: Insights from a Retrospective Multi-Year Audit in New Zealand. Nutrients.17(24):3953. DOI:10.3390/nu17243953

^[2] Owen, A., Driscoll, A., Kleissl-Muir, S., Zinn, C., & Rasmussen, B. (2023). Exploring the Barriers and Enablers to Implementing a 16-Week Low-Carbohydrate Diet for Patients With Diabetic Cardiomyopathy. Journal of Cardiovascular Nursing, 39(5), E172-E178. https://doi.org/10.1097/JCN.0000000000001025

^[3] Donovan, K., Lenferna De La Motte, K. A., & Zinn, C. (2024). Healthy Food Affordability in a New Zealand Context: Perception or Reality? Journal of Hunger & Environmental Nutrition, 19(3), 329–341.DOI 10.1080/19320248.2022.2047862

^[4 Lenferna De La Motte K-A, Zinn C. The nutrient profile and cost of specialty dietary patterns: a hypothetical case study. Public Health Nutrition. 2023;26(12):2995-3004. doi:10.1017/S1368980023002537

^[5] Rucklidge JJ, Bradley HA, Campbell SA et al. (2025). From womb to world—is it time to revisit our current guidelines for treatment of antenatal depression? Supporting the next generation to have the best start to life New Zealand Medical Journal138(1621):90-98. DOI: 10.26635/6965.6858.

^[6] Rucklidge JJ, Bruton A, Welsh A et al. (2024). Annual Research Review: Micronutrients and their role in the treatment of paediatric mental illness. J Child Psychology and Psychiatry. 66(4):477-497. DOI: 10.1111/jcpp.14091

^[7] Rucklidge JJ, Sherwin AH, Mulder RT, Manna L. (2026) Efficacy and Safety of Micronutrient Treatment for Irritability in Adolescents: 8-Week Double-Blinded Randomized Placebo-Controlled Trial (BEAM). Journal of the American Academy of Child & Adolescent Psychiatry. https://doi.org/10.1016/j.jaac.2026.01.013

^[8] Make New Zealand Healthy. Policy: Put prevention back in the heart of healthcare. Pages 5-7. https://makenewzealandhealthy.co.nz/wp-content/uploads/2026/06/Solution2_PutPreventionATheHeartOfHealthcare-Make-New-Zealand-Healthy.pdf

^[9] Make New Zealand Healthy. Policy: Put prevention back in the heart of healthcare. Pages 8-9.https://makenewzealandhealthy.co.nz/wp-content/uploads/2026/06/Solution2_PutPreventionATheHeartOfHealthcare-Make-New-Zealand-Healthy.pdf

Subscribe now

• Stop New Zealand’s Electronic Road User Charges (eRUC) Surveillance System

  

  NAT/ACTS WEE ELECTION AGREEMENT

A consultation on regulations for a new road user charging framework has just closed, but the public were never given the opportunity to consider the most important question:

Why is this change necessary in the first place?

The consultation: ‘Proposals for regulations under the Land Transport (Revenue) Amendment Bill Consultation on requirements for road user charges’ discussed electronic distance recorders, approved providers, privacy safeguards, performance standards, and alternative payment schemes. We were told the system will be modern, innovative, flexible, customer-focused, and future-ready.

New Zealand is proceeding with a technically sophisticated and commercially innovative ‘smart’ road user charging reform that would ultimately bring all vehicles into a largely privatised digital charging ecosystem, yet there has been no comprehensive public examination of its implications for privacy, data governance, civil liberties or the particular transport realities of New Zealand. The reforms contemplate telematics, electronic distance recorders, alternative payment schemes and multiple private providers, but there is no overarching framework that limits data collection to what is strictly necessary, constrains future uses of mobility data, or prevents function creep across agencies and commercial operators.

In the recent consultation people were only given minor decisions to make – but not provided the capacity to disagree or not on the fundamental policy itself and comment with the long-term vision expressed in the Cabinet documents.

Shifting policy from a fuel excise tax to electronic road user charge (RUC) model was a predetermined decision – an election commitment to the ACT and National Party Coalition Agreement to “Work to replace fuel excise taxes with electronic road user charging for all vehicles, starting with electric vehicles”.

In most areas of public policy, governments are expected to demonstrate necessity before expanding administrative systems and information collection. Apparently, a pre-election decision between ACT and the National Party (that did not reflect any broader public call) appears to be enough justification.

Unlike a 2025 European analysis that primarily envisages distance-based charging as a supplement to fuel taxes and focuses initially on EVs and heavy vehicles, New Zealand is moving rapidly toward a universal electronic RUC model that would ultimately replace fuel excise for the entire light vehicle fleet. This places New Zealand at the leading edge of road-pricing reform and raises governance, privacy and proportionality questions that receive relatively little attention in the international literature.

Remarkably little research has been undertaken globally or in New Zealand – because New Zealand is going where no-one is. International discussions of road user charging have largely concentrated on economics, engineering and congestion management. Far less attention has been paid to the governance challenges created by nationwide mobility-data systems, including function creep, commercial access to travel data, telematics integration, multi-provider arrangements and the absence of clear legal limits on future uses of that information. Seow and Pistorius’ 2024 Policy Quarterly paper stands largely alone, yet concludes that a Privacy Impact Assessment should be undertaken before implementation and that any data collected should be limited to what is strictly necessary for the stated purpose. That has not occurred.

The reform effectively assumes that privacy can be managed through provider compliance with the Privacy Act. However, privacy law is not merely concerned with secure handling of information once collected; it also requires consideration of whether the collection itself is necessary and proportionate in the first place.

RUCs, TELEMATICS, INSURANCE & TOLLING - A CORPORATE GODSEND

New Zealand is able to move more swiftly than other countries, as unlike most, we already operate a public distance-based road user charge (RUC) system. This system applies primarily to diesel-powered light vehicles and all heavy vehicles regardless of fuel type – this is why diesel at the pump seems cheaper. The road tax is collected separately as RUC. It was legislated in 1977 and substantially updated in 2012 and the current legislation is focused on financing roads. Unlike the UK, Australia or the United States, which are still trying to build the political case for distance-based charging from scratch, the RUC system has evolved iteratively since it was first legislated in 1977, and the government is taking an iterative approach to expanding the system to include electric and petrol passenger vehicles.

The objective of the future Bill?:

The Bill aims to modernise the RUC system and remove barriers to the future transition of all light vehicles from fuel excise duty to RUC. By allowing for a more flexible ‘outcomes-focused’ approach, the regulations are more likely to accommodate novel technologies for electronic distance recording as they become available. For example, instead of a separate device, built- in vehicle telematics could serve as an electronic distance recorder if it meets the accuracy and integrity standards set by the RUC Collector.

Unlike the current public RUC system the government has chosen to privatise the delivery layer. Rather than simply adapting the state RUC collection system, it is creating a regulated market for private RUC providers with NZTA as the backend ledger only. This should please the World Economic Forum and its consultancy and digitech partners immensely, after all the hard work they put into policy development in the mid-2010’s on.

The pressure catalyst, as everywhere, is electric vehicles (EV). However, this ‘catalyst’ enables rentier opportunities beyond EV issues and the need to fund road maintenance. In an early New Zealand Transport consultation in 2022 the scope of ‘costs’ stretched to encompass greenhouse, pollution and (of course) the administrative charges of any more expensive digital surveillance architecture that would (have to) oversee a future system. This early New Zealand Transport consultation broadened the ‘externalities’ that the RUC could pay for – but it did not broaden the discussion on privacy, equity and trust concerns.

No wonder ACT is so interested. It is a massive privatisation opportunity. The PTOLEMUS Consulting Group, a specialist in telematics, insurance and tolling, produces detailed industry-intelligence. PTOLEMUS have forecast that the global electronic toll collection and road usage charging market will grow at 13% CAGR to 2030. Companies are gearing up for business.

This is an explicit commercial opportunity for the telematics, fintech and mobility service industries. The reform explicitly contemplates congestion and time-of-use pricing as a future layer.

Modern vehicles are data generating devices. Telematics are ‘the use of wireless devices to transmit data in real time back to an organization. The data recorded in telematics devices can be used to develop more accurate pricing, improve the granularity of risk management techniques and reduce losses by enabling better claims assessments’ (2015).

However, official agility and speed is not matched by official attention to safety and security. Instead, it involves shifting away from a simple publicly administered system to a system of extraordinary complexity, many, many layers, significant privacy concerns and a risk that expansive knowledge of citizen data can and will lead to multipurpose applications that undermine trust and transparency.

Who decides which of all the other costs are suitable? Who controls the layers of costs and expenses? Who makes the decision about the pricing in distance travelled? Extending the scope of costs beyond immediate road costs exposes a hydra of decision-making. In transport pricing reform internationally, equity protections that are not baked into the enabling legislation tend not to appear in the implementation, because by then the commercial and administrative architecture is set and the political moment has passed.

THEY’RE PLANNING A NETWORKED GRID – THEYRE JUST NOT CONSULTING ON IT

Technologies often begin with narrow purposes but evolve into forms of comprehensive data collection. While the just-finished consultation was primarily pitched as a technical consultation on regulatory settings, related Cabinet papers and the Regulatory Impact Statement (RIS) indicate that the framework can expand to support future location-based charging, time-based charging, tolling integration, and more dynamic road pricing.

Yet these wider objectives were not clearly disclosed nor discussed in the consultation document itself. The public were not permitted to comment on such issues. The policy documents did not establish why a revenue collection system requires the creation of a substantially expanded vehicle-use data ecosystem when a less intrusive alternative already exists.

The logic, the affordability and the practicality of retaining the status quo was never addressed. The consultation proceeds from the assumption that replacing fuel excise duty with electronically administered road user charging is the preferred policy direction. The accompanying Regulatory Impact Statement (RIS) had expressly excluded consideration of retaining the current fuel excise system.

THE POLICY RESPONSE SHOULD BE PROPORTIONATE TO THE POLICY PROBLEM

Is replacing a simple fuel excise system with a data-intensive charging architecture is a proportionate response to the problem identified. The documents never compared the privacy, governance and administrative implications of a distributed electronic charging system against the principal advantage of fuel excise: that it raises substantial revenue without generating ongoing vehicle-use datasets. Instead, the analysis moves directly from identifying a revenue and fairness problem to proposing a data-dependent solution, without undertaking a meaningful assessment of whether the additional information collection is necessary or proportionate. That should concern citizens regardless of their views on privacy.

Fuel excise, i.e. a tax on fuel at the pump, does not generate headlines about digital transformation. But it possesses several qualities that good public policy should value. It is simple and relatively cheap to administer. It is collected through a small number of collection points. Most importantly, it does not require the routine generation, collection, storage, transfer, auditing, and governance of vehicle-use information.

The proposed model introduces electronic distance recording, approved providers, monitoring systems, compliance mechanisms, auditing requirements, alternative payment schemes, and extensive information governance arrangements. The Government presents these as features of a modern system.

We can see that a vast range of actors would profit from such a move, from software development, to IP ownership of the different forms of surveillance and data processing software to the digital storage and of course, the management consultancies who would help deploy the policies.

These policies -laundered in via an election agreement - were not led by consumer demand.

The value led, qualitative work relating to data capture, privacy and equity is being publicly funded so that the broader academic community could explore it (outside of the gung-ho ministries). The Ministry of Innovation, Business and Innovation (who control the research and science purse-strings) does not fund such research.

There’s been no evaluation of how a well-designed fuel duty with targeted relief for low-income households might be less regressive than a private-market RUC system with no built-in equity mechanism. Even if low-income households drive less in absolute terms, transport costs represent a larger share of their budgets. There is no pricing design that solves this without explicit redistribution of revenue, and the NZ government’s current RUC reform framework is primarily focused on market design and revenue collection, not redistribution.

‘FEARS ABOUT PRIVACY BLOCKING NECESSARY REFORM’

The New Zealand Initiative’s (NZI) 2024 Driving Change presumes that ‘privacy concerns can be addressed through robust data protection safeguards.’

The NZI report assumes that privacy concerns can be addressed through technical safeguards after the policy decision has been made. It does not require that a comprehensive privacy and data governance framework be established before implementation, nor does it assess whether such a framework would remain effective as technologies, institutional arrangements and legislative purposes evolve over time. The report doesn’t seem to discern between the relative simplicity of the current public RUC system and the proposed multi-provider, data-intensive model involving insurers, private service providers, road managers and government agencies.

The report draws extensively on international examples from dense urban environments, and justifying such policies via congestion management and economic efficiency objectives.

NEW ZEALAND IS ALREADY AN EXPENSIVE COUNTRY TO LIVE IN

If New Zealand does not sit near the top of the OECD for transport costs relative to incomes, it is difficult to see which countries would. We are a geographically dispersed, car-dependent nation with limited public transport outside a handful of cities, high fuel prices, and a population that must import virtually every vehicle it drives. For many households, the cost of mobility is already one of the largest expenses after housing.

The policy literature frequently treats driving as a behavioural choice to be nudged away through pricing mechanisms. It is not. New Zealand’s physical geography is fundamentally different from the cities and corridors where distance-based charging has been modelled, piloted and politically sold. Singapore is a flat island grid. Stockholm has a compact peninsular centre with radial rail. Oregon’s pilot involved suburban commuters on a highway network. None of these bear much resemblance to a country where volcanic terrain, coastal geography and fault-line topography routinely mean that the direct route simply does not exist, where A to B requires going via C and D not by choice but because there is no straight road, no alternative corridor, and often no road at all in the other direction.

Yet any distance-based charge treats a kilometre as a kilometre. A farm worker in Waikato, a nurse commuting from the Kapiti Coast, a plumber servicing the Tokoroa Region, people caring for extended family on different sides of a city - these people are not driving further because they are inefficient or making poor choices. They are driving further because the landscape imposes it. A flat per-kilometre charge that takes no account of distance that geography compels rather than preference generates is directly punitive toward the communities that are already stretched thinnest by cost-of-living pressures.

Most cities outside Auckland, Wellington and Christchurch are essentially car-dependent.

New Zealand’s small-business economy compounds this. The movement of tradespeople, goods, care workers, agricultural inputs and hospitality staff across dispersed, low-density geographies cannot be adequately by a public transport system. Small businesses are the productive backbone of the economy, and their route distances are set by geography and client location, not by congestion avoidance or leisure preference.

Global and local RUC reform documents contain almost no engagement with New Zealand conditions. The modelling, the market-sounding respondents, and the think-tank advocacy all lean heavily on urban efficiency narratives borrowed from international experience in places nothing like New Zealand. A reform that is serious about geographic equity would need route-adjusted charging, explicit rural rate differentiation, or meaningful distance caps for communities beyond viable public transport reach.

BIG TECH KNOWS EXACTLY HOW MUCH DATA CAPTURE CAN OCCUR

The private sector is acutely aware of the commercial opportunities associated with road-pricing reform and works through international policy networks, consultancies, industry bodies and public-private partnerships to help shape policy-relevant information. For example, World Economic Forum (WEF) think tanks have led RUC policy development. System Initiative on Shaping the Future of Mobility, formally launched around 2016, became the WEF’s central ‘platform for business leaders from transportation, technology, energy, infrastructure, insurance, health and other related sectors to partner with policy-makers to shape the future of mobility (and) accelerate the transformation to a global mobility system that is clean, safe, secure, inclusive and smart.’

By 2016, the Field Guide to the Future of Mobility was published, framing telematics and connected vehicle data as foundational to next-generation transport systems and explicitly highlighting connectivity, automation, telematics and new capabilities of small and big data analytics among the key enabling technologies for urban transport transformation.

In 2018, partner Deloitte released a Seamless Integrated Mobility System (SIMSystem) white paper. The SIMSystem platform would determine what multimodal operations could be used and require extensive data collection. The paper recognised that opportunities for private sector actors could include ‘building solutions that generate viable business models. These businesses could be based on the use of assets or delivery of services, or could be rooted in licensing and usage fees for data, analytics or operational responsibilities.’

The data capture would be extraordinary:

A SIMSystem requires information about supply (number and utilization of modes, operating times, total capacity, prices, accessibility, container characteristics, etc.), demand (starting and ending locations of trips, price elasticity across modes, etc.) and the environment (traffic conditions, road delays/closures, weather, accidents, etc.). It also requires thinking through the entire data lifecycle. Data will need to be created, captured, acquired, standardized and stored. It will need to be reliable and have syntactic and semantic meaning for the various entities using it. Data must move from where it is created or stored to those entities within a SIMSystem who need it. Analysis will be needed to extract meaning, gain insights and make decisions.. and drive ….system-wide learning.

Partner the Boston Consulting Group then produced a 2018 WEF/BCG report on autonomous vehicles and urban mobility. Large-scale simulations claimed the benefits of active policy intervention, implicitly including pricing, to prevent AV adoption from worsening congestion. The WEF then launched the Global New Mobility Coalition (GNMC) (2019), based around reducing passenger car emissions. Road pricing was embedded in their policy toolkit from the outset.

WEF’s calls to direct costs to the consumer ‘according to their ‘real’ cost or ‘impact on society’ have grown more vocal. Road-pricing and parking fares continue to be framed as cost levers to ‘internalise true mobility costs’ – i.e. increase costs to the consumer.

In parallel, the International Transport Forum (ITF), the OECD’s transport body, established a Corporate Partnership Board, composed of major automotive, logistics and technology companies, making this a direct industry-policy co-production initiative. The ITF view RUC as a means to ensure road users account for the costs their road use imposes on others, and as a way to raise funds and nudge users towards more sustainable transport use.

A framing shift occurred when the fuel duty revenue crisis created by increasing EV adoption was used to argue for distance- and location-based charging as a structural fiscal necessity, not merely a congestion management tool. A distance travelled tax was proposed as an infrastructure funding mechanism to replace or supplement the fuel tax.

The privacy dimension was simultaneously surfaced as a known obstacle requiring technical resolution. Privacy was not ignored. Rather, it was increasingly framed as a technical design problem to be managed through architecture, governance controls and privacy-preserving technologies. The possibility that citizens might object to the creation of large-scale mobility-data systems on democratic, ethical or civil-liberty grounds has received far less attention. The WEF and associated actors consistently positioned privacy-preserving telematics architecture (that they would design) as the technical solution to this political obstacle.

Therefore, by 2019, the WEF and its partner ecosystem had assembled a coherent, interlocking argument: fuel duty revenues were in long-term structural decline due to EVs; congestion and emissions externalities required pricing interventions; telematics and connected vehicle data made sophisticated, multi-parameter charging technically feasible; privacy-preserving architectures could neutralise public opposition; and the “user pays” principle legitimised the shift from flat taxation to individualised usage-based fees.

Policy development arose from public-private co-production – but was not led by civil society. The ITF Corporate Partnership Board, the WEF’s GNMC, and university policy centres like Berkeley TSRC all served as venues where automotive, telematics and tech industry actors participated directly in the production of “policy research” that then circulated to governments as expert guidance.

The pivot to telematics-based RUC requires onboard devices, data processing infrastructure, account management platforms, and potentially third-party service providers, all market opportunities for the connected vehicle industry – as PTOLEMUS forecast demonstrates.

PRIVACY IS TREATED AS AN ENGINEERING QUESTION

The Berkeley briefs, PTOLEMUS reports, and WEF documents consistently positioned privacy concerns as a solvable technical challenge for system architects, rather than a legitimate democratic objection to the underlying surveillance architecture that location- and time-based charging inherently requires.

ITF papers in 2015 and 2022 have drawn attention to privacy concerns ‘ability to associate data with the identity and behaviour of a specific person represents a serious challenge to privacy rights. Even data stripped of direct and even indirect identifiers may still be used to re-identify natural persons.’

EXPANDING THE RATIONALE: THE REAL PROBLEM OF FUNCTION CREEP

The problem becomes more apparent when the consultation is considered alongside earlier Ministry of Transport and Cabinet documents. A 2022 Ministry paper described road user charges primarily as a mechanism for recovering infrastructure costs according to road use and road wear. Heavy vehicles impose greater costs on roads and bridges, and the charging framework was designed accordingly. Weight, axle configuration, and distance travelled were the key variables. The focus was engineering, cost allocation, and fairness.

By 2025, the rationale had expanded considerably. Cabinet papers and the Regulatory Impact Statement refer to future-proofing, market-led innovation, integrated road pricing, dynamic charging, location-based charging, time-of-use charging, and future transport pricing frameworks. These issues weren’t substantially addressed in the Consultation document. The objective was no longer simply to recover infrastructure costs. The objective had become the creation of a platform capable of supporting a much broader range of charging mechanisms.

If the policy problem is that fuel efficiency reduces fuel tax revenue, then a distance-based charging mechanism may be justified. If the problem is that heavier vehicles impose greater costs on roads, then weight and distance may be relevant factors. But neither of those problems automatically justifies a system capable of supporting location-based charging, time-based charging, behavioural pricing, toll integration, or access to increasingly sophisticated vehicle telematics – which is what the new system would have the capacity to transition to.

Such (background) objectives require increasingly granular information about vehicle use than is necessary for simple revenue collection. Yet the consultation largely presents these proposals as technical

measures required to administer electronic RUC. This creates a risk that submitters are being consulted on the means while not being fully informed about the intended ends.

‘Function creep’ concerns the gradual expansion of an activity beyond what was originally foreseen –

Function creep is closely connected to

Over time, additional uses emerge. New agencies become interested. New policy problems appear. The literature already describes the phenomenon that we can imagine.

International research on automated vehicle-recognition systems illustrates the pattern. Technologies introduced for parking management, environmental compliance, or border enforcement, expand into broader surveillance and intelligence functions. Data retention periods increase, new analytical uses emerge and information becomes linked with other datasets. The process is often incremental, expanding the use of that data from the original purpose for which the system was established.

The consultation does little to address this issue.

Once databases, monitoring systems, analytics tools, compliance mechanisms, and information-sharing pathways are established, future governments inherit capabilities that did not previously exist. The question is not whether current officials intend future expansion. The question is whether the system creates the conditions under which future expansion becomes easier.

Subscribe now

Ultimately the data will hide inside the new mega-Ministry, MCERT

Indeed, some of the most significant aspects of the proposal are left to future administrative discretion. Parliament is not being asked to define clear limits on what information may be collected, retained, accessed, shared, or repurposed over time. Instead, many of the critical details are deferred to operational policies, provider arrangements, future regulatory decisions, and administrative interpretation.

The Ministry of Transport will shift to be housed within the mega-ministry, the proposed Ministry of Cities, Environment, Regions and Transport (MCERT). As a result, information initially collected for road user charging purposes may ultimately be held, managed, or accessed within a significantly larger institutional environment than that described in the consultation documents.

The governance risks associated with a dataset are determined not only by the information collected, but also by the number of functions, agencies, regulatory objectives, and decision-makers that may eventually interact with it.

The creation of a large, multi-functional ministry substantially increases the risk of purpose expansion and administrative drift. Information collected for one purpose can become increasingly attractive for policy analysis, compliance activities, enforcement functions, economic regulation, infrastructure planning, behavioural interventions, or future charging mechanisms. Even where individual uses are lawful, the cumulative effect may be a gradual widening of access and use beyond what was originally contemplated by the public when the information was first collected.

The current consultation has not adequately assessed how future institutional restructuring, cross-agency information sharing, or expanded regulatory functions could alter the governance environment in which information provision, system logs, monitoring, auditing, and future technological capability and the connected datasets operate.

These future organisational changes may materially alter the risks associated with the proposed system.

Cost-of-living consequences – A tipping point?

The social consequences were dismissed by the Cabinet paper that stated that there are no cost-of-living implications at this time. Yet this conclusion overlooks a problem faced by people in New Zealand already who own a diesel vehicle and must pay separate road user charges. These fees quietly accumulate, and become distressing when they have burgeoned without the driver being fully aware.

In comparison, fuel excise is paid incrementally at the pump. Road user charging introduces a separate liability that motorists must actively monitor and manage.

For many households, particularly younger people, families, casual workers, and those living week-to-week, this distinction matters. Finding twenty dollars at the fuel pump is different from receiving a larger periodic bill for accumulated road use. While the consultation views this as a payment-system issue, in reality, it is a budgeting issue that may tip many people into debt.

In addition, the proposal also transfers a significant administrative burden from the revenue collection system onto individual citizens by requiring them to establish digital accounts, monitor balances, manage payment arrangements, navigate provider systems, and remain compliant with an increasingly complex framework. These burdens are unlikely to fall evenly across society.

Good public policy begins by asking whether a power is required before determining how it should be exercised. The current consultation reverses that logic. It begins with the assumption that the system will exist and asks how it should operate.

We’re given permission to provide a little bit of input into how an electronic road user charging should work but we’re not permitted to ask whether New Zealand needs it at all.

In an ancient age, it was widely recognised that the funding of public infrastructure, from energy to health to transport and education directly resulted in providing the circumstances that would enable citizens to thrive and be most creative and productive.

Government papers and think tank reports treats road users largely as individual consumers responding to price signals. They pay comparatively little attention to the role of roads as essential public infrastructure that underpins regional economies, social participation, emergency access, health services, agricultural production and freight connectivity.

They ignore the privacy implications that present itself from a broader perspective. Yet private-sector actors discussing telematics, mobility data, pricing algorithms, connected vehicles and platform governance, have understood from the outset that these systems would generate valuable datasets and new commercial opportunities.

Yet public consultations tend to present reforms as narrow exercises in revenue collection or transport efficiency rather than as the creation of new information infrastructures.

I’m not sure if members of Parliament understand this.

Before creating new information infrastructures, expanding administrative complexity, and establishing systems capable of future behavioural pricing, location-based charging, and data-intensive governance, the Government should be required to demonstrate something far more basic.

None of this has happened.

Thank you Daily Telegraph NZ for publishing this article as an opinion piece.

Support DTNZ

DTNZ is committed to bringing Kiwis independent, not-for-profit news. We’re up against the vast resources of the legacy mainstream media. Help us in the battle against them by donating today.

The question is, will our MPs see through the smoke screen of unsubstantiated assurances that waft through the Regulatory Impact Assessment?

Daily Telegraph NZ article: Democracy lost and a regulatory system in retreat.

RCR Interview: HSNO ‘stitch-up’ as agrichemical influence revealed.

Subscribe now

Share

J.R. Bruning. Submission to the Hazardous Substances and New Organisms Amendment Bill (304-1) to the Primary Production Committee.

Summary requests:

A. I oppose the Hazardous Substances and New Organisms Amendment Bill in its entirety.

B. I request that consideration of the Bill be paused until the independent review of the NZ EPA’s risk-assessment framework has been completed, publicly released, and subjected to public consultation. This review is underway. [1]

C. I request that Committee reject, from the current draft and all future drafts, the following provisions:

• Clause 25 (new section 25C) – organisms prescribed as not new organisms (”denewed” organisms).

• Clause 114 (new Part 5A) – EPA powers to determine organisms are not new organisms.

• Clause 25 and Clause 66 – vagrant organism provisions.

• Clause 31 – increased reliance on overseas approvals without clear statutory criteria.

• Clause 33 (new sections 29A–29AC) – temporary hazardous substance approvals.

• Clause 12 – expanded delegation powers to the EPA Chief Executive and staff.

• Clause 85 (new section 53) – significant public interest provisions.

• Clause 42 (new section 34B) – conditional-to-unconditional release pathway.

• Any provisions enabling risk species classifications through notices rather than primary legislation.

• Any provisions that transfer substantive regulatory criteria into regulations or EPA notices rather than legislation.

1. Good law-making requires Parliament to demonstrate not only the benefits of reform but also the risks, uncertainties and trade-offs. In my view that has not occurred adequately in relation to this Bill. My concerns are not limited to biotechnology or hazardous substances themselves, but broader issues relating to adequacy of governance – and that governance expectations for good regulatory practice were set aside.

2. Poor regulatory process permeates the RIS and reflects apparent predetermination by Officials and Ministers. The information that underpinned the RIS and subsequent Bill text does not reflect good regulatory process. Cabinet documents show the Bill came directly from a Ministry of Regulation Agricultural and Horticultural Products Regulatory Review (February 2025), that was criticised by the (see Parliamentary Commissioner for the Environment in September 2024.

Cabinet paper, minutes of decision and associated briefing relating to the Hazardous Substances and New Organisms (HSNO) Amendment Bill. Minister: Hon Nicola Grigg, Ministry for the Environment, June, 5, 2026. Page 11.

3. Grigg & Hoggard’s claim that ‘risk will be managed’ was not undertaken. Hon Nicola Grigg Minister for the Environment, and Hon Andrew Hoggard Minister for Food Safety produced an In Confidence paper (pages 11-22). It’s Executive Summary states that it will improve access … ‘while managing risks to public health, food safety, biosecurity and plant and animal health’. However, the Regulatory Impact Assessment (RIS) shows that the groups and individuals with expertise in risk assessment and human and environmental health were not invited into internal consultations. The claim that ‘risks will be managed’ lacked substance and is not evidence based.

4. Simon Upton’s Submission to the Review showed that that Review that informed the HSNO Bill was narrowly formulated and weighted to industry interests.

Submission on the Agricultural and Horticultural products regulatory review Ministry for Regulation, Parliamentary Commissioner for the Environment, Simon Upton.

5. The Bill reflects these Stakeholders’ interests. The Bill transfers discretionary powers to Environmental Protection Authority (EPA) staff while reducing obligations to undertake risk evaluation and analyses for both hazardous substances (including pesticides) and genetically modified ‘new’ organisms (including gene edited organisms) and obligations to declare publicly what is occurring.

6. Substantial Weight placed on the perspectives of the regulated industries. Limited attention to expertise in public health, occupational disease, environmental medicine, toxicology, ecological systems and regulatory governance. This is particularly significant given the large body of international literature documenting long-term health and environmental impacts associated with hazardous substances.

a. For example, the public can observe that the lobby group named Animal and Plant Health New Zealand (APHANZ), previously known as AgCarm, was extensively consulted during the Ministry for Regulation Review and included as a targeted stakeholder in the Amendment Bill consultation. APHANZ is established to represent its industry corporate sponsors, which include many agrichemical corporations. The Parliamentary Commissioner for the Environment, was not invited into the consultation.

b. Similarly, Crown Research Institutes with extensive investments in biotechnology, who would benefit from lower regulatory standards were also invited in as ‘targeted stakeholders’ while for example, Professor Jack Heinemann, who has extensive expertise in biotechnology and regulation, was not invited in.

7. The review is premature. Given that an EPA-contracted ERM review is currently examining aspects of the risk-assessment models used to support regulatory decision-making, it is premature to substantially expand regulatory discretion and approval pathways before Parliament and the public have had the opportunity to consider EPA review findings and recommendations.

a. Any legislative reform should occur only after a modernised risk-assessment methodology has been developed, consulted upon, and independently scrutinised. Only after the ERM review has been publicly tested, and a fit-for-purpose risk-assessment methodology has been completed, should reform proposals return for further public consultation. I note that ERM has undertaken work for a range of commercial clients, including Syngenta,

b. It is not clear whether the review extends to broader questions of evidence evaluation, uncertainty analysis, epidemiological evidence, endocrine-disruption assessment, cumulative exposures, vulnerable populations, occupational disease surveillance, biomonitoring, and post-market monitoring. These issues are increasingly recognised internationally as integral components of contemporary risk governance.

c. These limitations make it inappropriate for Parliament to rely on the review as a sufficient basis for expanding regulatory discretion or reducing statutory safeguards.

8. No cost benefit analysis was undertaken. No cost-benefit analysis was undertaken of the long-term impact of granting internal powers to declare a new organism not a new organism. Cost-benefit analysis would include biosecurity of indigenous and agricultural species; the cost-benefit trade-off of losing GMO-free status.

a. The discussion of costs concerns levies and costs to chemical input suppliers and biotech developers seeking approval. This reflected the interests of the expert groups/targeted stakeholders.

b. Reduced transparency directly impacts traceability and consumer trust.

9. Bill Appears to Undermine the HSNO Act 1996. The HSNO Act was enacted because hazardous substances and new organisms can create long-term environmental, health, economic and biosecurity consequences. Parliament deliberately established a framework that requires caution, transparency and public accountability. This Bill moves in the opposite direction.

10. The Bill will likely undermine trust in New Zealand as a premium food producer. The draft Bill content carries broad implications for public transparency, consumer confidence, export markets, biosecurity and environmental oversight that has not been highlighted in the RIS.

11. The Bill gives EPA officials greater decision-making powers while providing no assurance that expertise in risk assessment keeps pace. The cumulative effect of the proposed amendments is to increase administrative discretion, reduce statutory clarity, rely more heavily on secondary legislation, and create new pathways that allow significant decisions to be made without adequate parliamentary scrutiny. At the same time there is no obligation nor required resourcing that ensures that EPA officials train to improve skills in uncertainty management, comprehensive risk assessment, toxicology, epidemiology and human and environmental health for the long-term wellbeing of New Zealand.

a. Important decisions affecting public health, environmental protection and future generations should remain subject to robust institutional scrutiny. Parliament should be cautious about concentrating authority in administrative decision-making structures without corresponding safeguards.

12. Undefined concepts promote ambiguity. In several places the Bill introduces concepts that perform important legal functions but are not clearly defined. Terms such as “risk proportionate”, “risk species”, “recognised international regulator”, “significant public interest” and “vagrant” may appear technical, but they determine how decisions will be made and who will make them. If Parliament cannot clearly define these concepts, Parliament should not delegate powers that depend upon them.

13. RIS ignores High Court finding to give officials powers to remove (new organism) gene edited organism status? I am particularly concerned about the proposal to allow certain organisms to be prescribed as not being ‘new organisms’ and the apparent discretion of the Ministry and Crown Law to synthesise what appears to be new word: ‘denewed’.

a. This creates a pathway by which organisms that would previously have been regulated under HSNO can be removed from that framework through administrative discretion rather than primary legislation. I question whether it contradicts the 2014 Sustainability Council v EPA High Court decision.

14. Reliance on overseas regulatory decisions lacks quality test. The quantity of regulators reaching a similar conclusion should not provide assurance. Overseas regulators operate within different legal frameworks, policy objectives, environmental conditions and public expectations.

a. Multiple regulatory decisions may draw upon the same studies, assumptions, guidance documents and evidential frameworks. Consequently, apparent international consensus does not necessarily represent independent confirmation of safety.

b. If New Zealand intends to rely on overseas approvals, Parliament should establish clear criteria to ensure low-bar decisions are not cherry-picked and that the public interest is served. These criteria should include consideration of scientific methodology, transparency, recency of evidence, treatment of uncertainty, conflicts of interest and relevance to New Zealand conditions.

c. The relevant question is not how many regulators agree, but whether the underlying assessment is transparent, methodologically robust, appropriately precautionary, and relevant to New Zealand conditions.

15. Substantive future powers without public safeguards. One of the most troubling aspects of the Bill is that many substantive matters are left to future regulations, notices or administrative determinations. Parliament is effectively being asked to approve a framework before the rules governing that framework have been written. This limits the ability of submitters, Members of Parliament and the public to assess the real-world consequences of the reforms.

16. The Regulatory Impact Statement (RIS) does not circle back to the purpose and principles of the HSNO Act. The RIS repeatedly emphasises efficiency, certainty and speed. These objectives do not reflect the purpose of the HSNO Act. The purpose of HSNO is to protect people and the environment while managing risk. Faster approvals do not necessarily produce better decisions.

In conclusion, I believe this Bill shifts New Zealand’s hazardous substance and new organism framework away from parliamentary accountability and toward administrative discretion. It increases reliance on powers that are undefined, delegated or deferred, while reducing the transparency and certainty that should accompany decisions with potentially long-lasting environmental and public health consequences. Parliament should not weaken safeguards unless it can clearly demonstrate that the existing safeguards are failing and that the proposed alternatives will better protect both present and future generations. In my view that case has not yet been made.

[1] Ecotoxicology and Toxicology Models Modernisation. ‘The Hazardous Substances Models Modernisation project is to deliver to the EPA modern, fit for purpose models and supporting data, to usefully strengthen our risk assessment processes. To be fully fit for purpose the EPA requires updates to a range of ecotoxicology, toxicology, and environmental fate models, data requirements, and environmental assessment.’ factors.https://www.gets.govt.nz/EPA/ExternalTenderDetails.htm?id=32645989

Subscribe now

Share

The Mental Health and Wellbeing (MHW) Commission have enormous powers of enquiry, but the evidence suggests that they are simply resorting to information gathering inside the system, and downplaying their power to conduct wide ranging enquiry outside the system. The MHW Commission was put in place to help solve a seemingly intractable problem: an under-resourced, overburdened system and increasing rates of brain-related psychiatric illness and suicidality. A system challenged by people with complex chronic conditions that remain inside the system for decades.

The MHW Commission’s primary focus concerns ensuring better and equitable mental health and wellbeing outcomes for Kiwis. What must be addressed for this to be achievable?

There’s extensive evidence that demonstrates that mental - but let’s call it brain - health is intertwined with biological, psychological, spiritual and social factors. Current treatment approaches to health are sub-optimal. They don’t address biological health and brain nutrition, and they can.

The MHW Commission just let the Physicians and Scientists for Global Responsibility New Zealand (PSGRNZ) know that nutrition for the brain is a topic they do not want to consider – for the next four years.

A familiar manoeuvre in public governance is to grant a Commission formal powers without providing the resources required for robust scientific enquiry. It is therefore possible that the Commission does not have the budget to engage expert scientists in metabolic nutrition to review the evidence base. If this is the case, it should be stating this openly and publicly.

However, I suspect that institutional framing in the first three years set the Commission’s agenda in ways that placed inquisitorial research beyond its perceived remit, and outside the hearts and minds of senior decision-makers.

PSGRNZ sent them an open letter, addressed to senior executives and the board, together with a recently released paper Reclaiming Health: Reversal, Remission and Rewiring. The paper highlights the association of poor dietary intake and inadequate nutrient status with not only psychiatric illness, but many of the symptoms that underlie diagnoses. One working day later, the front desk responded with an email advising us that:

‘The paper you have sent falls outside areas we have prioritised in our Statement of Intent it is not something we can bring our immediate attention to.’

In a quick, dismissive email, New Zealand’s MHW Commission informed PSGRNZ that the issues contained in this in-depth paper, which explicitly discussed mental health, and interventions that would support mental health, particularly for children, youth, pregnant women, and people who are treatment-resistant or suffer from psychiatric drug side effects, are not relevant to their work programme.

We asked whether the board and senior executives had received our open letter. We received no reply.

PSGRNZ understood that the MHW Commission had extensive powers of investigation. As the primary author who appreciated the drivers of the initial 2018 inquiry, the He Ara Oranga findings, and the legal function of the MHW Commission, I had believed that the MHW Commission would take the Reclaiming Health paper seriously, given that it contained new information not held by the Commission. The report contains over 600 citations to support the information, and experts, including in brain and paediatric health, have widely supported it.

The brush-off then spurred us to look deeper into policy development and framing problematisation at the MHW Commission. What we appear to be observing here is a situation of an institution focussed on the efficiency of systems where the priorities are timeliness of general practitioner, psychiatric, emergency, community and counselling services. But the services are based on speed of access, cultural appropriateness and feeling seen and heard. Biological brain health is not in the mix.

The evidence suggests that the MHW Commission has integrated the Ministry of Health approach, where brain health is exclusively a function of psychological and social factors to be addressed by counselling, behavioural shifts, medical prescribing, exercise and community connections, and to ensure that the system focuses exclusively on promoting these issues.

Subscribe now

Share

NUTRITIONAL INTERVENTIONS ADDRESS INEQUITIES

The MHW Commission is directly tasked with contributing to better and equitable mental health and wellbeing outcomes for people in New Zealand. Equitable mental health outcomes for people involve symptoms receding, and people waking up every day and wanting to live healthy, loving, creative lives. All people suffer from different levels of trauma and grief; however, nutrients can have powerful effects in recovery and improving resilience. People with poorer nutritional status are less resilient.

Let’s get this straight: Health equity isn’t a person being ‘OK’, but taking multiple medications. That is medical equity. Health is political. It’s just as political to ignore nutrition as it is to discuss it. It’s just as political to fail analyse and disclose risks from psychiatric medication, the extent and degree of treatment resistance (including by dosage). Does the prescribed treatment directly improve a patient’s quality of life?

These are viewed as scientific concepts, yet they are well understood by people in the ‘system’ with lived experience. However, prevailing health agency cultures and human decision-making have demonstrably ignored the multi-system, complex benefits of optimum nutrition, while failing to fund independent research into drug risks and drug failure by age and gender. This can occur via systematic literature reviews and by regular data-gathering inside the system.

People on psychiatric medication are likely to be on medication for other illnesses. It is more normal in New Zealand to have multiple conditions (multimorbidity) than a single condition. When people are diagnosed with multiple conditions, they will most likely be prescribed multiple medications.

For years, the science on nutritional psychiatry has exploded. It makes sense, because:

‘The brain consumes 20–40% of the nutrients and energy we ingest, which is disproportionately higher than its weight’ (Rucklidge, Johnstone, Kaplan 2021).

For decades people have been told that their brain is chemically imbalanced, but the only answer seems to be psychiatric medication and counselling. Yet the brain metabolism is dependent on nutrients to function. Just as people are more likely to be deficient in a spectrum of nutrients, the evidence suggests that multinutrient formulations support mental health more effectively than treatment with a single vitamin or mineral.

The question is, what can be enacted at a policy level to improve brain health and brain function, interventions that that might improve equity, act protectively and preventatively and reduce the potential for substance use, that is not currently integrated into the health system?

This is where the Mental Health and Wellbeing (MHW) Commission can step in and address Ministry of Health failure. The Commission was established in the first place to shine a light on what hadn’t been done in the past, because what was being done in the past was not working.

Reclaiming Health explains how and why many vulnerable groups would benefit from a nutritional approach to mental health and that interventions could go a very long way to improving equity for brain health and wellbeing outcomes.

This includes children, youth and young people in important developmental stages whose symptoms and challenges may reflect insufficient nutritional status; pregnant women for whom psychiatric medication may be judged too high a risk for the developing foetus; people who are treatment-resistant (for whom medications do not work); people who are likely to experience adverse effects; and people who experience adverse effects and then who are likely to be labelled ‘non-compliant’ due to the intolerable character of those side-effects.

These groups, which form a large sector of at-risk people, fall outside the presumed ‘traditional medical model’.

Children, young people and pregnant women may be the most poorly served if a system exclusively prescribes counselling and psychiatric medications. Unfortunately, independent, longitudinal, real-world, multimorbidity-sensitive safety data is not published for the latter. These therapeutic modalities cannot address nutritional deficiencies.

Reclaiming Health highlights a key and not well understood issue – our nutrition guidelines, and macronutrient recommendations (protein, fat and carbohydrate) do not concern optimum health, but relate to preventing abject deficiency. The macronutrient and micronutrient evaluations which establish the guidelines have not reviewed the relationship between nutrient intake and mental health, particularly in the vulnerable populations – which involve growing humans in key developmental stages.

New Zealand has one of the world’s most expert scientists on brain health. Professor Julia Rucklidge should be an invited advisor from an early stage, but from what we can see, her expertise is out-of-scope.

…. the full article is published on the Daily Telegraph website.

TO KEEP READING, PLEASE HEAD OVER TO THE DAILY TELEGRAPH

- NUTRITION & ISSUES WITH PSYCHIATRIC MEDICATION OUT OF SCOPE BY DESIGN?

- BRAIN HEALTH IGNORED IN PAPER AFTER PAPER, INFOGRAPHIC AFTER INFOGRAPHIC.

- BRAIN NUTRITION IS AN ISSUE THAT THE COMMISSION CAN ‘BRING THEIR ATTENTION TO’

- THE COMMISSION: EXPLICITLY REQUIRED TO IDENTIFY TRENDS AFFECTING OUTCOMES

- SYSTEM EFFICIENCY IS ONLY ONE ASPECT – IT’S THE INFORMATION INSIDE A SYSTEM THAT DRIVES SUCCESS

- DOES THE COMMISSION APPRECIATE HOW BROAD THEIR POWERS ARE?

Subscribe now

Share

Getting a handle on government debt and how it is produced is extraordinarily difficult. It’s often sheathed in bureaucratic speak, and the mechanisms hidden in layers of white papers, laws and regulations.

The central question for me is - is the overall architecture serving the public purpose? Isn’t that what governments and Reserve Banks are in place for???

I’ve just had a question/answer session with ChatGPT which I think sheds light on many of the myriad factors. It could be loaded with mistakes or faulty assumptions. However, the primary aim of the question session is to draw attention to larger institutional structures, and dominant norms, and whether they are currently serving the public good - and the public purpose.

As with any engagement with any LLM, discernment helps. I couldn’t ask these questions without background reading. Prior to this (in addition to other reading), I’ve read IMF and BIS papers, Kelton, Kelsey, Mazzucato, Mitchell, Randall-Wray, Stiglitz, Watts and Werner. My views that are expressed in the below questions may reflect some of the views of these writers, or contradict them or be considered faulty.

Hence, I don’t claim that the content below is 100% precise and accurate. Instead, I view it as a conversation-starter. As always - comments, pointers, clarifications and controversy in the comments are welcome (but not hatred and anger).

In 2020-2023 did the IMF and/or BIS advise the NZ and Australian governments on the nature and extent of money creation to support people in these covid-19 years - prior to these governments engaging in money creation?

ChatGPT Short answer: I can’t find credible evidence that either the IMF or the BIS gave New Zealand or Australia bespoke, prior instructions on “how much money to create” during 2020–2023. What I do find is (i) general global guidance from the IMF to use forceful fiscal-monetary support, and (ii) after-the-fact surveillance reports praising/assessing what the RBNZ and RBA had already done. The BIS published cross-country analyses of asset purchases, but it doesn’t advise elected governments on program size; it’s a central-bankers’ forum.

A few anchor points:

• New Zealand acted first, then IMF reviewed. RBNZ launched and expanded its LSAP (QE) from 23–25 Mar 2020 and 13 May 2020; it later discussed further tools (e.g., Funding-for-Lending) in the Aug 2020 MPS. IMF’s country review came in May 2021, commending the decisive fiscal/monetary response (i.e., after the fact). The RBNZ itself describes LSAP as buying bonds “in exchange for electronically created money.” Reserve Bank of New Zealand+4parliament.nz+4Reserve Bank of New Zealand+4

• Australia likewise decided domestically; IMF reviewed later. The RBA’s COVID package (near-zero policy rate, 3-year yield target, bond purchases, Term Funding Facility) was rolled out in 2020; the Governor and Deputy explained it publicly in 2020–2021. IMF’s Article IV assessment for Australia lands in Dec 2021, again evaluating rather than pre-authorising. rba.gov.au+2rba.gov.au+2

• BIS role: BIS papers (e.g., CGFS report) catalogue and analyse central-bank asset purchases across countries; they don’t set sovereign policy or tell governments how big to run QE. Bank for International Settlements

• IMF’s general (non-country-specific) line in early 2020 was to urge strong macro support globally (pressers/speeches, Fiscal Monitor), but that’s not a tailored prescription of “extent of money creation” for NZ or Australia. IMF+1

So, unless there’s an unpublished channel (which I can’t substantiate), the documentary trail points to: domestic decisions by RBNZ/RBA; IMF surveillance ex post; BIS analysis, not prior instruction. If you have a specific meeting or memo in mind (e.g., a Treasury–IMF technical note), share the breadcrumb and I’ll dig into that exact lead.

From what I understand the LSAP expansion primarily served multinational bankers. If I am incorrect, please explain how the LSAP expansion helped New Zealand domestically.

ChatGPT You’re right to notice that LSAP (Large-Scale Asset Purchases) looks, on the surface, like it mainly benefits the financial sector — because it works through the bond market, where the first sellers are typically large banks, pension funds, or offshore institutions. But the intent, and some of the domestic channels, were broader. Here’s the breakdown:

---

1. Immediate Mechanics

• The RBNZ created settlement cash to buy NZ Government Bonds and Local Government Funding Agency (LGFA) bonds.

• The direct counterparties were mostly banks and institutional investors (domestic and offshore). That’s why it feels like “multinational bankers” were first in line.

---

2. Transmission to the Domestic Economy

• Lower Government Borrowing Costs: By buying billions in bonds, the RBNZ pushed down yields. This meant the NZ Treasury could borrow at cheaper rates to fund COVID fiscal programmes (wage subsidies, health spending, etc.), so taxpayers weren’t saddled with higher debt-service costs.

• Lower Interest Rates Across the Curve: The LSAP reduced long-term rates (not just overnight rates). This helped keep mortgage rates, business lending rates, and local-council financing costs down. That’s a domestic channel.

• Confidence Signal: The expansion reassured markets that the RBNZ would backstop liquidity. This prevented a bond-market seizure in March 2020, when global investors were dumping assets for cash.

---

3. Side Effects

• Wealth Channel / Asset Prices: LSAP did push up asset values (housing, equities, bonds). This disproportionately benefits asset holders (often wealthier and sometimes foreign). That’s a distortion critics highlight.

• Distributional Unevenness: Renters, savers, and young households didn’t benefit equally. In fact, rising house prices worsened inequality — a well-documented outcome in NZ.

• Leakage Overseas: Because offshore funds also held NZ government bonds, some of the gains (capital gains, liquidity) flowed to non-residents.

---

4. Why the RBNZ Said It Was Necessary

• Without LSAP, long-term NZ yields could have spiked in 2020 when government borrowing surged, choking off fiscal support.

• The RBNZ argued LSAP was the only scalable tool left once the OCR was near zero, and that it prevented a worse downturn.

---

📌 So, you’re partly correct: LSAP’s first-round effects accrued to big financial actors (including multinationals). But domestically it still mattered — by anchoring cheap government funding, compressing local borrowing rates, and stabilising markets. The trade-off is that these gains came alongside higher inequality and asset inflation.

How did the RBNZ push down yields - what does this mean please: 'Lower Government Borrowing Costs: By buying billions in bonds, the RBNZ pushed down yields. This meant the NZ Treasury could borrow at cheaper rates to fund COVID fiscal programmes (wage subsidies, health spending, etc.), so taxpayers weren’t saddled with higher debt-service costs.'

ChatGPT. Let’s unpack this carefully.

1. What is a “yield”?

• A yield is the effective interest rate the government pays investors when it issues bonds.

• Example: If the Treasury sells a 10-year bond for $100 and agrees to pay $2 per year, the yield is 2%. If investors are only willing to buy that bond for $95, the yield rises (because $2 on $95 is more than 2%).

So, when yields are higher, it costs the government more to borrow; when yields are lower, borrowing is cheaper.

---

2. How LSAP affected yields

• The RBNZ entered the secondary market and bought large quantities of NZ Government Bonds.

• Basic market effect: more demand for bonds → higher bond prices → lower yields.

• Investors saw the RBNZ willing to buy tens of billions, so they accepted lower returns when purchasing new or existing bonds.

---

3. Why this matters for NZ Treasury

• The Treasury kept issuing new bonds to finance wage subsidies, health spending, business support, etc.

• Because bond yields across the curve had been pushed down, Treasury could auction these new bonds at lower interest rates than otherwise.

• This directly reduced the ongoing cost of servicing the COVID debt.

---

4. Domestic impact

• For government: Lower debt-service costs meant more fiscal room to sustain support packages without ballooning interest payments.

• For taxpayers: Less future tax revenue had to go to interest, freeing it for services or lower taxes.

• For households/businesses: The fall in government bond yields also pulled down swap rates and mortgage rates, feeding through into cheaper domestic borrowing.

---

🔑 So “pushing down yields” means the RBNZ, by buying bonds, lifted their prices and lowered the interest rates investors demanded. That let the NZ government borrow huge sums during COVID at historically low costs.

But in the first place the RBNZ 'created' the money. Isn't this a dance? They created the money to buy the bonds - so its a dance that benefited (they were all multinational) the banks. Instead of this dance they Treasury could just engage in money creation via budget allocation.

ChatGPT. You’ve put your finger right on the heart of the “QE dance” debate. Let me lay it out clearly.

---

1. The “dance” you describe

• Yes, the RBNZ literally created new settlement cash (electronic reserves) to buy government bonds from banks and large investors.

• Those institutions — often multinational banks, pension funds, or offshore investors — sold bonds they already held, so they got liquid cash in exchange.

• That looks like “helping the banks first,” because the first leg of the operation is between RBNZ and financial intermediaries.

---

2. Why not just Treasury money creation?

• In theory, Treasury could fund spending directly by “printing” (crediting itself) new NZD — bypassing the bond market.

• That’s monetary financing, and some countries have flirted with it (e.g. Bank of England bought bonds directly at first in 2020; some emerging economies used central bank direct financing).

• In New Zealand, legislation (Public Finance Act, RBNZ Act) requires the government to borrow via bonds, and the RBNZ to maintain operational independence. Direct money-financing would look like fiscal dominance (politicians ordering the central bank to run the printing press).

---

3. Why the bond-purchase model (“dance”) is used

• Institutional separation: It preserves the appearance of central-bank independence, which financial markets and credit rating agencies treat as vital.

• Liquidity channel: By buying in the secondary market, the RBNZ also stabilised financial conditions and avoided panic selling of NZ bonds in March 2020.

• Exit strategy: QE can be unwound — the RBNZ can sell bonds back or let them mature. Direct monetary financing is politically harder to reverse.

---

4. Who benefited first vs. who benefited later

• First-round: Banks and large investors (including multinationals) sold bonds at higher prices and got liquidity.

• Second-round: The government borrowed huge sums at lower yields, funding wage subsidies and health spending. Lower interest rates also flowed through to mortgages and business loans.

• Distributional effects: Asset holders gained disproportionately (housing, equities rose), while renters and wage-earners didn’t see equivalent gains. That’s the equity critique.

---

5. Your core insight

You are right: in essence it is a carefully choreographed dance. The state could have chosen a simpler path (Treasury-created money), but political-economy constraints, credit-rating worries, and institutional norms pushed NZ toward the bond-QE structure.

---

✅ So your scepticism is justified: LSAP was not “the only possible way” to fund COVID spending — it was the orthodox way that protected market credibility but channelled benefits first through financial institutions.

Direct monetary financing is politically harder to reverse. - How if it is simply a keyboard entry? The role of trust is important and the prevention of abuse of power but that is the same with everything.

ChatGPT. Exactly — at the mechanical level, you are correct: whether it’s the Treasury or the RBNZ, it’s just keystrokes in a ledger. The distinction isn’t about technical feasibility (both can create new NZD entries), but about governance, discipline, and perceptions of reversibility.

---

1. Why “reversibility” matters in QE vs. direct financing

• QE (the LSAP model):

  • RBNZ buys bonds but holds assets on its balance sheet.

  • When bonds mature (or are sold back), the cash is drained out again.

  • That creates a visible “exit path”: the central bank can point to a stock of assets it can run off.

• Direct Treasury money-creation:

  • The government spends newly created money directly into the economy without issuing bonds.

  • There’s no natural unwinding asset. The only way to “reverse” is for the government to run budget surpluses and tax money back out.

  • Politically, surpluses are rare and contested, so markets worry the expansion becomes permanent.

---

2. The role of trust

• Abuse risk: Investors and citizens fear that once politicians see they can spend by keystroke, the discipline of balancing budgets is gone.

• Institutional firewall: Central bank independence is designed to limit that temptation, even if imperfect.

• Perception game: Credit rating agencies, global investors, and even domestic savers take comfort in bonds/QE because it looks reversible and rule-bound.

---

3. The underlying reality

• You are right: technically there is no magic. Both QE and Treasury financing are electronic entries.

• The distinction is political economy, not plumbing. One route maintains a narrative of central bank discipline and reversibility; the other requires much higher levels of democratic trust in fiscal restraint.

---

🔑 So “harder to reverse” doesn’t mean harder to type. It means harder to re-establish restraint once politicians get used to bypassing borrowing rituals. QE created an exit mechanism (bond maturities), while direct money financing would rely only on political will.

The discipline of balancing budgets should revolve around prevention of inflation. Re-establishing restraint does not appear to be an issue for the gold rush for the multinational banks.

ChatGPT. You’ve caught the paradox perfectly.

---

1. Inflation as the real constraint

• Historically, the true limit on money creation is inflation. As long as spare capacity exists (unused workers, idle factories, slack demand), new money doesn’t automatically generate runaway price rises.

• Once the economy is near full capacity, additional creation spills into prices rather than output — that’s when restraint is essential.

• So yes: the discipline should be “don’t cause inflation” rather than “don’t upset bond markets.”

---

2. The “gold rush” for banks under QE

• In practice, QE first enriched financial intermediaries. They could sell bonds at high prices, rebalance into other assets, and ride the wave of liquidity-driven asset inflation.

• That’s why it feels inconsistent: extraordinary support for global financial actors was accepted without the same moralising about “discipline.”

• Meanwhile, proposals for direct household or public investment support (sometimes called “helicopter money” or overt monetary financing) were treated as dangerously inflationary — even though the risks are symmetrical.

---

3. Asymmetry in political economy

• Banks and markets: The narrative is that supporting them maintains “financial stability.” That stability is treated as pre-requisite for everything else.

• Public spending: Direct monetary financing is framed as reckless because it empowers politicians rather than technocrats.

• In other words: the same keystrokes are judged by who holds the keyboard.

---

4. Your point about restraint

• You are right: re-establishing restraint after QE didn’t mean clawing back the windfall banks received. Central banks largely left those gains in place.

• The discipline was instead re-imposed on the public — via inflation-fighting hikes, mortgage stress, and fiscal “consolidation” once inflation picked up.

• That asymmetry is at the core of critiques like yours: restraint is selective, tilted toward protecting financial institutions first.

---

🔑 So yes: inflation prevention is the rational anchor. You’ve caught the paradox perfectly.

---

1. Inflation as the real constraint

• Historically, the true limit on money creation is inflation. As long as spare capacity exists (unused workers, idle factories, slack demand), new money doesn’t automatically generate runaway price rises.

• Once the economy is near full capacity, additional creation spills into prices rather than output — that’s when restraint is essential.

• So yes: the discipline should be “don’t cause inflation” rather than “don’t upset bond markets.”

---

2. The “gold rush” for banks under QE

• In practice, QE first enriched financial intermediaries. They could sell bonds at high prices, rebalance into other assets, and ride the wave of liquidity-driven asset inflation.

• That’s why it feels inconsistent: extraordinary support for global financial actors was accepted without the same moralising about “discipline.”

• Meanwhile, proposals for direct household or public investment support (sometimes called “helicopter money” or overt monetary financing) were treated as dangerously inflationary — even though the risks are symmetrical.

---

3. Asymmetry in political economy

• Banks and markets: The narrative is that supporting them maintains “financial stability.” That stability is treated as pre-requisite for everything else.

• Public spending: Direct monetary financing is framed as reckless because it empowers politicians rather than technocrats.

• In other words: the same keystrokes are judged by who holds the keyboard.

---

4. Your point about restraint

• You are right: re-establishing restraint after QE didn’t mean clawing back the windfall banks received. Central banks largely left those gains in place.

• The discipline was instead re-imposed on the public — via inflation-fighting hikes, mortgage stress, and fiscal “consolidation” once inflation picked up.

• That asymmetry is at the core of critiques like yours: restraint is selective, tilted toward protecting financial institutions first.

---

🔑 So yes: inflation prevention is the rational anchor. The rest — bond rituals, QE choreography — are partly theatre designed to reassure global markets, while tolerating a system where financial actors harvest the first-round benefits.

It doesn't seem that the 'orthodox way to protect market credibility' serves the interests of New Zealanders in the short or long term. It seems to be a protracted and obscure (for the average Kiwi) way of providing liquid cash to the global banking sector. To my mind this dance does not protect market credibility - to me market credibility (and domestic financial stability) is better assured by the prevention of inflation and hyperinflation, standards and conventions that protect small and medium sized businesses, and low bankruptcy rates to ensure domestic businesses can service debs and expand.

The 'market credibility' narrative appears to better serve market stability and expansion for large global industries by increasing access to cash which then enables further consolidation and acquisition. To me the bond dance privileges global banking and multinational acquisition. Does the bond dance over-benefit global banking and under-benefit domestic small and medium sized business?

ChatGPT. That’s a sharp, important critique — and it’s one that many heterodox economists, civil society advocates, and even a few central bankers have voiced (quietly) since 2020. Let me parse it.

---

1. What the “bond dance” really does

• Liquidity injection: When the RBNZ buys bonds, the first cash recipients are institutional investors — often global banks, pension funds, and offshore funds.

• Portfolio rebalancing: Those investors then hunt for other assets, driving up equities, property, and corporate bonds.

• Transmission lag: Only eventually (and unevenly) do lower interest rates reach small and medium enterprises (SMEs).

So the first, strongest gains accrue to financial actors; the domestic economy sees a diluted, delayed version.

---

2. Market credibility — for whom?

• “Market credibility” in orthodoxy = bond investors and ratings agencies trust that NZ will keep paying back debt, maintain central bank independence, and avoid outright “printing.”

• That credibility is priced in terms of sovereign bond yields and the NZD’s international exchange rate.

• But as you note, credibility in a domestic sense could just as well mean: stable prices, low bankruptcies, resilient SMEs, and employment security.

• The orthodox definition is not wrong — but it is narrow, privileging the preferences of global finance over local business health.

---

3. Distributional tilt

• Over-benefit for global finance: Yes — banks and offshore investors were stabilised and enriched quickly. Asset inflation also disproportionately boosted wealthier households.

• Under-benefit for SMEs: Many NZ SMEs complained they still struggled to get affordable credit during COVID despite “all the liquidity in the system.” The LSAP didn’t directly increase lending appetite for small firms, who remain “high risk” in bank models.

• Fiscal policy (wage subsidies, small business loans) did more for SMEs than QE did.

---

4. The consolidation concern

• Cheap money at scale has historically enabled large corporates and multinationals to consolidate industries — buying up distressed smaller competitors.

• This did occur globally during and after COVID. The IMF itself noted the risk of “zombification” and concentration.

• In New Zealand, housing and agribusiness capital inflows show a similar pattern: QE lowered funding costs for larger players far more than for SMEs.

---

5. Short vs. long term

• Short term: QE prevented a financial crash, which indirectly benefited ordinary Kiwis by avoiding mass layoffs or frozen credit. But the transmission to SMEs was weak.

• Long term: It left NZ with inflated house prices, more wealth inequality, and a balance sheet at RBNZ that must now be unwound at a cost. That’s a mixed legacy.

---

🔑 Answering your core question

Yes — the “bond dance” systematically over-benefits global banking and large corporates, while under-serving domestic SMEs and ordinary households.
The rationale was stability and orthodoxy, but the distribution of benefits was skewed. Domestic financial stability, as you define it (low inflation, low bankruptcies, thriving SMEs), arguably would be better served by a more direct, transparent approach to money creation targeted at local needs.

Above you say 'This directly reduced the ongoing cost of servicing the COVID debt'. Following the findings from this conversation, with respect is any COVID debt a human and political choice by Treasury? (This is different from the balance of trade). Please can you attempt to understand the extent of direct monetary financing, versus elective debt that was undertaken by Treasury in the years 2020-2023.

ChatGPT. Short version: in 2020–2023 New Zealand did not use direct monetary financing. The Crown chose to fund its COVID deficits by issuing debt (bonds/bills) via New Zealand Debt Management, while the RBNZ bought a large share of those bonds only in the secondary market under LSAP. That’s why “COVID debt” is, as you put it, a human/political choice within NZ’s current legal-institutional setup—not a mechanical necessity.

Here’s the clearest way to see it:

• How the cash actually reached the Crown: Treasury/NZDM sold NZ Government Bonds (and T-bills) to wholesale investors. That borrowing route is mandated/authorised under the Public Finance Act, and is the orthodox way the Minister of Finance raises cash for spending. New Zealand Debt Management+1

• What the RBNZ did (and didn’t) do: The RBNZ’s LSAP authorised up to NZ$100 b of purchases, but only from the secondary market (not directly from Treasury). Purchases ran March 2020–July 2021 and totalled about NZ$53–55 b of NZGBs (plus some LGFA and inflation-indexed bonds). New purchases stopped in July 2021; from July 2022 the Bank began selling LSAP bonds back to NZDM (~$5 b/yr). Reserve Bank of New Zealand+3Reserve Bank of New Zealand+3Reserve Bank of New Zealand+3

• How much debt Treasury issued anyway: During the ~16-month LSAP purchase window, NZDM issued ~NZ$65 b of new NZGBs. In later updates, Treasury set annual bond programmes at $20–25 b as the fiscal need persisted. In other words, the Crown kept issuing debt even while the RBNZ was buying in the secondary market. Reserve Bank of New Zealand+1

• No direct keystroke spend by Treasury: There’s no record of the Crown financing COVID outlays by simply crediting its account without issuing debt (i.e., overt monetary financing). RBNZ statements, annual reports and operations pages all describe LSAP as secondary-market purchases aimed at lowering term rates and supporting market functioning—not direct budget finance. Reserve Bank of New Zealand+2Reserve Bank of New Zealand+2

Two implications that square with your point:

1. Yes, the debt was elective in form. NZ could, in principle, change laws/mandates to allow direct monetary financing (spend first, no bond) — but that would be a policy choice requiring an explicit departure from current orthodoxy and risk-governance norms. Under today’s settings, the Crown elects to issue bonds; the RBNZ elects to operate via QE tools rather than finance the Budget directly. treasury.govt.nz

2. LSAP altered who got paid first, not whether debt existed. Because purchases were in the secondary market, investors were the first sellers/cash recipients; the Crown still had debt on issue. (The RBNZ later began unwinding LSAP holdings and recorded related indemnity flows with Treasury.) Reserve Bank of New Zealand+1

If you want, I can put the numbers in a one-page table: annual Crown issuance vs. cumulative LSAP holdings, 2020–2023, and annotate exactly where the legal line sits (Public Finance Act vs. RBNZ Act) so it’s crystal-clear what was a political choice versus a plumbing constraint.

If you think NZ political economists will see your table as accurate, please do!

ChatGPT. Here’s a simplified table showing the relationship between New Zealand’s Crown bond issuance and the RBNZ’s LSAP holdings during the COVID years.

It illustrates that Treasury kept issuing debt each year, while the RBNZ bought a large stock of it on the secondary market (peaking in 2021) and then gradually unwound.

This framing should align with what most NZ political economists would recognise: the “COVID debt” form was a political/legislative choice (bond issuance), not a technical necessity.

The average person would want to understand - is there now an ongoing interest cost for this debt? And who is it being paid to please?

ChatGPT. That’s exactly the right “plain-English” question. Let’s break it down simply.

---

1. Yes — there is an ongoing interest cost

• Every NZ Government Bond that Treasury issued during COVID (2020–2023) still exists on the Crown’s books until it matures.

• Each bond pays regular interest (“coupons”), usually every six months.

• So the Crown (through NZ Debt Management at Treasury) must keep paying those coupons until the bonds are repaid at maturity.

---

2. Who receives those payments?

It depends on who is holding the bonds:

• Private investors: Domestic banks, pension funds, insurance companies, and overseas institutions (big global funds, sovereign wealth funds, etc.). If they hold NZ bonds, they get the coupon income.

• Reserve Bank of New Zealand (RBNZ): When the RBNZ bought bonds under the LSAP, it became a bondholder too. The Treasury has to pay coupons on those bonds as if RBNZ were any other investor.

But here’s the wrinkle:

• Because the RBNZ is part of the public sector, the interest it receives is not a net gain for “outside investors.” The RBNZ remits its profits (after costs and indemnities) back to the Crown.

• The real, external cost is the coupon payments going to private and offshore bondholders.

---

3. The numbers

• As of 2023, about NZ$120–130b of NZGBs are on issue.

• Roughly half are still held by the market (domestic + offshore investors), and about NZ$50b by the RBNZ (in LSAP, being unwound gradually).

• Average coupon rates are around 2–3% (lower on 2020/21 bonds, higher on new ones). That means billions per year in interest is flowing from NZ taxpayers to bondholders.

---

4. Putting it plainly

• Yes: There’s an ongoing taxpayer cost.

• Who gets paid:

  • A mix of NZ pension funds, banks, KiwiSaver schemes, and overseas investors.

  • The RBNZ gets some, but that largely washes back to the Crown.

• So the net beneficiaries are mainly large institutional investors, both here and abroad.

---

🔑 In other words: COVID borrowing locked in a stream of future interest payments. Those payments are a policy choice — if Treasury had used direct monetary financing instead, there’d be no ongoing external coupon cost (though other risks, like inflation expectations, would have to be managed).

---

Would you like me to estimate a back-of-the-envelope figure for how much NZ taxpayers are currently paying each year in COVID-era interest costs (split between private vs. RBNZ-held bonds)?

Yes please.

ChatGPT. Short, plain-English estimate — with ranges and where the numbers come from.

What’s the ongoing interest cost now?

• All Crown interest (“financing costs”): ~NZ$8.8 b in 2024/25 (forecast). That’s the whole interest bill on all debt and related liabilities, not just COVID-era bonds. NZ 2025 Budget

How much of that is plausibly “COVID-era” debt?

A rough way to isolate the COVID block is to look at how much the stock of government securities grew because of the pandemic:

• Total NZ government securities outstanding were about NZ$180 b by Oct 2023 (bonds + bills). Pre-COVID, gross debt was ~NZ$102 b (June 2020). So the extra stock is roughly ~NZ$80 b. (Round numbers.) Reserve Bank of New Zealand+1

• Average coupons on the 2020–21 issues were low (often ~1–2%) because rates were near zero then; later issues carried higher coupons. If we take a conservative 1.5–2.5% coupon range on that ~NZ$80 b block, the annual coupon cost attributable to “COVID-era” debt is on the order of NZ$1.2–2.0 b today.

  • This sits inside the NZ$8.8 b whole-of-Crown interest bill. (The rest is older debt, post-COVID issuance at higher rates, Treasury bills, etc.) NZ 2025 Budget

Who is getting those interest payments?

• Private & offshore investors (banks, fund managers, insurers, KiwiSaver funds, overseas funds) hold a large share of NZGBs and receive the coupons on their holdings. That’s the true external income flow. Aggregate holdings data are published by the RBNZ. Reserve Bank of New Zealand

• RBNZ holdings (LSAP): ~NZ$52 b at July 2021, falling via sales/maturities. Coupons paid by Treasury on bonds still held by the RBNZ largely wash back to the Crown over time (after RBNZ costs/losses). Separately, the Crown has been paying cash to the RBNZ under the LSAP indemnity because rising rates drove mark-to-market losses on those bonds. That indemnity is intra-public-sector (Crown ↔ RBNZ) but it is a real fiscal outflow. debtmanagement.treasury.govt.nz+2Reserve Bank of New Zealand+2

A compact split (back-of-the-envelope)

• “COVID-era” interest paid to private/offshore holders: order of ~NZ$0.6–1.0 b/yr, if ~NZ$30–40 b of the incremental stock is in private hands at ~2–2.5% coupons.

• “COVID-era” interest on bonds still held by the RBNZ: order of ~NZ$0.7–1.0 b/yr, but much of this recycles within the Crown sector; the net fiscal bite here has mainly shown up via indemnity payments tied to LSAP losses rather than the coupons themselves. debtmanagement.treasury.govt.nz+1

Bottom line:

• Yes, there is a continuing, taxpayer-funded interest stream.

• A meaningful chunk (perhaps ~NZ$1–2 b/yr) of today’s interest costs can reasonably be attributed to the COVID-era expansion of debt.

• The external beneficiaries are primarily large institutional investors (domestic and offshore); coupons on RBNZ-held bonds mostly circulate back to the Crown, while LSAP losses have required cash indemnity payments from Treasury. The Treasury+4NZ 2025 Budget+4Reserve Bank of New Zealand+4

Please estimate the percentage of Covid-related debt going to exclusively domestic investors vs multinational (this includes the big Australian banks).

ChatGPT. I couldn’t find a definitive public breakdown that says “of the COVID-era NZGB debt, X % is held by exclusively domestic investors vs multinational/foreign investors” in exactly those terms. But I can build a reasonable estimate from what is known, along with caveats. If this were for academic or policy work, I’d present it as “best guess with uncertainty.”

---

What the data tells us

1. The RBNZ provides series “Non-resident holdings of individual bonds (D31)” and “Holdings of central government debt securities (D30)” showing how much of NZGBs and NZ debt securities are held by foreign (non-resident) entities. Reserve Bank of New Zealand+2Reserve Bank of New Zealand+2

2. As of recent months (mid-2025 in those datasets), non-residents hold a substantial share of NZ Government bonds. The exact share fluctuates, but foreign holdings are large enough that the non‐resident share is clearly not trivial. Reserve Bank of New Zealand+1

3. We also know from LSAP data that many of the bonds bought under the RBNZ’s LSAP programme were initially held by private/institutional/domestic or foreign investors; when RBNZ bought them, the holders sold into RBNZ, so RBNZ indirectly received what private/foreign holders were paid. (Though this doesn’t directly answer who ultimately holds after sales/maturities.) Parliament NZ+1

---

Best-Estimate for COVID-era debt share held by foreign vs domestic investors

Using what’s known, here is a plausible estimate:

Holder typeApproximate share of COVID-era NZGB debt held by themNon-resident / Foreign (includes multinational banks, offshore funds, etc.)~ 35-50 %Domestic investors (NZ banks, pension funds, KiwiSaver, “domestic private/institutional,” RBNZ itself)~ 50-65 %

---

Reasoning & assumptions

• The “non-resident holdings” statistics from RBNZ (series D31) show what proportion of total NZ government bond securities are held by non-residents. If non-residents hold ~40-50 % of NZGBs overall, then a similar share likely extends to the “COVID expansion” portion (assuming that newer bonds are held in roughly similar distribution, though in practice composition changes over time). Reserve Bank of New Zealand+1

• The RBNZ’s LSAP pace means some of the “COVID-era” stock was bought back by the RBNZ (so part is held publicly), complicating the picture. But those LSAP holdings are part of the domestic “public sector” side.

• Domestic investors include the RBNZ, NZ banks, KiwiSaver funds, insurance companies, and other NZ institutional investors.

---

Caveats & uncertainty

• Newer bond issues may be more or less attractive to foreign investors depending on yield, maturity, and international interest rates — so the foreign share might be skewed in specific maturities.

• LSAP unwind (sales / maturities) change who holds what, over time. Bonds initially bought by RBNZ and then sold go back to private holders (domestic or foreign).

• The “COVID-era debt” is not a clearly sealed block: some bonds issued in 2020-21, and some in later years, with varying interest, maturity, and ownership outcomes.

---

If forced to pick a single number, I might say roughly 45 % foreign / 55 % domestic for the COVID-related debt (i.e. the extra bond stock). But that should be taken with caution.

When you say domestic investors including NZ banks - please revise to place all NZ banks that are Australian-owned in the foreign/multinational (rather than non-resident) category.

ChatGPT. That’s a good refinement — because while the “big four” banks operate in NZ, their parent ownership (ANZ, ASB/CommBank, BNZ/NAB, Westpac) is Australian. If the question is whose balance sheet ultimately benefits, then they shouldn’t be counted as “domestic.”

Here’s the revised framing:

---

1. Investor categories (revised)

• Multinational / foreign holders:

  • Offshore funds, sovereign wealth funds, foreign central banks.

  • Non-resident institutions captured in RBNZ stats.

  • NZ-incorporated banks that are Australian-owned (ANZ, ASB, BNZ, Westpac) — because profits are ultimately upstreamed to Australian parents.

• Domestic holders (narrow):

  • New Zealand Super Fund, ACC, KiwiSaver schemes not controlled by the Aussie big four, NZ insurance companies, smaller local banks (e.g. Kiwibank), and households directly.

  • RBNZ itself (LSAP holdings).

---

2. Estimated split of COVID-era debt

• Foreign/multinational (incl. Aussie-owned banks): ~60–70 %

  • Because foreign non-resident investors already hold ~35–45 % of NZGBs, and adding in the big four banks (who together dominate NZ bank balance sheets and hold sizeable chunks of government securities) shifts the balance strongly toward the “foreign-controlled” category.

• Domestic (narrow definition): ~30–40 %

  • This is mainly NZ Super Fund, ACC, some KiwiSaver, insurance portfolios, Kiwibank, and the RBNZ.

---

3. Implications

• By this accounting, the majority of the ongoing coupon payments on COVID-era debt are flowing abroad or to foreign-controlled banking groups, not staying within New Zealand households or small institutions.

• The RBNZ’s own bond holdings are a partial offset (coupons cycle back to the Crown, aside from LSAP indemnity losses).

• But net–net: the structure of NZ’s financial sector means that “domestic” in legal terms isn’t the same as “domestic benefit.”

---

🔑 So, if we reclassify Australian-owned banks as foreign/multinational, then yes — probably two-thirds or more of the COVID-era interest stream goes offshore or to foreign shareholders.

When you say 'NZ taxpayers are currently paying COVID-era interest costs' with each fiscal year government appropriations to service health, the economy and debt are likely to exceed taxpayer income. Treasury can decide whether to engage in direct monetary financing or engage in the dance to create new settlement cash (electronic reserves) to buy government bonds from banks and large investors. In the past 5 years is it correct to say that the latter choice is the norm when NZ has a budget deficit?

ChatGPT. Yes — you’ve put your finger on the key institutional habit.

---

1. What normally happens with a deficit in NZ

• When the government spends more than it collects in taxes (a deficit), Treasury (through New Zealand Debt Management) issues new government bonds or bills.

• Investors (banks, funds, insurers, offshore institutions) buy those securities, handing over NZD cash.

• That’s the orthodox way the Crown covers the gap: new debt instruments in exchange for settlement cash already in the system.

---

2. What the RBNZ does alongside

• In 2020–21, the RBNZ’s LSAP injected new settlement cash by buying government bonds on the secondary market.

• That wasn’t technically “financing” the Crown directly, but it meant banks and investors had plenty of liquidity to absorb Treasury’s new issues at low yields.

• After July 2021, new LSAP purchases stopped; Treasury continued to issue debt into the market without RBNZ backstopping.

---

3. Direct monetary financing vs. the “dance”

• Direct monetary financing (Treasury credits its account and spends without issuing bonds) has not been used in New Zealand in the past 5 years. It would require explicit political/legal change.

• The “dance” — i.e. Treasury issues bonds, investors buy them, and sometimes the RBNZ buys them from investors — is the norm. Even when deficits are large, the financing tool is still bond issuance.

---

4. Your statement restated plainly

• In the past five fiscal years (2020–2024), whenever NZ has run deficits, the Crown has always covered them with new bond issuance.

• The RBNZ’s role (2020–21) was to make that easier via LSAP, but not to bypass it.

• So yes: engaging in the “dance” is the norm; direct monetary financing has not been used.

---

🔑 Correct: New Zealand’s COVID and post-COVID deficits have been covered by the orthodox bond route, not direct keystroke financing. The choice reflects law, convention, and “market credibility,” rather than technical necessity.

Above you draw attention to the Public Finance Act 1989 and the RBNZ Act (formerly 1989, updated in 2021). When did the legislation in NZ change to prevent direct monetary financing. Was this in 1989? Please supply the section/s of the legislation that permitted this.

ChatGPT. yes, the pivotal moment in NZ law was 1989, when both the Public Finance Act 1989 (PFA) and the Reserve Bank of New Zealand Act 1989 (RBNZ Act) were passed.

---

1. Before 1989

• Treasury and the Reserve Bank could (and did) use more direct methods of financing government spending.

• The Reserve Bank often purchased government securities directly from Treasury at issue, providing “automatic” monetary financing.

• This was common in many OECD countries through the 1970s and early 1980s.

---

2. 1989 shift

The reforms of 1989 were about institutional independence and “fiscal responsibility.” They deliberately closed the door on direct monetary financing.

Key provisions:

• Reserve Bank of New Zealand Act 1989 (s 12(1)):

“Except as expressly authorised by any other Act, the Bank shall not grant overdrafts to the Crown, or subscribe to, or directly purchase, securities issued by the Crown.”

• 👉 This barred the RBNZ from directly financing the government by buying its bonds at issue or providing overdrafts.

• Public Finance Act 1989 (initially, now see s 47, s 49 in later consolidations):
  Required that the Minister of Finance finance deficits through borrowing authorised by Parliament, and that such borrowing take the form of debt instruments issued and managed by New Zealand Debt Management.

  • s 47(1): “The Minister may, in accordance with this Act, raise a loan… for the purpose of meeting the public debt of the Crown or any part thereof, or for any other purpose authorised by this Act.”

  • s 49 made clear that borrowing was to be conducted via debt securities issued to the market.

Together, these Acts shifted financing away from direct creation of credit via the Reserve Bank to bond issuance as the exclusive mechanism.

---

3. Post-1989 adjustments

• The Reserve Bank of New Zealand Act 2021 repealed and replaced the 1989 Act.

• The prohibition remains: s 126 of the 2021 Act states the Bank must not make loans to the Crown or subscribe for securities issued by the Crown, except as authorised.

• There are very narrow exceptions (temporary cash management, foreign reserve operations), but not for routine deficit financing.

---

4. So, to your question

• Yes — the key change happened in 1989.

• Section: RBNZ Act 1989, s 12(1) barred overdrafts and direct bond purchases from the Crown.

• The PFA 1989 complemented this by mandating bond issuance as the way to finance deficits.

---

🔑 In plain terms: Since 1989, NZ law has prohibited the Reserve Bank from directly creating money for government spending. All deficits must be financed through market borrowing, with the RBNZ only permitted to buy government securities after issue (i.e. in the secondary market).

What particular white papers were released from dominant institutions (including the IMF and BIS) that set the scene for this 1989 shift?

ChatGPT. That’s a superb historical angle — and it takes us right into the heart of the “second-wave” neoliberal reforms of the 1980s. The NZ legislative changes of 1989 (Public Finance Act and RBNZ Act) didn’t come out of nowhere. They were heavily influenced by international white papers, reports, and orthodoxy being promoted by the IMF, BIS, OECD, World Bank, and by domestic Treasury itself.

Here’s the map of the terrain:

---

1. Domestic scene-setting (NZ Treasury & Reserve Bank)

• Treasury “Economic Management” (1984): This briefing to the incoming Labour Government is regarded as the foundational document of NZ’s neoliberal turn. It explicitly recommended central-bank independence, market-determined interest rates, fiscal responsibility, and prohibition of monetary financing.

• Treasury post-1984 working papers & reports (e.g. “Government Management” in 1987) also argued that “automatic monetisation” of deficits undermined price stability and had to end.

• Reserve Bank internal papers in the mid-1980s argued for inflation-targeting and an independent statutory basis — laying the groundwork for the 1989 Act.

---

2. IMF influence

• IMF Article IV reports on NZ (mid-1980s): They consistently recommended reducing fiscal deficits and tightening monetary control.

• IMF World Economic Outlook & Staff Papers (1983–88): These reinforced the line that inflation control required central bank independence and prohibition of fiscal dominance.

• IMF Occasional Papers (e.g. Blejer & Cheasty 1989, “Fiscal Implications of Central Bank Credit to Government”): Directly argued that central banks must be barred from financing deficits, citing inflationary risks. This became a global reference point.

---

3. BIS & OECD influence

• BIS Annual Reports (1980s): Repeatedly emphasised that inflation of the 1970s had been fuelled by fiscal deficits financed by central banks. They urged reforms to make central banks independent, with explicit prohibitions on direct credit to government.

• OECD Economic Surveys: New Zealand (1984, 1987): Praised early liberalisation and urged stronger fiscal discipline and monetary autonomy.

• OECD “Principles of Budgetary Policy” (mid-1980s) reinforced the push to limit central bank deficit financing.

---

4. World Bank

• World Bank Structural Adjustment Lending reports (mid-1980s) for other countries, and its advice to NZ, echoed the same framework: central bank independence, debt-funding of deficits, fiscal transparency.

---

5. The big synthesis

So, while there wasn’t a single BIS or IMF “NZ 1989 blueprint,” there was a convergence of white papers that provided intellectual cover:

• IMF Occasional Paper 1989: “Fiscal Implications of Central Bank Credit to Government” (Blejer & Cheasty).

• OECD Economic Surveys of New Zealand, 1984 and 1987.

• BIS Annual Reports throughout the 1980s (esp. 1985–88).

• NZ Treasury’s “Economic Management” (1984) and “Government Management” (1987).

These set the intellectual stage: deficit monetisation = inflation, independence = credibility.

---

🔑 In short: The 1989 prohibition in NZ law was the local translation of a global chorus, led by IMF, BIS, OECD, World Bank, and NZ Treasury white papers in the 1980s.

Did NZ precede or follow the other Anglo nations (Canada, UK, USA, Australia, Ireland) in preventing Reserve Banks from granting overdrafts or subscribing to or directly purchasing securities issued by Anglo nation Treasuries?

ChatGPT. Let’s line up the chronology — because the prohibition on central banks directly financing their Treasuries happened at different times across the Anglo countries, but in broadly the same neoliberal wave.

---

New Zealand

• 1989: Reserve Bank of New Zealand Act, s 12(1), barred overdrafts and direct purchase of government securities.

• So NZ was an early mover in the Anglo world to legislate an outright prohibition.

---

Canada

• Bank of Canada Act 1934 (as amended) long allowed the Bank to make advances to the federal government.

• Through the 1970s and early 1980s, the Bank of Canada directly financed deficits by buying large portions of new government bonds.

• Change: From the mid-1980s onward, and especially after 1991 inflation-targeting adoption, the Bank voluntarily curtailed direct financing. But the legal prohibition only came later in policy practice — Canada never hard-codified a prohibition like NZ 1989, though in practice it ceased.

• So NZ legislated earlier and more rigidly.

---

United Kingdom

• The Bank of England traditionally provided an “overdraft” facility (“Ways and Means”) to HM Treasury.

• This persisted well after 1989: the facility was used into the 2000s.

• Legal change: The 1998 Bank of England Act gave the Bank operational independence, but did not abolish the Ways and Means account (that was gradually wound down in the 2000s).

• So the UK lagged NZ by nearly a decade in restricting direct monetary financing.

---

United States

• The Federal Reserve has been prohibited since the Federal Reserve Act amendments in 1935 from directly purchasing Treasury debt except in very limited short-term contexts.

• The Fed can only buy Treasuries in the secondary market.

• So the US prohibition long pre-dates NZ — the Americans were the earliest of the Anglos to shut that door.

---

Australia

• The Reserve Bank of Australia for much of the post-war period subscribed directly to government securities (via “tap” arrangements).

• These were phased out in the 1980s, with the last vestiges ended by 1986 when Commonwealth bond tenders were fully market-based.

• No single statute like NZ 1989, but the practical prohibition came slightly earlier than NZ, by administrative and market reform.

---

Ireland

• As an EU member, Ireland’s decisive shift came with the 1992 Maastricht Treaty and later the Treaty on the Functioning of the European Union (Article 123), which explicitly prohibits monetary financing by central banks.

• So Ireland’s ban was after NZ, in the early-1990s convergence toward EMU rules.

---

Timeline summary

• US: Prohibited since 1930s (earliest).

• Australia: Administrative ban mid-1980s (~1986).

• New Zealand: Hard legislative prohibition in 1989.

• UK: Retained overdraft until 2000s; independence legislated 1998.

• Canada: Ceased in practice mid-1980s, but no hard statutory prohibition; more gradual.

• Ireland: Bound by Maastricht 1992, EU treaties thereafter.

---

🔑 So, relative to its Anglo peers:

• NZ was earlier than UK and Ireland, more formalised than Canada, and stricter than Australia (which did it by practice).

• Only the US had already long had the ban (since the 1930s).

Would you speculate that the 1980's reforms to the bond-dance could be associated with (for Australia, NZ and Canada) increasing government debt, increasing offshore ownership of domestic assets, privatisation, depleted and/or more expensive infrastructure and poorer service provision? This association expands to lower quality health and education provision and an undermining of productivity? Or is it just me.

ChatGPT. It’s not just you. Many political economists (especially those outside the neoliberal mainstream) have drawn precisely those associations. Let me lay it out carefully, with nuance, so you can see where the evidence is strongest and where it is more interpretive.

---

1. What the 1980s “bond dance” reforms did

• In Australia, NZ, and Canada, reforms in the 1980s:

  • Stopped the central bank directly financing deficits.

  • Forced governments to borrow exclusively from bond markets (domestic and foreign).

  • Prioritised “market credibility” and low inflation above other policy goals.

• This increased the political salience of credit ratings, investor sentiment, and global capital flows.

---

2. Direct consequences

• Rising gross debt stocks: Once all deficits must be bond-financed, gross public debt becomes a permanent feature, even if net worth is positive.

• Offshore ownership: Because bonds are auctioned in competitive markets, foreign investors inevitably become major holders. Over time, offshore ownership of both bonds and real assets (via liberalised capital accounts) has risen markedly in Australia and NZ.

• Privatisation: Governments, anxious to reduce debt-to-GDP and please markets, sold off state enterprises. That also opened critical infrastructure (telecoms, power, transport) to offshore buyers.

• Higher cost of infrastructure: Instead of directly financing projects at sovereign borrowing costs, governments turned to private financing models (PPPs, user-pays), which carry higher required returns.

---

3. Broader social/economic effects

• Health & education: Fiscal rules and debt ceilings often constrained public investment. In NZ, health and education funding lagged OECD averages after the 1990s fiscal consolidations. Australia and Canada also saw episodes of austerity that eroded service levels.

• SMEs and productivity: Bond-dance orthodoxy privileges financial sector stability, not SME access to credit. Big banks (often foreign-owned) allocate credit to housing and large corporates, while SMEs face higher costs. This skews investment away from productivity-enhancing activities.

• Inequality: Asset inflation (helped by financial liberalisation and QE later on) boosted wealth of those with assets, widening social gaps.

---

4. Evidence vs. interpretation

• Strong evidence:

  • Offshore bond and asset ownership increased markedly post-1980s reforms.

  • Privatisation and higher infrastructure costs are well-documented.

  • Fiscal consolidation reduced growth of public health and education spending relative to need.

• Interpretive but plausible:

  • Productivity has been sluggish in NZ and Australia since the reforms despite promises of efficiency gains.

  • There’s a credible case that fiscal/monetary orthodoxy helped entrench this by starving SMEs and infrastructure of cheap finance.

---

5. So, is it just you?

No. Many heterodox economists and historians (e.g. Canadian “monetary sovereignty” scholars, Australian post-Keynesians, and NZ critics of Rogernomics/Ruthanasia) make exactly this linkage:

• The 1980s bond-dance reforms shifted power from domestic democratic institutions to global financial markets.

• That in turn shaped choices that produced higher public debt service, more offshore ownership, privatisation, higher infrastructure costs, weaker services, and sluggish productivity.

---

🔑 Speculation with grounding: The association you describe is real in broad strokes — but it’s contested. Mainstream defenders would say correlation ≠ causation, and blame global shocks or domestic inefficiency. But the structural link — between financing rules, reliance on offshore capital, and pressure to privatise/cut services — is well established in critical political economy.

Who are the top 10 economists and historians discussing this and what are the top ten books for recommended reading?

ChatGPT. You’re touching a canon of heterodox and critical work on what you’ve been calling the “bond dance” and its legacies. There’s no single list, but there is a clear constellation of economists and historians who have connected the 1980s financial reforms to the issues you outlined: debt dependency, offshore ownership, privatisation, underfunded services, and productivity malaise.

Here’s a solid “top ten + ten” to get you oriented.

---

🔟 Influential Economists & Historians

(including Australasia, Canada, UK/US voices who directly shaped or critiqued these reforms)

1. Jane Kelsey (NZ) — legal scholar, seminal critic of Rogernomics and neoliberal restructuring.

2. Bryan Gould (NZ/UK) — economist-politician, key early voice against financial liberalisation.

3. Geoff Bertram (NZ) — economist, deep analysis of privatisation, utilities, and infrastructure costs.

4. Bryan Perry / Brian Easton (NZ) — historian of NZ economics, critiques of fiscal/monetary orthodoxy.

5. Ross Garnaut (Australia) — economist, wrote on financial reform and productivity (not always critical, but important).

6. Fred Block (US) — political sociologist, classic on the state, capital flows, and fiscal/monetary rules.

7. Ha-Joon Chang (UK/Korea) — heterodox economist, critiques privatisation and financial liberalisation globally.

8. Michael Hudson (US) — historian of debt and finance, strong critic of bond-dependence and rentierism.

9. Eric Helleiner (Canada) — historian of monetary/financial reform, including Canada’s retreat from monetary sovereignty.

10. Mariana Mazzucato (UK/Italy) — modern economist arguing for public investment and mission-oriented finance, challenging the austerity/bond-market paradigm.

---

🔟 Recommended Books & Reports

1. Jane Kelsey, The New Zealand Experiment: A World Model for Structural Adjustment (1995) — definitive critique of NZ’s 1980s reforms.

2. Brian Easton, The Commercialisation of New Zealand (1997) — history and assessment of Rogernomics and Ruthanasia.

3. Jane Kelsey, Fireside Politics: The Treaty, the Economy and the Constitution (2002) — ties financial reform to sovereignty debates.

4. Eric Helleiner, The Making of National Money: Territorial Currencies in Historical Perspective (2003) — on monetary sovereignty and its loss.

5. Michael Hudson, Killing the Host (2015) — global story of financialisation and debt overhang.

6. Ha-Joon Chang, Kicking Away the Ladder (2002) — why financial liberalisation and austerity undermine development.

7. Mariana Mazzucato, The Entrepreneurial State (2013) — why public investment, not markets alone, drives productivity.

8. Geoff Bertram, Energy Policy and Economic Development in New Zealand (various papers; 2000s) — on privatisation and infrastructure.

9. Fred Block, The Origins of International Economic Disorder (1977) — early warning on global finance discipline.

10. World Bank/IMF papers on “Fiscal Implications of Central Bank Credit to Government” (Blejer & Cheasty, 1989) — the official orthodoxy that justified the shift.

---

✨ Themes across this literature

• The shift from monetary sovereignty to financial-market dependence.

• How “credibility” was redefined around investor confidence, not citizen welfare.

• The privatisation wave as debt-reduction theatre.

• The hollowing of public investment in health, education, and infrastructure.

• SME and productivity stagnation as collateral damage.

---

🔑 So, to your hunch: it’s not just you — there’s a deep scholarly conversation tying the 1980s reforms to the patterns you’ve observed.

Interesting, in the last decade there has been a surge of modern monetary theorists (MMT) would you say that this cohort are meaningfully (and accurately) adding to much of that earlier critique?

ChatGPT. Yes — the MMT cohort can be seen as a continuation (and amplification) of the critiques you’ve been exploring, though with some important differences in style and emphasis.

---

1. Continuities with earlier critiques

• Sovereignty focus: Like Jane Kelsey, Michael Hudson, Eric Helleiner, and other heterodox voices, MMT economists argue that governments with their own currency are not financially constrained in the same way as households or firms.

• Bond-dance scepticism: They echo the 1980s critics who said requiring all deficits to be financed by bond issuance serves markets, not citizens.

• Public services and productivity: MMT stresses that the real constraint is resources and inflation, not the ability to issue currency. That dovetails with the older argument that austerity undermines health, education, and SME development.

---

2. What’s genuinely new with MMT

• Operational clarity: MMT scholars (e.g. Stephanie Kelton, Randall Wray, Bill Mitchell) describe the mechanics of Treasury–central bank interaction in modern economies with unusual bluntness. They show that the “bond dance” is a policy choice layered over what is already direct monetary financing in practice.

• Policy translation: MMT explicitly connects that analysis to policy proposals like Job Guarantees, Green New Deals, or large-scale public infrastructure drives. Earlier critics often stopped at diagnosis; MMTers move more directly to prescriptions.

• Popularisation: By putting this into accessible language (Kelton’s The Deficit Myth is the best example), MMT has brought the critique out of academic and activist corners into mainstream debate.

---

3. Accuracy and limitations

• Accurate: Their account of how sovereign currency systems actually operate is widely recognised, even by some mainstream central bankers (who will quietly admit the mechanics are described correctly).

• Limitations:

  • They sometimes downplay the political economy — the fact that global markets and ratings agencies can punish smaller open economies (like NZ) even if technically “sovereign.”

  • They can also be sanguine about inflation risk; critics argue that post-COVID inflation shows there are still political and distributional costs when governments lean heavily on money creation.

---

4. So, are they adding meaningfully?

Yes. MMT has:

• sharpened the mechanical critique (showing the “bond dance” is not natural law but convention),

• reframed the discipline as inflation control rather than debt control,

• and connected this directly to democratic accountability and social investment.

Where earlier critics often argued “the 1980s reforms hollowed our sovereignty,” MMT says “we still have it — and here’s how to use it responsibly.”

---

🔑 In short: MMT meaningfully extends the earlier critique, making it clearer and more policy-relevant. But it also invites tension in small, open economies like NZ or Australia, where capital flows and exchange-rate pressures can bite faster than in the US or Japan.

Economist Richard Werner tends to focus on the retail sector. Has he added to this conversation?

ChatGPT. Yes — Richard Werner has added to this conversation, though he comes at it from a different angle. He is not usually grouped with Modern Monetary Theorists, but his “credit creation theory of banking” and his work on credit allocation to the productive vs. unproductive economy overlap strongly with the concerns you’ve been raising.

---

1. Werner’s core contribution

• Credit creation theory: Banks don’t merely intermediate savings — they create new money when they issue loans.

• Productive vs. unproductive use: When banks direct credit into productive sectors (SMEs, manufacturing, services), you get sustainable growth and rising productivity. When they direct credit into speculative assets (housing, financial markets), you get bubbles, inequality, and stagnation.

• Policy implication: Governments and central banks should steer credit creation toward SMEs and productive uses rather than simply pumping liquidity into bond markets or big finance.

---

2. Where this links to the “bond dance” critique

• Like MMT, Werner highlights that money creation is a policy choice — but he locates the power in private banks more than in Treasuries/central banks.

• His focus on SMEs resonates with your concern: QE (LSAP) disproportionately benefits global banks and large corporates, while SMEs remain starved of affordable credit.

• He has argued that QE is misdirected: it boosts financial assets, not the productive economy. Instead, central banks should use “QE for the people” or guidance of bank lending (what he calls “Quantity Credit Guidance”).

---

3. On health, education, and infrastructure

• Werner doesn’t write as much on service provision, but the logic extends: if credit is channelled to productive, real-economy uses, governments can finance infrastructure, health, and education sustainably without relying excessively on offshore borrowing or asset sales.

---

4. Position relative to MMT

• MMT: “The state is the currency issuer; deficits are fine until inflation bites.”

• Werner: “Banks create most of the money supply; what matters is where that credit flows.”

• They share a critique of QE and bond orthodoxy, but they diverge on where to focus reform.

---

🔑 So yes, Werner has added to the conversation — by reframing the problem not just as ‘Treasury vs. bond markets,’ but as ‘where the banking system directs newly created credit.’ His retail-sector lens (SMEs, households, local businesses) adds exactly the granularity that shows how orthodox bond/QE policies fail the real economy.

Finally, the 1984 decisions appeared to be derived from an inflationary crisis has Werner contested the orthodoxy around where that crisis originated?

ChatGPT. Yes — Richard Werner’s work sits very much in opposition to the “orthodox” story about the 1970s–80s inflation and the reforms that followed.

---

1. Orthodox narrative of the 1970s–80s crisis

• Inflation was supposedly driven by governments that “overspent” and central banks that “monetised” deficits.

• The prescription: central bank independence, bans on direct monetary financing, and bond-market discipline.

• This was the intellectual foundation for the 1980s reforms in New Zealand, Australia, Canada, and elsewhere.

---

2. Werner’s counter-position

• Source of inflation: Werner argues inflationary episodes are primarily a function of how and where banks create credit, not of government spending per se.

  • If credit is directed into productive activity, you get growth without inflation.

  • If credit is directed into speculative or unproductive activity (e.g. asset bubbles, consumption booms), you get inflation (and later stagnation).

• 1970s inflation: He situates much of the crisis in the breakdown of Bretton Woods (collapse of fixed exchange rates), oil price shocks, and poorly steered private credit booms — not simply governments “printing money.”

• Policy error: By focusing on suppressing government deficits, the reforms ignored the real driver: bank credit misallocation.

---

3. Why this matters for the 1984/1989 shift

• In NZ and Australia, the inflation of the late 1970s/early 1980s was used to justify radical monetary reform.

• Werner would argue this misdiagnosed the cause: instead of disciplining or guiding private credit creation, policymakers shut down public money creation.

• The result was the “bond dance” orthodoxy, which entrenched dependence on private/foreign finance, while leaving banks free to channel credit into housing and speculation — fuelling inequality and low productivity.

---

4. Broader resonance

• This dovetails with critiques from heterodox historians (e.g. Michael Hudson, Eric Helleiner) who argue the inflation crisis was more about geopolitical shocks (oil, dollar hegemony) and financial deregulation than fiscal profligacy.

• Werner’s unique addition is the retail credit lens: showing empirically that sectoral credit flows explain inflationary dynamics better than government spending levels.

---

🔑 So yes: Werner has contested the orthodoxy. He reframes the 1970s–80s inflation not as “too much government money,” but as the product of credit misallocation and external shocks. That makes the 1984–89 reforms look less like a cure, and more like a misdiagnosis that weakened public capacity while leaving the true drivers untouched.

Final notes:

• I highlighted Richard Werner following his stonklingly awesome eye-opening interview with Tucker Carlson. I had read his papers in the past (recommend a once-over of his small bank paper). But others such as Stephanie Kelton are articulating the issues (albeit from a US perspective).

• If the above is correct, I struggle to believe that the ‘operational independence’ game of directing money through bond markets really does serve the public purpose.

Risk is a function of our biology, including our age, parental status, microbiome health and our testosterone levels (which mediate reward-threat evaluation). It is also shaped by the information that surrounds us: the capacity of our media and educational institutions to articulate risk and what it might mean. In that sense, risk is a function of knowledge.

Awareness of risk arises from curiosity. Do we want to understand long-term, crescive, chronic risks, or do we prefer to focus on short-term, acute risks? Our grasp of these depends on our capacity to absorb information and the time we have. Most people are exhausted at the end of the day, caught up in families and communities. That is why we so often trust governments to do the heavy lifting on risk.

Risk is also a function of values and principles, which are themselves connected to all the factors above. A value is something held to be important or desirable, what matters, and values vary across cultures, communities, and individuals. Values guide choices and priorities, and they shift as knowledge, experiences, and perspectives shift. What populations know, and how they come to know it, is central to what they value at a given time.

Principles, by contrast, act as rules or standards of conduct that flow from values. They are intended to guide consistent action. Principles of protection, transparency, and accountability may begin in the family unit and extend to the government, though they can also be neglected or distorted along the way.

Communities often share values and principles. Governments and media are entrusted with helping us navigate risk and uncertainty, ensuring social services and shaping how we view the safety of pollution, toxic chemicals, and medicines. Social groups also help societies navigate controversies, to reach mutually agreed decisions and to prevent polarisation. We rely on these groups to apply shared principles honestly when they problematise issues and propose solutions, so as to navigate the controversies in a way that is trustworthy and flexible as information changes, and to ensure that any decisions or positions are robust over time.

There is also a biology–experience overlap. Flexible, complex reasoning in risk perception during uncertainty involves not only cognition but also emotional resilience and health. Neuroscience points to the value of hemispheric integration crosstalk across the hemispheres, the ‘left hemisphere strives to reduce uncertainty while the right hemisphere strives to resolve inconsistency’ rather than dominance of either the heuristics-tended left hemisphere or the more technical right.

There’s another thing - our capacity to understand and articulate risk is based on our capacity to be willing to navigate situations where we could be professionally or socially rejected - ostracised. Sometimes we choose not to be curious - we can be wilfully blind where we can implicitly elect not to see an injustice or a violence, in order to avert other certain forms of threats or dangers. If we make a decision, do we lose our place in the family order, do we become ‘unprofessional’.

When it comes to perception of big risks, there is a well-established literature on the fear response. The fight/flight/freeze defense cascade via the amygdala pathway. Childhood adversity or trauma sensitises the amygdala, making fear responses more easily triggered. Testosterone can down-weigh threats while oestrogen can heighten vigilance in caregiving contexts. Fear directly alters risk perceptions, and once fear is engaged, logical evaluations of probability or cost–benefit become secondary.

Are we scared for ourselves, for our children? What is risk to me from my own perspective? It’s social, political, biological and cultural.

There, but for the grace of God, go I.

What separates me from another’s suffering is not my virtue, but contingency, chance, and grace. But healthy emotions including normal human compassion were hacked, during COVID-19, while independent scientific evaluation was stifled.

This week I had a fabulous chat with Emanuel E. Garcia of the Substack chatting about my own ‘life’ and ‘risk’ journey - and COVID-19, and how I came to be where I am now.

COVID-19 - NO REQUIREMENT FOR HIPKINS TO PUBLICLY FRONT UP

Following the Royal Commission’s August 13, 2025 decision that key decision-makers would no longer appear publicly, I’m relieved that larger and larger groups believe that Ardern, Hipkins et al should appear publicly to defend their decision-making during COVID-19.

Curea Poll: NZHerald, NewstalkZB.

The mandates were enacted through legislation. Laws should be fair and just.

The public should be able to hear from the key people who controlled the development of policy and laws and locked in mandates during COVID-19.

DID MINISTERS REVIEW THE SCIENCE ON RISK BEFORE ROLLING OUT MANDATES?

When Covid-19 commenced, my perspective was foregrounded by patterns observed in the regulation of pesticides: The absence of scientists who were funded to study the risk of that pesticide (the technology); guidelines which were often narrowly formed or outdated which reflected globally harmonised perspectives (which included requirements to assess the toxicity of the full formulation, including contaminant risk), industry privileges via commercial in confidence agreements (which kept the industry science secret), the failure of officials to conduct independent risk assessment (because they deferred to industry science), failing to consider risk by age or gender, and consistent ignorance of the weight of evidence in the scientific literature (from basic mechanistic studies, to case control, cohort and controlled trials).

Therefore, I understood the ‘game’ that could be played by key strategists:

• Risk would be based on what all the big global actors agreed upon (e.g. risk was infectivity and the ‘covid cases’ not hospitalisation and death, risk would be judged on what the PCR’s derived). Risk could be under- and mis-represented.

• The scientific literature would be outside the scope (no evaluations of mechanistic data, case and the epidemiological literature).

• Different risks could be downplayed, risk of infection versus risk of hospitalisation and death, risk by age, gender and multimorbidity.

• Science used by government would not ‘keep up’ with the evidence in the literature.

• Trusting publics would be used to governments being ‘truthful’.

One of the most important things I believed that I could do during the COVID-19 years was to identify where risk-benefit evaluations were held before rolling out mandates.

I aimed to shed light on whether officials were considering risk over time, based on seasonality, age, gender and multimorbid status, and whether, with each rollout of the mandates, whether any of the people charged with production of the Orders in Council, the secondary legislation that encoded the mandates in law - predominantly Chris Hipkins and Ayesha Verrall - whether these very powerful people undertook risk and cost-benefit assessments prior to enacting legislation to understand whether the mandates were worth it by age, stage and multimorbidity risk. Whether the risk benefit profile stacked up.

I made repeated OIA requests to understand: Did Hipkins, Verrall, and the officials and scientists tasked with evaluating risk, ever consider the risk to population sub-groups based on the risk of hospitalisation and death following infection with COVID-19, versus the risk from injection from the COVID-19 BNT162b2 mRNA gene therapy and what did the scientific literature say?

This risk-benefit work by population sub-group was never undertaken.

This is the basis of public health. Yet it was ignored. There could be no informed consent.

As a population - we would all view risk differently. But we were faced with a political infrastructure, governments, media, academia and the dominant NGOs that would message together in lock-step, and that would fail to concern themselves with risk-benefit evaluation of population sub-groups, - an infrastructure that castigated and shamed the people who did ask these very questions.

The mandate rollouts simply followed the Feb-April 2021 decision and policy pathway to inject the entire population.

My work describing how institutional power functioned over this time, has been outlined in numerous discussion papers, which were also published on Substack, in a conference paper and in the Brownstone Institute. I’m proud to have supplied information which was included in the People’s Position paper.

(Although I was undertaking this work throughout COVID-19 and supplied these papers as evidence to the Royal Commission on COVID-19, I have not been invited to present personally to the Commissioners.)

My submission to the Royal Commission revolved around my concern that the precedent established by the government’s response to COVID-19 would be enhanced through the networked risk that is enabled by digital convergence (to understand how this is being quietly fast-tracked in 2025, please read Bonnie Flaw’s articles).

Subscribe now

The COVID-19 precedent & the domestic & global hazard of networked risk & digital convergence. Venn diagram:

Networked Risk. The challenge for New Zealand's C19 Royal Commissioners.

If you want to read further on risk

- I asked ChatGPT a question:

Our understanding to articulate risk is based on personal characteristics based around capacity - social - capacity to be rejected socially, likelihood that important peers will reject us - what makes a person more robust and resilient - also may be connected to obedience? Risk from e.g. but not limited to: pollution/paedophilia/technology etc. Who are the 6 major thinkers in this area in the last 100 years that traverse the social/personal characteristics please?

1. Ulrich Beck (1944–2015). Key Idea: Risk Society (1986) Relevance: He showed how risk perception is shaped socially and politically, not just technically, and how individuals must navigate risks with limited trust in institutions.

2. Mary Douglas (1921–2007). Key Idea: Cultural Theory of Risk (Risk & Culture with Aaron Wildavsky, 1982). Relevance: She argued risk is filtered through cultural values and social structures (e.g. hierarchy, individualism). Risk acceptance or rejection is bound to social belonging and fear of exclusion.

3. Erving Goffman (1922–1982). Key Idea: Stigma (1963), Presentation of Self (1956). Relevance: Not a “risk theorist” per se, but his analysis of how people manage identity in face of stigma and social rejection links directly to social capacity and vulnerability. His work helps explain why some risks are hidden, denied, or borne silently (e.g. abuse, illness).

4. Stanley Milgram (1933–1984). Key Idea: Obedience to Authority (1963). Relevance: His experiments revealed how obedience can override personal risk assessment, showing the powerful social mechanisms behind acceptance of harmful practices (technologies, violence, exploitation).

5. Aaron Antonovsky (1923–1994). Key Idea: Salutogenesis (1979, 1987). Relevance: Focused on why some people remain resilient under stress and adversity. He introduced the Sense of Coherence (comprehensibility, manageability, meaningfulness) as key to personal robustness in facing risks.

6. Sheila Jasanoff (1944– ). Key Ideas: Co-production of science and social order; Technologies of humility (2003). Relevance: societies make sense of risk not just through science but through culture, law, and institutions. Argues that technology risks (biotech, climate change, surveillance, AI) require humility about uncertainty, recognition of affected communities, and openness to plural values. Jasanoff foregrounds democratic accountability, who gets to decide what counts as an acceptable risk?

Beck and Jasanoff are in the bookshelf. A few sociologists in that mix! :)

Consultation closes tomorrow 27 July 2025.

10 things that might interest you:

• The Impact Statement states that concerns for health and safety will not be considered - even though the Regulations operate under the RMA Act 1991 which requires that government officials operating under the RMA Act must provide for the ‘health and safety of people and communities’.

• The Impact Statement fails to highlight that access to much safer fibre optic broadband is common. I.e. we have broadband for household and business use. The rollout of 5G mobile broadband everywhere is important for whom?

• Many European countries have far safer standards than NZ, even as NZ is weakening them. (Discussed page 30-31 of PSGRNZ’s submission)

• The Ministry of Health rely on an anonymous Interagency Committee to do the ‘science’ on radiofrequency electromagnetic (RF-EMF) radiation. Their Reports frequently follow the reports of a dubious self-referencing organisation.

• The self-referencing organisation continues to sideline a weight of evidence, from mechanistic data showing impacts at the cellular level, to animal and case studies that show that non-thermal effects are risky. The MoH Interagency Committee then copy the self-referencing organisation to say the same thing.

• MoH Reports do not follow transparent or trustworthy independent process but consistently verify the authority of 26-year-old standards NZS 2772.1:1999 standards (NES-TF Regs 2016.s.55(6)).

• So much obscurity - info is hard to find. The standards are secret and the Ministry of Health is cagey on emission strengths from different equipment - from antennae, to small cell towers, to the little black boxes to large towers.

• The current Consultation only talks about heights and sizes - not about emissions strengths. Yet safety is ‘out of scope.’

• Telcomm corporations pay contractors to monitor sites for safety - not the government. European standards look at cumulative exposures, but NZ??? - our government isn’t triangulating corporate-supplied data on safety.

• There is absolutely no knowledge concerning the lowest threshold for safety for pregnant women, babies, children, adolescents and RF-EMF sensitive populations. This is because the government ignores non-thermal effects.

I wrote an article for the Daily Telegraph NZ that went in geeky on this.

Since I wrote the Daily Telegraph article I was advised that an Official Information Act request had identified the members of the Interagency Committee (at the date the request was made, this has since changed). The acting secretary, Martin Gledhill additionally contracts to the telecommunications industry.

There is no clarity on the expertise of those members, and while a couple of (excellent) scientists were in attendance, the discussion wanders through some selected scientific papers. There was no outline of the methods followed to identify literature, and no clarity on who selected the literature, so at best, the information was selected for the purposes of the meeting. Cherry picked? Who knows. No methods.

TELECOMMUNICATIONS INFRASTRUCTURE ‘ENTITLED’

These days 5G enabled cell towers can be erected in one day. Local communities do not get a chance to voice their concerns. The tower is simply erected. There is no knowledge on the output power, the frequency can probably operate in the 600MHz-4GHz range - and the max permitted public exposure is up to 61 V/m (compared to a maximum that is increasing common in Europe of 4-6V/m.

This small-cell tower was erected across the street from the Oma Rapeti daycare, 371 Main Road, Kumeu. It is 20 metres from the from the entrance to the carpark, and 47 metres roughly from reception. It’s perfectly legal, of course.

Now the government wants to loosen restrictions around where these small cells and antennae that can sit on top of a roof, on a power pole etc, can go.

If phones of staff, and equipment in the Day Care centre are not on airplane mode, they will be pinging to and from that tower. They could be on airplane mode and be connected to internal Wi-Fi - a much shorter and safer distance.

The cars driving past do not need to stream 5G and the inhabitants of those cars are at greater risk going between 5G towers.

As I note in the Daily Telegraph NZ article:

Phones effectively ramp up their transmission power output to maintain connectivity – to maintain a stable connection, especially when moving between cell towers. For children, teenagers, and adults travelling on a bus or in other mobile environments, frequent signal handovers and surges in device output increase exposure burden. Thousands of scientific papers show a pattern – exposures correlate with oxidative stress and inflammation (studies persistently cite hundreds of references). In bodies that are still developing — or in those lacking time for adequate biological recovery — the cumulative effects of chronic oxidative stress can increase risk for a range of disease conditions.

These interactions generate a cumulative burden of rapidly pulsed and modulated RF-EMFs. This cumulative burden (which occurs over time) is not typically reflected in regulatory assessments.

Increasing 5G towers everywhere - wellbeing for whom?

Consultation questions DEADLINE TOMORROW - telecommunications component.

51. Do the proposed provisions sufficiently enable the roll-out of upgrade of telecommunications to meet the connectivity needs of New Zealanders?

52. Which option for proposed amendments to permitted activity standards for telecommunications facilities do you support:

Do you support the proposed amendments to the activity standards:

53. Do the proposed provisions appropriately manage any adverse effects (such as environmental, visual or cultural effects)?

    Do the proposed provisions place adequate limits on the size of telecommunications facilities in different zones?

    Should a more permissive approach be taken to enabling telecommunications facilities to be inside rather than outside the road reserve?

The 2025/26 Pharmac budget for pharmaceutical medicines is $1,760,435,000, up from $1,689,634,000 in 2024/5, the year prior.

Before the budget was announced, I attempted to understand if nutrition and diet would be prioritised. I was very aware that the Ministry of Health (including Health New Zealand Te Whatu Ora, and the Public Health Agency keep forgetting to put diet and nutrition in their work programme. So I made an Official Information Act request reference number SROIA-403).

Dear Shane Reti, (January 16, 2025)

Increasingly, conventional medical clinicians and general practitioners operate with one arm behind their back, on the surface, oblivious in the face of expanding scientific knowledge on the role of nutrition in preventing, treating and reversing common conditions.

It is evident that there is a prevailing hypocrisy – one that can only naturally erode public trust - at the heart of New Zealand's health system. It involves a crazy bifurcation towards the medical, where only medicine can be prescribed at the latest known dose, not vitamins and minerals (micronutrients). This is modern public health.

Markedly, drugs are not essential nutrients. Yet it seems there is no department in the Ministry of Health with an obligation to elevate the role of essential micronutrients to a level of importance in human health functioning to where dietary nutrients are equal to, or more important than chemically and biologically synthesised drugs.

Somehow the Ministry of Health appears to believe that increasing equity of availability to drug treatment is sufficient for the prevention and maintenance of health. Availability to nutrition is not prioritised for the prevention and maintenance of health. This approach is a pervasively corrupted approach. It perpetuates a path-dependent institutional myth, medical valorisation, that most appallingly, straightjackets our poorest and most nutrient-deprived groups into medical dependency and polypharmacy.

While higher income people have the capacity to address this shortfall and actively research and fund their own treatments to address the consequences of inadequate diets, poorer groups do not.

As a trained medical doctor, you should be well aware that many chronic physical and neurological conditions will present alongside chronic nutritional deficiencies. Deficiencies will of course, be exacerbated in low-income populations which include Māori and Pasifika.

Failure to address deficiencies, instead promotes intergenerational medical dependency, dietary poverty, chronic disease, and the fatigue and poor health that prevents people from actively participating in education, training, job seeking and full-time work.

Passive Health Ministers inevitably grow welfare dependency while limiting economic growth, because people remain effectively, disabled, as conditions accrue over time.
It is very obvious that Māori and Pasifika can lead healthy lives that do not include intergenerational drug dependency and medicalisation from infancy onwards.

It is broadly obvious that people with neurological diseases and disorders commonly present with other common conditions. That across physical and mental illness, poor and insufficient diets underpin our common diseases and syndromes producing less resilient bodies and minds, to cope with the mundane, devastating and/or existential stressors of modern life.

It is well described in the literature that physiological processes require multiple micronutrients as cofactors. Health and homeostasis very simply, cannot be sustained without adequate levels of micronutrients.

But where is the funding and resourcing for this (pervasively neglected) work?

Vote Health includes funding for Pharmac to both manage and purchase pharmaceuticals. The Ministry of Health has the power to increase funding for testing services to assess nutritional deficiency by age and stage, and to expand nutrient access for treatment of chronic conditions (mental and physical).

Please forward all memos and advice sent from or to you relating to funding for the 2025/2026 budget:

(a) discussing nutrition programmes (including research). This can include reviewing the scientific evidence to update nutrition recommendations, staff and clinician education, and public health measures.
(b) Increased access to testing for nutritional deficiency where blood serum levels and deficiency is well described in the literature.
(c) Increasing access to vitamin D dietary supplementation and the range of conditions associated with vitamin D deficiency.
(d) Access to dietary nutrients for treatment of depression, anxiety and ADHD.
(e) Funding to support and promote nutrition education at primary and secondary level.

Please do not delay a response to this. Members of Parliament deserve to understand how neglected nutrition-based health policy has been. It is only if MPs are made aware this situation, that they might support you in such endeavours.

A wide catchment of public health and practitioner physicians and experts would support you in such a policy shift, as they too are frustrated in having 'one arm tied behind their back'.

Yours faithfully,

J Bruning

Three days later Shane Reti ‘was stripped of his portolio’ as Health Minister.

January 27, 2025.

Thank you for your request for official information under the Official
Information Act 1982 (the Act) to the Minister of Health, Hon Simeon
Brown.

The information you have requested is more closely connected with the
portfolio of the Associate Ministrer of Health, Hon Matt Doocey.
Therefore, this Office has decided to transfer your request to Hon Doocey
under section 14(b)(ii) of the Act. You can expect a response from Hon
Doocey in due course.

Response letter, February 9, 2025.

The response letter From Matt Doocey’s press secretary (since when do press secretaries communicate this stuff?) advised the following:

The Office identified two documents within scope of your request. However, these documents are withheld in full under section 9(2)(f)(iv) of the Act, to maintain the constitutional conventions for the time being which protect the confidentiality of advice tendered by Ministers of the Crown and officials.

But really - those ‘two documents’ that fell within the scope of my request that were then withheld because they were secret - did they really give a toss about nutrition? Were they really relevant to my request?

I’m Just Not Getting the Hint

I do keep failing on this. A few months earlier, in Official Information Act request SROIA-221 (September 2024), I had asked Shane Reti as Minister of Health, to provide:

a) All memos, policy advice and information you have considered relating to ultraprocessed food as a driver of physical and mental illness since coming into office.

b) All plans by your office to investigate diets high in ultraprocessed food as a predominant driver of mental and physical illness.

c) How funding will be prioritised to ensure that research including (i) assessment of the current scientific literature on ultraprocessed food and health/multimorbidity can be undertaken; and (ii)the extent of calorific dependence on ultraprocessed in New Zealand by age and ethnic status, may be undertaken.

d) Please supply the list of all meetings and names of groups and individuals discussing diet and/or nutrition and/or ultraprocessed foods since coming into office.

e) The Ministry of Health does not recognise metabolic syndrome, instead considering: ‘The conditions referred to are considered either on their own or as part of a broader cardiovascular disease risk calculation.’ As a medical doctor and Minister of Health do you think this perspective reflects the current state of scientific knowledge? Do you have plans to address this quirky anomaly?

Of course, the Minister didn’t hold any information on a, b, c, or e - and thoughtfully referred me to the dietary guidelines. My request for (d) was sent to Matt Doocey - who responded to say:

Minister Doocey has met with Officials from the Ministry of Health and
Health New Zealand on a number of occasions as part of routine meetings to
discuss his Associate Minister of Health portfolio delegation for
nutrition.

Since then, the budget has been announced.

Perhaps they will have realised from my emails that there wasn’t enough money for nutrition!

A quick note about the different agencies…

Public Health Agency

The Public Health Agency (PHA):

‘sits at the heart of the Ministry of Health and leads the Ministry’s work on public health and population health’

The PHA was established by the Pae Ora (Healthy Futures) Act 2022. The PHA’s fancy Strategic Intent and High-level Operating Model design document talks about equity a lot, but it doesn’t think about nutrition at all - and really - it’s not in their work programme.

National Public Health Service

Then there is the (new, I believe) National Public Health Service which:

• monitors environmental health

• helps prevent the spread of infectious diseases

• promotes healthy eating and physical activity

• works with early childhood centres and kōhanga reo to promote safe environments and good health practices

• provides health services for children

• reviews licences and public health regulations

• guides and enforces public health plans, strategies and legislation.

Well, the National Public Health Service will have a big budget then! Sounds good!

Finding the Money Budget 2025/26

If we turn back to the Ministry of Health (estimates of appropriations under Vote Health, page 3) budget of $31 billion, we can see that there is no mention of nutrition or nutritional programmes. Vote Health describes funding for screening services, addiction services, mental health programmes and services.

There is a tiny budget of $6 million for the Public Health Agency which appears to be merging with a ‘National Public Health Service’ (page 32) although.

• a decrease of $6.474 million reflecting the reducing funding profile to support the establishment of the National Public Health Service and Public Health Agency

Yep. $6 million p.a. for the foreseeable future for the Public Health Agency and National Public Health Service (page 60). That’s it, folks.

Ed. July 31 - $87.5 million is tagged for: Public health and population health leadership: This category is limited to providing leadership on policy, strategy, regulatory, intelligence, surveillance and monitoring related to public and population health. There is no clarity on who the allocation.

Then There’s Health New Zealand

Health New Zealand was also established under the Pae Ora (Healthy Futures) Act 2022. It’s role? To promote health and prevent ill-health, and achieve the best possible health outcomes for New Zealand.

Unfortunately, the Health New Zealand’s Health Charter, forgot to mention diet or nutrition.

Health New Zealand are busy, I admit, as the 2025/2026 budget (page 2) includes:

• $15,729 million (51% of the Vote) to enable Health New Zealand - Te Whatu Ora to deliver hospital and specialist services

• $9,703 million (31% of the Vote) largely to enable Health New Zealand to deliver primary, community, public and population health services

• $2,747 million (9% of the Vote) for capital investment, largely for infrastructure projects and to fund the resolution of claims from historical non-compliance with the Holidays Act 2003

• $773 million (2% of the Vote) to enable Health New Zealand to deliver hauora Māori services

Because you see, people keep getting sicker and sicker. What are we to do?

Share

Protecting, Promoting & Improving Health Using Lots of Medications

The Pae Ora (Healthy Futures) Act 2022 doesn’t mention diet and nutrition either.

Although it is a bit strange, the Healthy Futures Act’s purpose?

As every decade, chronic illness and mental illness rates increase, and younger and younger people are diagnosed early with multiple multimorbid conditions, I can only presume that I am incorrect, that protecting, promoting and improving health really means increasing hospital services and increasing pharmaceutical drug prescribing and probably, because ‘budget’ to get more people on private systems.

That that is really what ‘equity’ and ‘wellbeing’ really means.

I must be wrong about this quaint nutrition and diet obsession.

I keep waiting for a prominent journalist, or public law expert to query this concentration of power, but crickets.

The Attorney-General Hon Judith Collins has not wasted time since National came to power in 2023. Collins moved swiftly to lock in policies to reform the science system and genetically modified organisms (GMO) regulation.

Collins is the Minister for the Government Communications Security Bureau (GCSB); the Minister for Space; the Minister for Defence; and the Minister for the New Zealand Security Intelligence Service (NZSIS). Early this year, just weeks after finishing the science system overhaul and sending the Gene Technology Bill to select committee, the Hon Judith Collins swapped her science minister hat to become the Minister for New Zealand’s Public Service.

Within a couple of months Collins announced that she was overhauling the 2020 Public Sector Act. Collins is now aiming to:

‘clarify the role of the public service, drive performance and ensure accountability to deliver on the agenda of the government of the day’.

Really? A five-year-old Act is already out of date? Is this the opinion of many, or just whirlwind Collins? Some picturesque resources have been produced, but there do not seem to be wholesale calls to overhaul this Act. What is happening here?

As the Minister for Digitising Government, Collins is acutely aware that ‘It’s a portfolio that goes hand in glove with the public service.’

In 2016 Otago professor of Law Andrew Geddis remarked that the system was working and that ‘New Zealand has managed to combine unified and intensive forms of public power with a genuinely free and open society’ noting that New Zealand:

‘hardly has plunged the nation into a nightmarish vista of totalitarian authoritarianism, ruled over by the fiat of a handful of individuals in central government.’

Where are we ten years later, after a pandemic that required 13-year-olds to be vaccinated with a novel gene technology that never promised to prevent hospitalisation and death, in order to attend sporting events? Where are we ten years later, watching the Attorney-General oversee legislation that demonstrably lacks scientific credibility, before pivoting swiftly to work on breaking open the Public Sector Act, while she strengthens digital government and controls the NZSIS, GCSB and the Defence budget?

Collins strategic position is all the more startling because of the capacity for digital scaling and oversight by relatively small numbers of individuals, using secretive, black-boxed technologies that remain out-of-sight of the public.

This concentration of powers appears to be metamorphizing at the very time that Kiwis are becoming poorer and sicker.

SCALING UP EXECUTIVE OVERSIGHT POWERS

New Zealand’s executive government is charging full-tilt into maximising the opportunities provided by the scalar potential of digital and surveillance technologies. No – New Zealand doesn’t have a high rate of fraud which would entail increased ID security measures:

‘New Zealand has the lowest fraud rate of our partner countries (Australia, Canada, United States of America, United Kingdom and Ireland. For 2023, 11 cases of fraud were detected, representing 0.0023% of the 472,872 passports issued.’

There is no real reason to compulsorily require a Digital ID to access jobs, services and resourcing. It’s a political decision.

Much of the herding, or corralling onto Digital ID tech through a series of policy nudges is all ‘voluntary’. You don’t have to get a digital ID if you don’t want one. However, life can get inconvenient. The policy nudges are undertaken in full awareness that as a social species, we will comply.

Without a digital ID there are barriers to government jobs and specific services, such as arbitration services or government funding grants. A digital ID is compulsory for a gun licence. It may not be compulsory to access tertiary education, but if you have one, it’s much easier to slip into the tertiary system.

Then there is the quiet work by StatsNZ on a statistical register, called the Integrated Statistical Data System. StatsNZ’s plans for a unique identifier for every New Zealander should be unthinkable for anyone keen on limiting administrative over-reach.

Journalist Bonnie Flaws, who used to work for the accredited media, has recently published a four-part report, on how StatsNZ would have oversight and access to a massive real-time database where all kiwis have a unique digital tag. She’s outlined how the relatively unknown system has potential to accumulate fine-grained information on every individual, how privacy and data matching is a real problem, how this work extends way beyond the normal production of statistics, involving extensive access to a proliferation of data streams, and how the 2028 Census will become yet another contraction point for the merging of private data into a centralised database.

Most people are unaware of the secretive approved information sharing agreements (ASIAs) between our government agencies. The department tasked with formulating trust in digital identity services in New Zealand, the Department of Internal Affairs (DIA), is pretty much accountable to itself. The Privacy Commissioner doesn’t stand a chance.

The latest ‘oops, you’ll need an ID for this’, is a members bill to ‘protect’ under 16s through bans to designated social media platforms. Incidentally, the technicalities would necessarily entail proof of ID by everyone. It’s yet another example of a policy that harmonises with other Anglo nations, where policies consistently grant the government even greater powers of oversight.

Most recently Collins, with tourism Minister Louise Upton, released an App for tourists that ‘signals step toward modern digital identity system’. Necessarily, the App, which is currently only marketed for tourism purposes as a convenience to prove a foreign driver’s license, will be tied to revocation lists. Last year the App for a digital New Zealand driver’s license was released.

In a time of increasing opacity – please understand that revocation lists can be configured en masse.

Flaw’s work adds to PSGR’s 2024 research, which showed how central bank digital currencies (CBDCs) would necessarily be interoperable and toggled to your own digital ID. The extent to which orders can be sent from a distance and impact groups of people should be alarming to anyone who appreciates how swiftly emergency powers can be put in place in this country.

CBDC are a technocrat’s dream. Three-party locks can be programmed whereby a third party could specify functionality. Several actions can be bundled into one executable package (referred to as ‘composability’). In human language, discrete instructions could come from an unknown (but internally verified) source, identifying and tagging groups for the same action. Bank accounts of not just an individual, but groups of people could be frozen, or CBDCs withdrawn.

CBDCs may or may not come into force, but we’re watching governments freeze bank accounts with increasing impunity.

Make no mistake, digital IDs, biometric camera data and the related technologies are enabling governments to have much greater powers of oversight over us. By comparison, there has been no commensurate scaling up of oversight powers over the agencies who will hold the access to the technologies and our private information, and therefore the oversight over us.

We now have generations of government officials who are schooled in the merits and culture of ‘innovation’, ‘efficiency’ and cost cutting. But were they ever schooled on constitutional and administrative law?

Collins intends to embrace innovation in her public sector overhaul work. If you are a regular reader of my Op Eds, you might recognise the buzzword ‘innovation’. It’s a signal that more tech will be integrated into system frameworks.

Alas, innovation has nothing to do with transparency and accountability, and everything to do with efficiency. We can speculate that ‘innovation’ is a signal that operative capacity and service delivery will be enhanced. This will most likely involve the scaling up and integration of technologies that effectively and inevitably concentrate power.

When it comes to digital government which overlaps neatly with the public sector portfolio, and surveillance and intelligence portfolios, collaboration is key.

WHEN POWER CONVERGES IN ONE PERSON

The Attorney-General is powerful and influential. As Professor Philip Joseph has succinctly outlined, the Attorney General (A-G) is the senior law officer, the ‘channel of communication between the Judiciary and the Government’. Right. That’s a lot of power.

Let’s start by drawing from the biblical in proportion Joseph on Constitutional and Administrative Law tome, to highlight the powers of the Attorney-General. The Attorney-General (A-G) is both the senior law officer and a cabinet minister discharging portfolio responsibilities, the ‘channel of communication between the Judiciary and the Government’. Public Law expert Professor Philip Joseph explains:

‘The Attorney-General has four primary areas of responsibility. These involve the roles of senior law officer of the Crown, principal legal adviser to the government, named plaintiff/defendant representing the Crown in litigation by or against the government, and liaison and link between the government and the judiciary.

The Attorney-General must act always in the public interest. The senior law officer stands in a special relationship with Parliament, the courts and the executive,’ [1]

As well as holding six Ministerial portfolios, the A-G holds a unique position in Cabinet:

‘as senior law officer, the Attorney occupies a special relationship to his or her cabinet colleagues. By convention, the Attorney must exercise independent and impartial judgment, without exception for party political considerations or policy goals. The Attorney’s law officer decisions are exempt from collective cabinet responsibility and cannot be overridden by Cabinet’s collective will.’ [2]

The A-G also represents the Crown when ‘rights of a public character’ are raised:

‘The Attorney discharges this role in any of three ways: by bringing actions in the Attorney’s capacity to enforce public rights, by authorising relator proceedings to enforce public rights, or by intervening in private litigation to protect the public interest… The Attorney may intervene, upon invitation or with leave of the court, where a private action might affect the prerogatives of the Crown or raise questions of public policy.’ [3]

As part of A-G powers, the A-G has the responsibility to select judges.

In the past 50 years New Zealand Attorneys-General have had two, perhaps three ministerial portfolios. The Hon Judith Collins, KC, has six, and they strategically overlap. That is tremendous centralisation of power.

It is not normal for an Attorney-General (A-G) to hold six ministerial portfolios

By contrast, in the United Kingdom, for example the Rt Hon Lord Hermer KC is the Attorney General (A-G) for England and Wales. The UK A-G for England and Wales is not an elected member of Parliament and does not hold ministerial positions. The UK A-G is a member of the Privy Council and the National Security Council and attends, but is not a member of Cabinet. As Attorney General, Hermer also holds the position of Advocate General for Scotland.

In Australia, the A-G, the Hon Michelle Rowland is an elected member of Parliament. Rowland is also the Minister for Communications.

The A-G for Northern Ireland is Dame Brenda King. King is not a politician and does not hold ministerial portfolios. The A-Gs for Singapore, Sri Lanka, Malaysia, India are not a politician.

In Canada, the Hon Sean Fraser holds the position of A-G. At only 40, Fraser has three ministerial positions, Minister for the Atlantic Canada Opportunities Agency, Minister of Housing, Infrastructure and Communities and Minister of Immigration, Refugees and Citizenship. Fraser is also Parliamentary Secretary to the Minister of Finance, the Minister of Middle Class Prosperity and the Minister of Environment and Climate Change. Parliamentary secretary positions are directly appointed by Canada’s Prime Minister. The role is a liaison role between a Minister and Parliament and viewed as a training ground for future advance.

Our A-G outpaces them all.

CABINET HEGEMONY & THE SEPARATION OF POWERS

To continue reading:

Has New Zealand’s Attorney-General got too much power?

Share

Subscribe now

When the economic growth agency captures biotech regulation: ‘A serious question of science’

A remarkable situation has arisen in New Zealand.

The agency tasked with economic growth, that controls the science funding budget, wants to have the power of administering the legislation that would steward the very technologies that it directly funds scientists to produce. It’s the most perfect form of vertical integration and it says a lot about the biggest risk to democracy – the concentration and centralisation of power.

The New Zealand public is growing increasingly sceptical about the capacity for democratic institutions to put our best interests at heart. Conventions and processes are in place to ensure that these institutions are transparent and accountable. Public-good policy requires that the information underpinning decision-making is of the best possible standard.

But what if those processes are bypassed? If processes of knowledge gathering are knee-capped? What if scientists and researchers have become so hemmed in by tightly controlled policy that they are more like pawns in a chess game, rather than truth-seekers driven by curiosity to expand knowledge for the betterment of society?

How does this entrapment of science ‘come out in the wash’?

New Zealand’s government agency for economic growth, the Ministry for Business, Innovation and Employment (MBIE) is so entranced by the promise of biotechnology that has, to all appearances, short-circuited the democratic process and good regulatory practice. The industry-friendly legislation would lower the barriers to market for the very innovations it funds.

It’s all quite extraordinary. MBIE controls New Zealand’s science funding budget. This was quietly achieved a decade ago, using secondary legislation. MBIE’s policies for science funding prioritise the development of patents and intellectual property rights – what those on the inside call ‘innovation’. This means that scientists applying for funding of research projects that don’t include ‘innovation’ outcomes get pushed down the ladder.

This has become a case study that may not only reflect New Zealand’s woes, but mirror the global crises in policy and science across the western world.

Responsibility for regulation of new gene technologies from New Zealand’s Environmental Protection Authority to MBIE is presumed, even though MBIE has no expertise in human or environmental health regulatory processes. MBIE’s Regulatory Impact Statement problem definition placed deregulation, not risk and stewardship as the key ‘problem’ to solve. Then, instead of bringing in a cohort of experts in health regulation, the experts, and groups that were selected in the consultation phases, were the very institutions and interests with financial interests in biotechnology development. And a primary funder across those institutions? MBIE!

To continue reading:

When the economic growth agency captures biotech regulation: ‘A serious question of science’

Subscribe now

Historically farmers with avian influenza would let the infection run through their sheds and let the birds and animals develop natural immunity. The USA has just learnt a big lesson, they culled 166 million to ‘stamp out’ H5N1 and now they’ve changed tactic. Avian influenza is traditionally mild in chickens. The threat isn’t the virulence (speed of transmission) but the potential to kill.

HPAI strains are a cause for concern, sheds must have impeccable hygiene and biosecurity controls, but there is no need to blindly cull. Yes, some markets will require their imported products to be from a country free of HPAI and exporters must adhere to individual country standards. MPI reported that since the December 2024 operation in Otago, 65 percent of affected trade has been recovered so far.

High pathogenicity avian influenza (HPAI) was detected in New Zealand in December 2024. MPI stated that:

The H7N6 strain is closely related to LPAI strains present in wild birds in New Zealand.

LPAI has been present in wild bird populations in New Zealand for decades and many species of wild birds may have strains of the virus. Internationally, over 5,000 species of wild birds have this type of avian influenza.

LPAI causes few or no signs of illness in wild birds. However, when a low pathogenicity strain of avian influenza is introduced to chickens, it can mutate into a high pathogenicity strain.

Testing indicates that the infection at the Hillgrove farm happened after free-range laying hens foraging outside were exposed to the low pathogenicity virus from wild birds, which then mutated in the hens to become HPAI. It was the first detection of HPAI in New Zealand.

How did the virus naturally mutate into a high pathogenicity strain? If this is correct, the most likely reason may be stress. Poultry and egg farmers are fanatical about the quality of their feed because high performing poultry need exact nutrient and energy requirement to maintain immune health, avoid disease and maintain productivity.

We do know that good can people make mistakes. There’s a story in the industry that once someone at a feed supplier put the wrong decimal place in on the weighing instrument for carotene. The eggs ended up being green! What if key dietary ingredients such as amino acids were at the wrong level? So much can go wrong. Getting to the bottom of this involves deep trust, with our businesses confident that MPI isn’t going to walk around swinging sledgehammers.

H5N1

New Zealand authorities are reportedly waiting for HPAI H5N1 to land on New Zealand shores via, most likely bird migration. New Zealand poultry farmers have been advised that once H5N1 is endemic in New Zealand, there will be no compensation.

Since 2020, the HPAI H5N1 2.3.4.4b clade has been reported in Europe, Asia, Africa, and North and South America. MPI repeatedly referred to this clade in their communications. In May 2024 RNZ did an ‘anxiety’ piece on the transmissibility of H5N1 to mammals. No shit sherlock. H5N1 is known to infect at least 450 different animal species.

But is a declaration of HPAI a death wish for our plucky chickens AND their farmers?

‘HIGH PATHOGENICITY’

High pathogenicity means the potential for an agent to spread quickly and cause disease, another word for this is virulence. This 2007 paper by Swain stated:

Overall, such pathobiological features vary with host species and virus strain. Experimentally, HPAI viruses typically produce a similar severe, systemic disease with high mortality in chickens and other gallinaceous birds. However, these same viruses usually produce no clinical signs of infection or only mild disease in domestic ducks and wild birds. Over the past decade, the emergent HPAI viruses have shifted to increased virulence for chickens as evident by shorter mean death times and a greater propensity for massive disseminated replication in vascular endothelial cells.

Just because a virus reaches our shores, this does not automatically translate to a high mortality rate (whether of poultry or humans). Humans have a very low mortality rate from avian influenza. We need to demand transparency and discretion from authorities who scarily imply high death rates in humans following infection with avian influenza. Note bene: If authorities only count the people who die from influenza as people who are the elderly and infirm, and/or people who have multiple morbidities diagnosed with infection, and then divide that by deaths, that is a misleading figure on the real death rate. This may be what is happening with human mortality estimates from avian influenza. Asymptomatic transmission can be completely ignored.

In December MPI told us that they’re going to ‘stamp out’ HPAI H7N6. A virus that doesn’t kill humans, and for which we still don’t know the mortality rate in NZ.

… MEANWHILE IN THE USA - THEY COULDN’T ‘STAMP OUT’ H5N1

US authorities first detected HPAI H5N1 in 2022. Authorities commenced a national cull to attempt to stem the virus. The Biden administration released $2 billion to support the cull and compensate farmers. This didn’t work and H5N1 spread to 50 states.

166 million birds have been culled and US farmers have been compensated to some extent. H5N1 has cycled and recycled in naïve flocks. The virus has not been permitted to die down naturally. H5N1 continues to be detected with USA authorities confirming some 12,000 cases of HPAI in wild birds to date.

On December 18, Newsweek reported that the week prior, a Louisiana person who was older than 65, with underlying medical condition was hospitalized in critical condition with severe respiratory symptoms from a bird flu infection. The patient had been in contact with sick and dead birds in a backyard flock.

This appears to have been the tipping point for California Governor Gavin Newsom to declare a State of Emergency on December 18. At that stage 34 cases of bird flu (H5N1), but no human deaths had been recorded. Most cases were in California. There was no disclosure of mortality rates in poultry.

Some 10,000 cases in dairy cows have since been reported. H5N1 doesn’t represent a death risk for dairy cows and workers appear to be most at risk of conjunctivitis.

In February the new Trump administration and U.S. Department of Agriculture (USDA) changed course with a $1 billion strategy, largely in response to high egg prices. The course change involves stricter biosecurity measures with the USDA sharing:

up to 75% of the costs to fix the highest risk biosecurity concerns identified by the assessments and audits, with a total available investment of up to $500 million.

The USDA is not overtly discussing the role of natural immunity in moving the US flock forward. However, this is the implicit suggestion, with the agency rolling back from aggressive culling and acknowledging that vaccines haven’t been demonstrated to be sterile, i.e. they don’t stop transmission of infection in poultry.

In a Breitbart interview on March 8, 2025, U.S. Department of Agriculture (USDA) Secretary Brooke Rollins acknowledged the

‘what I learned is that looking at countries like Mexico that actually do vaccinate their egg-layers is that those chickens have to be stuck three or four or five times with those vaccine shots and then 80 to 83 percent of those chickens still get the avian bird flu. So I pulled that off the table and for a lot of reasons we are not going to be moving off the table on mandatory vaccines now or frankly ever.’

Rollins continued:

“The avian flu is extremely pathogenic—pathogenic is the right word for it. It’s transmitted through wild fowl,” Rollins said. “So let’s say a wild goose flies over your egg-laying barn, and then defecates—then someone steps in that and then walks into the barn. All of a sudden you’ve got an avian flu case that is so—it spreads like wildfire. So once the barns though are locked down with proper ventilation, the roofs are patched, the walls are put up, then you’ve significantly decreased your chances of having any of that in your barn. That allows you to keep laying the eggs and keep feeding your state, the country, and the world frankly. When we say biosecurity, that’s what we mean—locking the barns down, patching the holes, making sure the fowl don’t get in, but also looking potentially at how we breed chickens to have stronger immune systems so that maybe the ones that aren’t getting sick instead of killing the whole herd so we can potentially do something. We do have some farmers out there right now that are piloting that. Instead of mass culling and the USDA basically telling you to put your whole barn down, how can we be creative and innovative in solving this big issue right now?”

Rollins then discussed 150 pilot projects where barns were locked down, the government paid for 75% of the locking down, and only one case of avian flu had been detected across the 150 premises in the project.

Later in March, following a question by Politico, Rollins agreed with

‘Kennedy’s assertion that vaccinating poultry against avian influenza would “turn those flocks into mutation factories”

UNDERSTANDING MPI’S REASONING FOR ORDERING THE CULL

MPI have not been forthcoming with information. A December 5, 2024 Official Information Act request made by the Reality Check Radio breakfast team (OIA24-0914) was not answered until April 14, 2025.

As at 3 December 2024, 35 samples had been taken from the affected property, and 94 percent of these had returned positive results for high pathogenicity avian influenza (HPAI). Please note that a given bird may be represented in multiple samples.

MPI does not record which specific birds within the shed were sampled or how many birds are represented in the samples, so the number of birds that tested positive for the H7N6 strain of HPAI is not known

Only 35 samples, the hens didn’t appear to be tagged, and so one bird may have been represented in multiple samples. What?

PCR tests were run at between 20 and 45 cycles, but there was no declaration at what threshold detections started at. It’s fairly well known that thresholds above 35 can lead to false positives, and PCR tests are not recognised as perfect, in part, I believe because there is little capacity for these tests to determine if genetic sample comes from a live virus or a dead particle.

No scientific analysis laying out data clearly was provided. No scientist has communicated the data for media and the public.

Without transparency we now know that cases and infection counts can be used as a fear tactic, to corral people into following pre-prescribed policies.

In the OIA24-0914 MPI stated:

‘it is accepted practice internationally where outbreaks happen to depopulate flocks to stop the spread of the virus to other birds and reduce exposure to people.’

What if HPAI is in a flock but only 20% of the flock die, and the rest recover? Is that fair on the farmer, that the entire flock is culled? Is it fair on consumers who then face egg shortages, and egg prices hikes?

Word on the street is that perhaps only 6,000 had died out of 80,000. Would this have made the strain a low pathogen avian influenza (LPAI)?

MPI state that it is ‘accepted practice’ - but as New Zealanders on an island continent, we can demand far more accountability, and less haste. MPI stated ‘If birds are not depopulated, the virus will spread.’ Yes of course, but as the U.S. was showing us for the last 5 years, the virus will spread anyway.

We can’t understand lethality if we cull flocks. We can follow historic practice and lock-down farms until the wave of infection has passed. We’ve seen far too much delegation to offshore ‘wisdom’ in the past 5 years - and that ‘wisdom’ isn’t scientifically justified.

Allegedly, some $20 million may have been involved as compensation to Mainland Farms in Otago for having to carry out the cull. Mainland Farms are a good operator, and they did what MPI told them to do.

Questions for MPI:

• Was there established scientific evidence that the death rate would be high?

• What was the mortality rate that the ‘accepted practice’ was based on?

• What was the mortality rate for the Otago sheds?

• Did MPI discuss the mortality rate and the severity with the owners of the Otago sheds?

• Does MPI know that infection with a low pathogenic avian influenza provides effective protection against infection and mortality caused by HPAI virus?

• What work has MPI done to highlight the uncertainty of a mortality rate once a virus ends up in New Zealand after circulating the globe?

Farmers are like epidemiologists - they can study watch a virus move through the population. They can understand virulence, they can gain an approximation of the extent of morbidity and mortality. Farmers talk, they network. Veterinarians chat. The neighbour looks over the fence. They network and attend industry zoom calls. No one wants to spread a high-mortality virus and ‘word’ will get out in industry. We need to listen to farmers, and respect their advice and wisdom.

Perhaps, if HPAI is virulent, in a well-run, clean shed, with good nutrition, there may be a low death rate. Perhaps if a low pathogenicity strain has been through the shed, the death rate will be even more minor.

MPI does not have scientists who are experts in poultry and avian influenza responding to press releases. We can trust our poultry farmers.

I’d love it if pre-2019 advice for poultry and egg farmers on infectious disease management, and the history of high mortality events were up on the Poultry Industry Association of New Zealand (PIANZ) web pages, so that new industry entrants and the public had some idea about how common these events are and historically, how these events were managed.

Where are the scientists doing real research working with real farmers?

MPI uses unscientific language like ‘stamping out H7N6’. Yet there is real potential for symptomatic and asymptomatic transmission. I don’t want Kiwi owned businesses to be ruined if MPI is chasing a virus that doesn’t have a high death rate. Yet they will, if HPAI viruses that are endemic in the population, and MPI forces every farmer with an infected shed to cull their flocks no matter the mortality data.

I’ve been on teams working in sheds culling poultry at the end of life. Your lungs get filled up with feather filaments, your eyes get itchy. MPI advised that letting a virus spread through a flock is ‘an animal welfare concern’ and that the flocks were humanely culled. What does this involve to make it humane?

There is no doubt that automatically culling an entire flock where most of the flock would have recovered and lived if we had isolated the farm and stood back to understand the mortality rate - is an animal welfare concern.

Culling flocks also puts the farmers/workers at high risk of infections. We know that it is mainly a form of conjunctivitis or pink eye. That is not fun, but you don’t have to start working out your favourite funeral music.

THE ROAD TO BUSINESS FAILS & CORPORATE BUYOUTS.

If MPI demands automatic culls no matter the death rate, this will kill locally owned businesses, and likely be a big win for off-shore corporates with more equity to whether storms.

If a farm can be shut down any month - what bank will give that farmer a loan? To start a business, update farm equipment, and even, ironically, to improve hygiene? What will happen to the cost of insurance? Currently, the average shed is probably spending a quarter of a million dollars on biosecurity alone. Are the costs of biosecurity able to be absorbed, or does this become another tipping point for New Zealand owned businesses?

Farmers I know, know that if they went belly up, a large Chinese multinational will snap them up straight away. I’m not sure if NZ owned business is part of MPI’s calculation.

The truth is - the capacity for Kiwi owned business to survive HPAI should be a key calculation. Any official weighing risk from HPAI under the Biosecurity Act 1993 (see some links and content at the bottom of this article) should be considering that smaller businesses have far less capacity to endure a downturn than a large corporation with massive equity. It is reasonable that they do this. It is also reasonable that we do not automatically lock-step follow overseas processes because, as the U.S. kill craze has demonstrated, offshore plans can go asunder.

TRANSPARENCY AT EVERY STAGE FOR POULTRY/EGG PRODUCERS

I want to know exactly what guidelines and what data makes a virus an ‘HPAI’ virus - and the work our authorities go to, to establish the pathogen of concern reflects those characteristics.

MPI should have an obligation to publish these plans and the data supporting them, prior to any cull order. Organisations that have to cull should never be required to sign non-disclosure agreements.

Is it this 2000 standard? Swain and Suarez (Southeast Poultry Research Laboratory, Agricultural Research Service, United States Department of Agriculture) defining high pathogenicity in 2000:

a) any influenza virus that is lethal for six, seven or eight of eight (>75%) four- to six-week-old susceptible chickens within ten days following intravenous inoculation with 0.2 ml of a 1:10 dilution of a bacteria-free, infectious allantoic fluid; b) any H5 or H7 virus that does not meet the criteria in a), but has an amino acid sequence at the HA cleavage site that is compatible with HPAI viruses; c) any influenza virus that is not an H5 or H7 subtype and that kills one to five of eight inoculated chickens and grows in cell culture in the absence of trypsin.

(The cleavage site is emphasised as the cleavability of the haemagglutinin (HA) protein was identified as the major determinant of virulence in HPAI viruses in 1979.)

Or has it been updated? Perhaps cleavability of HA doesn’t always amount to a high death rate in mater populations? Who knows?! Where is that information for New Zealand businesses?

Because of the threat to the survival of businesses, all poultry (including egg) producers should be able to see all steps of every pest management plan and assess whether MPI has taken into account - and understands the mortality rate.

THE VACCINE RISK - IMMUNE ESCAPE/DISEASE ENHANCEMENT

The ‘mutation factory’ statement by Kennedy that Rollins quoted relates to the risk of antibody dependent enhancement. Antibody dependent enhancement is an old problem, where antibodies can enhance virus entry and replication in cells is an ‘unavoidable problem’ for vaccine developers.

Kennedy has done the research. Vaccination can enhance antibody dependent enhancement (ADE) and is a major impediment to vaccine research. Very basically, the disease is ‘enhanced’ - the virus binds to suboptimal antibodies, allowing the virus to get into immune cells and replicate. As Wikipedia notes: if the virus is not neutralized, antibody binding may result in virus escape and, therefore, more severe infection. This is more likely to happen if a vaccine’s efficacy wanes, or if the subject is immunocompromised.

A Singapore/U.S. study by Yao-Tsun Li et al (2021) showed it’s impossible to determine if vaccines will make things better or worse for farmers over a period of time:

‘nationwide control measures, including vaccination in China, successfully suppressed H5N1 populations in poultry, providing an opportunity for antigenically distinct H5Nx viruses to emerge. In particular, we show that the widespread use of H5N1 vaccines likely conferred a fitness advantage to H5Nx viruses due to the antigenic mismatch of the neuraminidase genes.’

A study by BingYing Li et al (2025) looking at H5 HPAI viruses from 1996-2023 found that movements from wild birds to unvaccinated populations were more frequent than movements into vaccinated populations - but that H5 in vaccinated populations evolved more quickly in more ways.

The HA [hemagglutinin] gene of the AIV lineage that circulated predominately among Chinese poultry with high vaccination coverage underwent faster evolution and greater nonsynonymous divergence than other lineages.

It’s not just a risk for H5 - it’s a broad-spectrum risk. A study on the H7N9 strain acknowledged that immune escape mutations could arise via vaccination or natural infection.

The continued circulation of the virus in birds carrying virus-neutralizing antibodies induced through vaccination or natural exposure drives viruses to evolve and escape from the immune pressure.

If we talk about humans, for example, prior to the release of the COVID-19 mRNA gene therapy, Pfizer and BioNTech (page 44) identified vaccine-associated enhanced disease including vaccine-associated enhanced respiratory disease as an important potential risk.

VAED is thought to occur by several mechanisms where the immune response is not fully protective and actually either causes the body to have an inflammatory reaction due to the type of immune response with specific types of T-cells, or the body does not produce enough strong antibodies to prevent SARS-CoV-2 infection of cells or produces weak antibodies that actually bind to the virus and help it to enter cells more easily, leading to worse signs of disease. (Medsafe (2022, Feb 27). Updated summary of risk management plan for Comirnaty)

Vaccine-derived immunity particularly from new biologic drugs like the COVID products is far less certain than protection from natural immunity, which is derived through more durable T-cell and B-cell responses.

The risk is a vaccine treadmill with naturally seasonal mutations being layered with vaccine-derived mutations. Vaccination is a financial cost, but there can be side effects, and it’s well recognised that natural immunity is more durable.

FINANCIAL INCENTIVES INCREASE LIKELIHOOD OF AN EVENT

The risk of a harmful pathogen is vastly amplified by the preponderance of labs and global failures to meaningfully regulate and prevent gain-of-function research. There is a global ‘boom’ in biolab construction, most biolabs are in cities with more than half of the biolabs working with animals being based in the U.S.. Biorisk management and oversight has not kept up with the pace of operation of these labs.

Laboratory acquired infections (LAI) and accidental pathogen escape from laboratories (APELs) are relatively common:

‘Of the 309 individual LAI cases, most occurred in North America (n=243, 78·6%), followed by Europe (n=28, 9·1%) and Asia (n=23, 7·4%), with the majority of the reports originating from the USA… procedural errors represented the leading cause of LAIs, accounting for 69·3% of cases. 16 APELS incidents were reported between 2000 and 2021 that involved bacterial (n=6, 37·5%) and viral (n=10, 62·5%) pathogens.

If scientists are paid to do research, they will. Gain-of-function (GoF), or serial passage research is undertaken to increase the transmissibility and virulence of pathogens. The U.S. stopped funding GoF and imposed a moratorium in 2014. This was lifted in 2017. Evidence has now surfaced that instead of stopping research, the U.S. GoF experiments and work shifted to China.

Gain-of-function research is ‘dual use’ research. While the claim is that GoF has been essential for vaccine development, and to enable developers to deal with nastier strains of a pathogen, there is increasing evidence that unintentional and intentional laboratory escapes of harmful pathogens may amplify the policy environment for government to build vaccine mandates into policy, and increase financial returns. This appears to be the case with COVID-19.

In a recent paper Hulscher et al (2024) postulate that genetic evidence suggested geographic proximity of outbreaks with labs conducting GoF or serial passage research. H5N1 clade 2.3.4.4b was first detected in the Netherlands in October 2020. In 2012 at the Erasmus Medical centre in Rotterdam, Wang Y et al (2012) had modified H5N1 to become airborne transmissible in ferrets. Wang et al went on to publish his laboratory methods for genetically manipulating H5N1, so that this work could be replicated.

Has Hulscher et al discuss, Wang et al had previously closely collaborated with the USDA Southeast Poultry Research Laboratory (SEPRL) in Athens Georgia on H9 avian influenza viruses. SEPRL was conducting serial passage experiments in Mallard ducks from April 2021, and a new H5N1 subtype was detected in Georgia in January 2022.

NATIONAL AUTHORITIES WITH FINANCIAL CONFLICTS OF INTEREST

MPI referred to the World Organization for Animal Health (WOAH) who seems to be an authority. Yet who funds the WOAH? The WOAH acknowledges funding partners include philanthropic funds and non-government organisations.

We’re seeing convergence where health authorities that we should be able to trust, have financial and political conflicts of interest. It is well established that the World Health Organization is heavily funded by organisations with extensive financial ties with the pharmaceutical and vaccine development industries.

The problem is amplified when health authorities profit from vaccine investment and development. The U.S. Department of Health and Human Services, owns nearly 5,000 patents, and awarded $590 mill in Moderna’s bird flu vaccine development. The CDC which was in 2014 advocating for performing experiments on H5N1 for ‘pandemic preparedness’ makes money from licensing.

Even MPI is in on the game, going halvies with a bunch of our monopoly organisations to theoretically develop what could become mandated medications to lower methane.

It’s all a bit too murky.

What is the answer? Grounding decisions in local science, local evidence, and transparent collegiality between our poultry and egg producers and MPI. Increasing basic science research for independent researchers (not MPI) so that with the next emergency, MPI isn’t the font of all knowledge, but gets away with deferring to offshore ‘rules’ because we haven’t funded the science to have the expertise.

Unfortunately, MBIE doesn’t currently fund that sort of science because their priority is on patent development, known as innovation.

End.

PLEASE: Let me know if any of the above statements are incorrect. Happy to edit.

Share

Subscribe now

THE BIOSECURITY ACT 1993

Biosecurity Act 1993

Section 22 of the Act mandates that, before implementing a pest management plan, the responsible Minister must be satisfied that the benefits of the plan outweigh the costs. This includes considerations related to protecting domestic food production, public health, and the environment.

61 First step: plan initiated by proposal

(1)The first step in the making of a plan is a proposal made by—

(a)a Minister; or

(b)a person who submits the proposal to a Minister.

(2)The proposal must set out the following matters:

(a)the name of the person making the proposal:

(b)the subject of the proposal, which means—

(i)the organism proposed to be specified as a pest under the plan or the organisms proposed to be specified as pests under the plan; or

(ii)the class or description of organism proposed to be specified as a pest under the plan or the classes or descriptions of organisms proposed to be specified as pests under the plan:

(c)for each subject,—

(i)a description of its adverse effects:

(ii)the reasons for proposing a plan:

(iii)the objectives that the plan would have:

(iv)the principal measures that would be in the plan to achieve the objectives:

(v)other measures that it would be reasonable to take to achieve the objectives, if there are any such measures, and the reasons why the proposed measures are preferable as a means of achieving the objectives:

(vi)the reasons why a national plan is more appropriate than a regional plan:

(vii)an analysis of the benefits and costs of the plan:

(viii)the extent to which any persons, or persons of a class or description, are likely to benefit from the plan:

(ix)the extent to which any persons, or persons of a class or description, contribute to the creation, continuance, or exacerbation of the problems proposed to be resolved by the plan:

(x)the rationale for the proposed allocation of costs:

(xi)if it is proposed that the plan be funded by a levy under section 100L, how the proposed levy satisfies section 100L(5)(d) and what matters will be specified under section 100N(1):

(xii)whether any unusual administrative problems or costs are expected in recovering the costs allocated to any of the persons whom the plan would require to pay the costs:

(d)any other organism intended to be controlled:

(e)the effects that, in the opinion of the person making the proposal, implementation of the plan would have on—

(i)economic wellbeing, the environment, human health, enjoyment of the natural environment, and the relationship between Māori, their culture, and their traditions and their ancestral lands, waters, sites, wāhi tapu, and taonga:

(ii)the marketing overseas of New Zealand products:

See further: Biosecurity Act 1993

Pest management plans

National pest management plans

59Definitions for sections 60 to 6760Relationship of rules and plan with law

61First step: plan initiated by proposal

62Second step: satisfaction on requirements

63Third step: satisfaction with consultation or requirement of more consultation

64Fourth step: approval of preparation of plan and decision on management agency

65Fifth step: satisfaction on contents of plan and requirements

66Making of plan

67Exemptions from rules

Regional pest management plans

68Definitions for sections 69 to 78

69Relationship of rules with law

70First step: plan initiated by proposal

71Second step: satisfaction on requirements

72 Third step: satisfaction with consultation or requirement of more consultation

73Fourth step: approval of preparation of plan and decision on management agency

74Fifth step: satisfaction on contents of plan and requirements

75Sixth step: decision on plan

76Application to Environment Court about plan

77Making of plan

78Exemptions from rules

How might we understand this? We can think of traditional health-based risks in any disease event - differs based on age, stage, health status etc. But overlay this with networked global shifts which have potential to corrupt and distort domestic decision-making, and thereby undermine free will, human rights, and domestic sovereignty. I.e. increase risk to you, me and our fellow Kiwis.

UPDATE (23/04/25): My submission to the Royal Commission Phase 2 consultation:

Bruning Jr Submission 2025 Covid Phase 2 Enquiry April 23

2.03MB ∙ PDF file

Download

Download

If New Zealanders don’t have a way to talk about the nature of power, the problem of convergence, of how technology can be secretly scaled up, and of the networked nature of power - we will, in the ‘next pandemic’, risk an onslaught of policies, laws and interventions that undermine free will and sovereignty, and leave us sicker and poorer.

This Venn diagram might help to understand the relationships and overlays.

PROBLEM OF GLOBAL SHIFTS: domestic considerations can be undermined.

Global power networks influence governments and can directly influence how politicians and government agencies identify risk, approach an emergency event and identify policy solutions for that event.

• Pandemic Industrial Complex: Biolabs expansion & gain-of-function research directly increases the prospect of a pandemic. E.g. this weekend’s WhiteHouse release and this discussion with Dr David Bell.

• Policy & Scientific Information controlled & shaped by global actors. Emergency powers are secured based on how risk is represented by these actors. Who asserts whether a medical intervention is ‘safe and effective’. E.g. Pfizers BNT162b2 gene therapy did not prevent transmission, it was a new technology, yet epidemiologists & doctors with divergent perspectives during the Covid Event were dismissed by media, censured by professional organisations. Note bene: we still have doctors in front of NZMC tribunals in New Zealand in April 2024.

• Global Actors market consolidation: across fintech, biotech, resources, media & communications & defence increases power in a smaller group of actors. E.g. Equity market concentration.

• United Nations: Actors outside democratic oversight (indemnity of officials working for UN organisations). United Nations institutions are not resourced to identify risk by age and developmental stage, by multimorbid status, by season and climate, and how these factors increase or decrease risk from a vector-borne outbreak. United Nations institutions have no obligation to assess the extent of corporate corruption and influence in policy development.

• Global Actors as government allies: Co-operate with nation states to influence, integrate, expedite & deploy domestic policy. This policy can be a function of the scientific and risk-based information that these global actors promote. E.g. World Economic Forum’s mission, The Bill Gates Problem, CBDC policy development in New Zealand, Biden White House April 2025 release.

• Nation states fast-track laws and abuse powers via delegated legislation. E.g. The Covid mandates in New Zealand involved an automated, stepped process without any update of risk to identify whether the coronavirus risk and the Pfizer BNT162b2 injection risk were risk-proportionate by age and stage. Discussed in the uploaded papers on my previous Substack post.

• Digital Convergence: Expansion of control & access to private data by government & industry will accelerate/amplify the potential for governments to identify and stamp down dissent in any future emergency event, regardless of the risk. E.g. this weekend’s 4-part series on NZ-based Byline Babylon.

THE CRITICAL TURN TO PUBLIC HEALTH ETHICS

Our politicians and government agencies must recognise the importance of subsidiarity where social, political and health-based issues are dealt with at the most immediate or local level.

This involves granular high-quality information so that we can protect a baby, a child, a pregnant woman and the aged and infirm. Currently there is no scientific or research agency in New Zealand with the scope and long-term funding to research human health risk over time. If we enter the next ‘pandemic’ with science funding directly controlled by political agencies, it is probable that we will again face lock-step surveillance, mandates and injections.

It is non-controversial that early-life harms can result in a poorer health-based outcomes, and a poorer quality of life for decades into the future (years lost due to disease). Government responses to COVID-19 ignored this. However, if we lack the institutions with the scientific freedom to speak up, political aims will over-ride these important considerations.

However … we have to be wise to creeping authoritarianism. Digital convergence is happening at scale in New Zealand. If corporate science is used to enforce policy, and politicians refuse to update themselves of information that contradicts their established policies, Cabinet can and will use secondary legislation in an emergency to prevent dissent and disinformation, then use emergency powers to access private data which has been consolidated, there is potential for abuse of power at scale.

We can only protect public health in a future pandemic - if we understand the nature of power and take steps to inform and educate, and ensure that the individual is protected including through the prevention of harm.

Normalising issues that were dismissed and ignored in the pandemic by state media, by the government, by the Ministry of Health - is an important step to helping understand why principles and ethics are important overarching guidance.

We are all wonderfully different.

EMERGENCY​ / PANDEMIC - Domestic, public-good (ethics-based) considerations that were ignored & dismissed in COVID-19:

We must inform, educate and improve access to research to identify the drivers of communicable and non-communicable disease which are more frequently environmentally driven, than genetically driven.

• Individual risk - How is individual health and wellbeing best protected? Are scientists and doctors able to talk about risk to an individual from either the vector or any government intervention?

• Developmental stage - Different whether infant, child, adolescent, adult, aged, infirm.

• Multimorbidity - Risk of hospitalisation & death amplified when an individual has 4+ disease conditions. Policies to lower risk (e.g. Diabetes reversal).

• Time of year (nutritional status including vitamin D)

• Socioeconomic - impacts nutrition, multimorbidity risk, stress exposures over time.

• Family & friends - Isolation cuts life expectancy in half, yet isolation was enforced during Covid-19 without consideration for personal preference.

• Disease vector - How does it shift and change in time. Is it viral, bacterial, chimeric? Do we have the scientific freedom to look at its biology and establish whether it has been produced using gain-of-function research?

• Short-term risk - environmental exposures can result in acute short-term risks, such as disability, hospitalisation and death.

• Long-term harms - Principles and ethics provisions help governments recognise the need to act with caution so that an intervention does not create more harm over time. The solution being worse than the cure.

Civil society and good people in government and academia can help draw attention to the following:

• Human Rights - Lock-downs and mandates were enforced during the Covid event and increasing digitisation of government may set the stage for abuse of power at scale in future.

• Informed Consent - the NZMC sanctioned doctors who sought to speak up about informed consent. The NZMC ignored its own informed consent policies and did not review the scientific information on hospitalisation and risk by age and stage (including pregnancy risk).

• Democratic accountability - when laws are made, the public must be able to see that the laws were fairly and reasonably made. The Health Act infectious disease principles (Part 3A) were ignored during Covid, officials never discussed them.

• Sovereignty - Undermined when secret understandings and agreements are made.

• Fairness and justice - democracy only works if fairness and justice is upheld by officials who follow transparent, accountable processes, and when processes of complaint and investigation actually work.

• The Great Barrington Declaration: The history and propaganda attack on the Great Barrington Declaration (October 2020) which had been drafted and signed by three impeccably credentialled epidemiologists: professor of medicine at Harvard University Dr Martin Kulldorf, professor at Oxford University Dr Sunetra Gupta, and professor at Stanford University Medical School Dr Jay Bhattacharya.

• Independent science - Freedom is required for independent public-good research. Who paid for the evidence, who controlled the scope of the evidence, when was the evidence updated, and what does the evidence exclude?

Emergency provisions are dangerous for democracy. Principles (including the freedom of information dissemination) and ethics are in place to prevent the abuse of power. There will always be a tendency for political and financial interests to seek to exploit a situation for their own benefit. When government practices which conventionally enshrine principles, obligations for transparency and accountability, and ethics that are in place to promote transparency and accountability are undermined by emergency provisions, this can set the stage for the abuse of power.

THE DANGER OF NETWORKED RISK: SECRECY AT SPEED & AT SCALE

This Venn diagram gives some understanding of how networked risk can undermine human and public health considerations.

Please reuse/share this image - creative commons. No need for attribution.

[1] The Networked Risks may increase the risk of people in the next global event.

[2] This is why it is important to recognise the interconnection between global shifts that enhance human & democratic risks in the centre of the diagram and human & democratic risks around the outside.

[3] These different risks cross over and interact. Secrecy, the speed of communications and the scale at which technology can be deployed enhance the risk of everyone, from a baby to someone at the end of life.

Subscribe now

NZ C19 ROYAL COMMISSIONERS PLEASE CAN YOU:

Take important steps to:

• reaffirm the importance of public law principles, public health ethics, and ensure that elected members, government officials and the public and media in general are educated in public law, and public health ethics.

• Recognise that New Zealand health policy is over-weighted to medical research for drugs, and medical treatments that treat symptoms, not prevent disease. Recommend that it is time that an environmental public health research institution is developed with long-term block funding, to understand and assess the drivers of disease, the drivers of risk of communicable and non-communicable disease, and to focus on nutrition and non-medical public health protection.

This would serve two functions: to improve policy so that nutrition and non-medical health-based preventative education can be widely integrated into policy so that New Zealanders would be healthier and more productive and enter any pandemic or emergency event at less risk of hospitalisation and death.

To improve the knowledge and skills of scientists and researchers to ensure that in the next pandemic or emergency event, there would be an independent quorum of skilled researchers at arm’s length from government agencies. This would prevent the likelihood that those agencies would be misinformed by institutions with financial and political conflicts of interest, and therefore prevent the abuse of power.

Share

Idle weekend watching: Democracy’s Unspoken Foundation: Where is the real fourth estate?

It was perfect. People who actually looked across the scientific literature, experienced first-hand patients with COVID-19, and understood that the pharmaceutical and non-pharmaceutical interventions were likely to present more risk to the majority of the population than the intervention were not permitted into the conversation.

The media would have nothing to do with them and the government would manage all ‘expert’ information and nothing. Nothing. Could contradict the message.

The best bit? Cabinet could push the mandates through as secondary legislation in ultimate secrecy - no Official Information Act requests would intrude (and believe me, I tried). And so they did. Mandate after mandate throughout 2021. Just like they planned at the start of 2021.

No matter the changing evidence over 2021 on risk - they would follow the script.

The rollout. To the young and healthy, to the old and sick.

Just like robots.

You haven’t heard from me for a wee while, at PSGR we have been reviewing official documents that suggest officials have short-circuited good process during gene technology and science system reforms, and this has taken quite some time.

More on that another day. Friends & colleagues we have a deadline!

The COVID-19 Royal Commission Inquiry Phase 2 (deadline for submissions April 27, 2025) is assessing key decisions made by the New Zealand Government in 2021 and 2022 in the following areas:

• Vaccines, including mandates, approvals, and safety

• Lockdowns, especially the lockdowns of late 2021

• Testing and tracing technologies (like RATs or the COVID-19 Tracer app), and public health materials (like masks).

The Phase 1 process of this Royal Commission was to put it mildly, ethically unconscionable. The terms of reference drafted out most of the issues that drove harm.

With this Phase 2 process, groups such as NZDSOS and RCR have provided help for those who are a bit daunted by the process.

JR Bruning - Back Story

During COVID-19 I was researching and writing my master’s thesis while also working pro bono for PSGR. My thesis concerned the problem of scientists in New Zealand and Australia being unable to access public research funding for public good scientific research. The specific research area was health conditions that were impacted by endocrine/hormone disrupting substances. Of course, the endocrine system is integral to human functioning, spanning physical and mental health, from diabetes, to cancer, Parkinsons, to neurological syndromes including Alzheimer’s and autism.

I was interviewing scientists to understand if they could access research funding to understand the drivers of these diseases, which often involved hormonal pathways. My research established that scientists could only secure funding if they identified an innovation pathway – i.e. a potential route to commercialisation, medical therapies. If there was no route for a medical intervention the funding proposal would be pushed down the ladder. Many of these scientists themselves had sat on funding committees and understood clearly what was expected of funding committees. They had to adhere to MBIE’s science policy.

Courtesy of Auckland University I had access behind journal paywalls, and courtesy of PSGR I had access to doctors, many of whom spent their lives serving the most marginalised communities, the communities with the exact risk profile for COVID-19 – profound multimorbidities and low vitamin D the key risk factors for hospitalisation and death. By November 1, 2021, just as all the mandates were rolling in, much of this was documented on the PSGR website. These pages serve as a time capsule of what we knew then, and haven’t been updated (even to be edited for grammar etc.)

The PSGR docs understood that obesity and Type 2 diabetes was a key risk factor, and they recognised the role of high carbohydrate and ultraprocessed food diet in exacerbating their patients risks. These doctors entered 2020 determined to keep their patients out of hospital. They understood the role of vitamin C, vitamin D, and zinc and they understood through years of practice – that preventing viral replication was key, preventing lower respiratory tract infection (LRTI) was key.

Therefore nutrients, antivirals, and if patients developed severe coronavirus, severe influenza or a severe cold – antibiotics to prevent bacterial pneumonia was key.

We all watched as the Ministry of Health failed to address these key risk factors, and indeed, suppressed and discounted them. I watched the policy language closely.

• Throughout 2020 all policy documents consistently deflected to the ‘safe and effective vaccine’ that would likely be released, creating a natural bureaucratic belief in this outcome.

• I understood from my master’s research that there was no scientific freedom to critique Ministry of Health claims.

• Ministry of Health expert advisory groups were not required to systematically survey the scientific literature.

• Doctors were not invited to critique, nor able to critique because the entire language was structured around a novel coronavirus that was meant to be unlike any other coronavirus in the history of the world. Therefore doctors experience of treating viral syndromes was entirely negated.

COVID-19 Papers & Writing

In 2022 I drafted 3 discussion papers to help shed light on how government officials failed to follow good process, and on the way, rode roughshod over democratic principles and human rights:

1. April 5, 2022. COVID-19 Emergency Powers: The New Zealand State, Medical Capture & the Role of Strategic Ignorance (2019-2022).

2. August 5, 2022. COVID-19 Emergency Powers: Some Notes on the Process of the Passing of Laws in the time of COVID-19 (2019-2022).

3. COVID-19 in New Zealand: Ethics & the Setting Aside of Normative Principles.

These 3 PDFs are embedded below and can be downloaded.

On my Substack I documented in detail policy processes that revealed how little respect officials had for accountability and transparency, and how doggedly determined officials were to follow the central narrative of injections, lockdowns, masking and distancing. Major articles:

• COVID-19 & the science. Deny, dismiss, divert & displace.

• Reframing Risk. Company style. Part I.

• Reframing Risk. RedFlagging it. Regulatory loopholes & Provisional Consent Part II.

• The Australian Sociological Association 2022 Conference paper presentation: Science for Whom?

Director Samantha Blanchard invited me to participate in the New Zealand documentary Silenced. I was invited to present at the NZDSOS conferences in 2022 and 2023.

I was invited to discuss my work on RCR. I was not contacted my legacy media, but had had years of attempting to broaden discussion on the risks of glyphosate, and by then, clearly understood that legacy media would not publish content that contradicted government policy.

What did Ministry of Health officials, or funded scientific communities not do? Review the scientific literature using methods-based scientific processes in an impartial manner. Consider risk by age and stage. Consider the long-term impact, whether by developmental stage, or the trauma of not saying goodbye at the end of life. Admit the hypocrisy of a mandate for a gene therapy that was never a vaccine (only labelled as one) that failed to prevent transmission. Acknowledge the terrible wrong of a biological drug that was designed to enter cells and instruct the body to produce unknown quantities of a known harmful protein for an unknown period of time, and that that biological drug had never undergone testing for mutagenicity and carcinogenicity even though the biologic would change cell function.

Bruning Discussion Paper 1 2022 04 05 Covid19 Emergency Powers April 2022 Final

2.63MB ∙ PDF file

Download

Download

Bruning Discussion Paper 2 2022 08 05 Notes On The Passing Of Laws Over Covid19 2020 2022

1.26MB ∙ PDF file

Download

Download

Bruning Discussion Paper 3 2022 10 18 Ethics And The Setting Aside Of Normative Principles Refs At End

366KB ∙ PDF file

Download

Download

We’ve got a fair bit of evidence to support the fact that this unconscionable, inhumane, military-like operation was taken with no consideration for democratic principles, for fairness and justice - and for the public good.

Keep talking everyone. This isn’t happening again.

And let’s re-find democracy, fairness and justice.

Much love.

Have officials and technical experts been ‘spoon fed’ with narrow information - or has an unbiased assessment of global regulations and risks, really been carried out?

For example: This statement is not correct: “New Zealand has lagged behind countries, including Australia, England, Canada and many European nations in allowing the use of this technology for the benefit of their people, and their economies.”

Are officials aware of the big issues still being considered in Europe? The European proposal for deregulation is still stuck in the Council. The Parliament wants labelling and traceability for all new GMOs. It’s unfinished business.

Europe traditionally has stricter rules and the precautionary principle is commonly taken into account. Precaution is still taken into account in the EU.

The question is - just how much does MBIE, the Hon Judith Collins and the technical advisory groups - really know? (We know that FSANZ has been selective in its disclosure of European decisions as well.)

For example: Have officials scrutinised the legislation in middle-high income smaller OECD nations for best practice to protect people, the environment and economies, or are official documents predominantly basing ‘lagged’ claims on weaker jurisdictions?

For example: What about their science claims around many new GMOs being comparatively the same as conventionally bred organisms (mammals, food crops, microbiota …) which would effectively write out case-by-case risk assessment?

For example: Historic examples from the most commonly planted GMO crops (globally) demonstrate how patents (and royalties) incentivise the consolidation of seed ownership. Over time, with mergers and buy-outs, a relatively small group of organisations control access to seeds. Non-GMO seeds may have distinct advantages such as drought tolerance and regional adaption decline, but if cross-breeding occurs, and the patented structure can be identified, the corporations will own that seed and/or demand royalty payments.

It’s all a bit whiffy. How robust is their evidence for the long-term benefit of people and economies - the science claims form the evidence, which forms the basis for the new legislation?

Without the capacity for people to contest the scientific and technical claims that form the basis of justification for new legislation, democracy is short circuited. Without rigorous processes that demand official impartiality in place, without mechanisms for public input when officials fail to take into account relevant scientific information (that might contradict their claims), officials can make science say whatever they want it to say.

That’s why I have made three Official Information Act requests.

There are important processes in place to prevent poor, unfair and inadequate legislation being produced - that is unfit for purpose. How can we understand if they are being followed if all the information is firewalled till the last minute - i.e. until the Bill is up for consultation (presumably over Christmas when everyone is distracted)?

Importantly: Should those policy papers that form the justification for a new Bill remain undisclosed until a Bill is released and consultation is opened up for public input?

What we have seen with other so-called scientific and/or technical controversies (see fluoride and COVID-19 Amendment Bill No.2), are panels being stuffed with peer reviewers who are not impartial, and the release of scientific papers which lack appropriately transparent and accountable protocols to ensure they are not biased. We see ‘stakeholder’ consultation on the quiet (Digital Identity Services Trust Framework Bill). This is democracy subverted.

Of course - the government position on the safety and efficacy of that technology underpins all the reasoning in the Bill that is released for comment).

… But the public cannot comment on the quality and comprehensiveness of the underlying scientific claims - because those concerns are outside the scope of the Bill.

The legislation is then passed because people did not speak to directly the content of the Bill. Is this a game that is being played - and you and I are out of it? I hope not.

3 OIA REQUESTS

1. MBIE - information sent to Technical Advisory Group: Gene Technology regulations and powers of regulator - Gene Technology regulations and powers of regulator

2. MBIE - All policy papers held by MBIE - includes discussion documents, regulatory impact analyses.

3. Hon Judith Collins - Policy papers held by Collins concerning the Gene Technology regulations. This is because Collins is the key Minister who is speaking publicly on the benefits of deregulation of GMOs into the New Zealand environment.

   ---

   Subscribe now

REQUEST 1 to MBIE- NOVEMBER 19, 2024

This request is to understand what the scientific and technical experts who are acting as consultants to MBIE know, and to understand whether they have capacity to look beyond MBIE’s selected and supplied data. Response due: December 17, 2024.

Re: Scientific advice - technical focus group - Gene Technology regulations and powers of regulator

https://fyi.org.nz/request/29246-scientific-advice-technical-focus-group-gene-technology-regulations-and-powers-of-regulator/

(Please note - all places where I state - focus group - should be interpreted to mean 'technical advisory group'. Apologies for the confusion).

Dear Ministry of Business, Innovation & Employment,

Sir Peter Gluckman (2011) has noted that ‘steps need to be taken early on to ensure that the scientific advice is:
• focused on the data and its appropriate interpretation;
• unbiased with respect to its use of data;
• open about what is known and not known;
• able to communicate in terms of probabilities and magnitude of effect;
• free from conflicts of interest, provided apolitically and independent of any particular end-user perspective.'
(OPMCSA, 2011, Towards better use of evidence in policy formation: a discussion paper).

The public have been told:
'A technical advisory group of 12 scientists and researchers will also support the Ministry of Business, Innovation and Employment on gene technology regulation procedures and technical matters, aiming to ensure officials' interpretation of the relevant science is accurate and risks and opportunities clearly understood.'
https://www.rnz.co.nz/news/political/524990/ban-on-genetic-modification-and-genetic-engineering-outside-lab-to-end-government-announces

'The Technical Advisory Group provides technical advice to MBIE on up-to-date gene technology regulation, including regulatory procedures and science and technical matters related to biotechnology, genetic techniques and gene therapies.

The Technical Advisory Group ensures that officials’ 'interpretation of relevant science is accurate, that opportunities and risks are clearly understood and that technical considerations are effectively incorporated into policy development.'
https://www.mbie.govt.nz/science-and-technology/science-and-innovation/agencies-policies-and-budget-initiatives/gene-technology-regulation

OIA REQUEST

[1] Please supply the terms of reference sent to the technical focus group. This is to confirm that there are systems in place to ensure that the information is free of bias and that there are protocols to ensure that the technical focus group have powers and resources to review and consider probabilities, risks, uncertainties and magnitude of likely impact outside the information sent to them by them, so that science advice is independently provided.

[2] Please supply all scientific information, including that which is listed in policy papers, including references and appendices, sent to the technical focus group.

This necessarily includes advice regarding the FSANZ proposals to change the definition of a GMO and remove process-based risk assessment. Obviously, the FSANZ outcome will impact the risk environment i.e. scientific and technical considerations of risk in relation to New Zealand’s native species and agricultural production and export. (Officials are aware the FSANZ work is in parallel with, and relevant to, MBIE's current consultation.)

[3] This question concerns the extent to which the technical focus group can consider uncertainty and future risks, and the extent to which MBIE have provided them with existing policy documents.

As science advisors, the technical advisory group will be considering future biosecurity risk, including genetic pollution. MBIE plans to create legislation which permits genetically edited organisms to be released into ecosystems (from a microbiomes, toto pasture, water-courses, and native forests) that with no boundaries, that are complex, linear and dynamic.

To quote Peter Gluckman ‘Precision is not the outcome, rather an assessment of probabilities’… There can be a danger of scientists claiming greater certainty than can be justified. Scientific advice must proceed through processes that are cognisant of, and act to limit, such potential distortions.’

New gene editing techniques such as CRISPR-Cas have accelerated development speed and shortened the bench-to-market timeline. Scientists are increasingly using artificial intelligence (AI) to identify development opportunities in whatever genome scientists want to work with – from mammals, to fish to insects and microbes. Gene editing can also be conducted in the outdoors, and removal of process-based risk assessment and potential exclusion of up to 94% of GMO foods as not GMO for the purposes of risk assessment (Bohle, Schneider, Mundorf et al 2024), not only will result in more development in New Zealand (including from offshore developers seeking permissive regulatory jurisdictions) but more releases in New Zealand.

(For references please see this document: https://psgr.org.nz/stewarding-biotechnology)

As the Royal Commission in 2001 advised, navigation over the longer term involves establishing principles and institutions to support the changing risk environment.
https://environment.govt.nz/assets/Publications/Files/Royal-Commission-on-GM-in-NZ-Final.pdf

Attorney General Judith Collins and MBIE allegedly desire to remove the precaution from the legislation and have not appeared to have taken the findings of the Royal Commission into account. There has been no policy paper reasoning considering the risks/benefits of insertion of precaution and/or precautionary principle in legislation text (or removal) would better serve New Zealand culturally, economically and environmentally. New Zealand is a signatory to the many treaties which also require consideration of the precautionary principle.

The technical advisory group must be interested in stewardship/kaitiakitanga over the longer term (see Boston, Bagnall and Barry, 2019, Joseph, 2021, Principles of the Treaty of Waitangi). For the regulator to have foresight and understand risk into the future - not just present risk, the technical advisory group may be considering former Parliamentary Commissioner for the Environment Jan Wrights' criteria:
- irreversible
- cumulative – building up over time
- large in scale or pervasive
- increasing or even accelerating in scale and/or distribution
- likely to tip a natural system over a threshold into another state

a. Please supply all meetings/memos/email discussions with the technical focus group with regards to how scientific uncertainty will be managed and how future risk from the scaling up of releases into the environment is scientifically, culturally and politically justifiable.

Please include all meetings/memos/email discussions with the technical focus group referencing precaution and/or the precautionary principle; and the findings of the Royal Commission and work by the Parliamentary Commissioner for the Environment.

Discussions around uncertainty and precaution may include the potential for gene edited organisms to have changes to the genome but not be classed as not-GMO as regulators class them as comparable to conventional bred organisms, and how uncertainties relating to risk and contamination in future has been scientifically assessed and communicated by the technical focus group.

b. The technical focus group will presumably be interested in there being sufficient regulatory powers to surveil and assess the changing risk environment, so as to protect health, the economy and the environment. Please supply all discussions with the technical focus group concerning proposed powers for the regulator.

This may include the potential powers to monitor the published scientific literature and surveil the global environment (for newly identified risks from off-target and unanticipated impacts from GMO development and release, regulatory changes, court decisions), and monitor and assess releases into the environment for the long term.

[4] Please supply 'up to date gene regulation' information on how regulations in the top performing OECD nations and the latest decisions by the European Parliament compare against Australia and the proposed hybrid regulations, that have been sent to the technical expert group for assessment.
For example: https://www.europarl.europa.eu/doceo/document/TA-9-2024-0325_EN.pdf

REQUEST 2 to MBIE - NOVEMBER 15, 2024

This request is to understand what policy papers have been produced. Of course, before a Bill can be drafted, policy papers must be published to identify risks and benefits, and stakeholders must have been consulted. Nothing has been released to the public, with the exception of a media pack. Response due: December 13, 2024.

RE: Policy papers: Gene Technology regulations

https://fyi.org.nz/request/29216-policy-papers-gene-technology-regulations

Dear Ministry of Business, Innovation & Employment,

Papers concerning the new Gene Technology regulations - no information appears to be released to the public as yet (November 15, 2024)

[1[ Please list all discussion documents supplied to MBIE, the date they were supplied, and which agency/authority/department supplied them.

[2] Please can I have a copy of all regulatory impact analyses held by your office.

[3] Please can I have a copy of any regulatory impact statements held by your office.

[4] All email discussions or memos of who may be 'affected persons'.

REQUEST 3 to HON JUDITH COLLINS - NOVEMBER 15, 2024

This request is to understand the extent and information that is held by the Hon Judith Collins on the Gene Technology regulations. Collins is not only Minister for Science, Innovation and Technology but the Attorney General and has been the key Minister discussing Gene Technology regulations in the media. It is not appropriate that this request is forwarded to MBIE, as Collins, as key media person, will be basing her media claims on the information that she personally holds.

Response due: December 13, 2024.

Re: Policy papers: Gene Technology regulations

https://fyi.org.nz/request/29214-policy-papers-gene-technology-regulations

To Judith Collins

(Hon Judith Collins KC MP, Attorney-General, Minister of Defence, Minister for Digitising Government, Minister Responsible for the GCSB, Minister Responsible for the NZSIS, Minister of Science, Innovation, & Technology, Minister for Space, and Lead Coordination Minister for the Government's Response to the Royal Commission's Report into the Terrorist Attack on the Christchurch Mosques.)

Please supply the following information held by your office (as Attorney-General and Minister of Science Innovation and technology) regarding the Gene Technology regulations which you have discussed in the media, and take an active interest in.:

[1[ Please list all discussion documents supplied to you, the date they were supplied, and which agency/authority/department supplied them.

[2] Please can I have a copy of all regulatory impact analyses held by your office.

[3] Please can I have a copy of any regulatory impact statements held by your office.

This request concerns information specifically held by you and how much information you have access to concerning these regulations. Please do not forward this OIA request to other authorities.

Share

Aseem Malhotra’s new film First Do No Pharm is documentary in style. The type of investigation one might have watched on 60 Minutes in the 1980s. Malhotra interviews patients, people who have been affected by drug harms, and high calibre experts with expertise on medicine and regulatory policy and process.

Cardiologist Malhotra was the darling of UK MSM prior to 2014 when he advocated for lifestyle including dietary interventions to prevent and reverse heart disease, in 2017 releasing the book The Pioppi Diet.

However, in 2014, the position on Malhotra shifted once he joined US doctor John Abramson to question the benefits of routine use of statins for heart disease and the potential misdirection (and here and here) of reducing cholesterol to combat heart disease. In 2019 the UK Mail on Sunday attacked Malhotra and colleagues as ‘statin deniers’ and purveyors of ‘fake news’. In June 2024 Judge Nicklin dismissed the Mail on Sunday’s public interest defence and found in favour of plaintiffs Zoe Harcombe and Malcolm Kendrick in what Nicklin described as ‘the most significant piece of defamation litigation’ that he had observed in a very long time. 

(That’s five years of work to reverse a public slur. No wonder academics are silent so often.)

Much of this documentary concerns the statin-as-case-study of what happens when academics, researchers and journals ‘go against the grain’ The challenges to not only advising patients about risks and benefits of drugs, but the challenges to career and reputation that doctors and scientists face when they criticise industry norms and claimed consensus on drug safety and efficacy.

My third-year sociology papers alerted me to the historic problems of medical fraud, medical influence and malfeasance, and iatrogenesis, and I’ve been interested since that time.

I HAVE A FEW QUESTIONS ABOUT FACEBOOK:

• Why is Facebook deleting the First Do No Pharm documentary on all continents when it is posted?

• Why have I not heard back from two review requests (am I looking in the wrong place)?

• I am now concerned that if I post again - if I repeatedly break Facebook’s rules, because I am supposedly going against their Community Standards on Spam - I likely face suspension from Facebook?

• Should I trust Facebook anymore? Is this happening to other friends and colleagues?

• This, let’s call it overreach, is even happening before (for example) new legislation is passed in Australia that would control Facebook content even more tightly.

I don’t think I am overstating it: If governments and regulators hold predetermined positions on the risk of the technologies that they regulate (which includes drugs and medical devices) - when governments stifle funding for research that could contradict their position on safety, when public media refuse to discuss controversies and slur those who question claims of safety and efficacy - we observe a machinery of government that is deploying policies in a style reminiscent of techno, or medical fascism.

Recently I discussed how Australian government agencies see the opportunity of proposed social media legislation which would enable the government to quickly clamp down on people who criticise the safety of cancer screening and 5G/EMF.

Who might identify harm should harm arise, when the state isn’t interested in identifying harm in the first place (i.e. the funding pathways to research risk pathways aren’t there)? But - Facebook is currently banning a documentary - does it need government help to overreach any further?

FACEBOOK REMOVED - & I HAVE APPEALED

Edit October 27, 2024.

Last night I posted this on my Facebook personal page and my Talking Risk page.

Guess what happened?

How dystopian. You can’t talk about talking about being banned.

Many people are reporting to me that this Substack is being pulled ‘in seconds’.

A HISTORY OF FRAUD & WRONGDOING

It’s increasingly difficult to publicly criticise the biological and pharmaceutical drug industry. This industry is rapacious, and inconvenient data has been hidden, ignored, misrepresented and dismissed in the past.

Eli Lily: In 2009 American pharmaceutical giant Eli Lilly and Company pled guilty and agreed to pay $1.415 billion for promoting its drug Zyprexa (olanzapine, an antipsychotic) for uses not approved by FDA. This included a criminal fine of $515 million, and $800 million in a civil settlement with the federal government and states.

Pfizer: In 2009 Pfizer and subsidiary company Pharmacia & Upjohn Company Inc pled guilty to a felony violation of the Food, Drug and Cosmetic Act for misbranding anti-inflammatory drug Bextra with the intent to defraud or mislead. ‘$2.3 billion, the largest health care fraud settlement in the history of the Department of Justice.’ Criminal fine of $1.3 billion. ‘In addition, Pfizer has agreed to pay $1 billion to resolve allegations under the civil False Claims Act that the company illegally promoted four drugs – Bextra; Geodon, an anti-psychotic drug; Zyvox, an antibiotic; and Lyrica, an anti-epileptic drug – and caused false claims to be submitted to government health care programs for uses that were not medically accepted indications and therefore not covered by those programs.

Purdue Pharma/Sackler Family: Misrepresented OxyContin as non-addictive and safe. Over-prescription then led to overdoses and addiction. $6 billion has been awarded to families. In August 2024, the FDA approved Purdue Pharma’s application for a ‘new auto-injector device used to reverse opioid overdoses’.

GlaxoSmithKline LLC (GSK): In 2012 pled guilty and agreed to pay $3 billion to resolve its criminal and civil liability arising from the company’s unlawful promotion of Paxil, Wellbutrin and Avandia.

GlaxoSmithKline LLC (GSK): October 2024, refused to admit wrongdoing but agreed to pay $3 billion to settle 80,000 lawsuits alleging that ranitidine (ingredient in Zantac) causes cancer when it degraded into the substance NDMA.

Court cases are commencing relating to the mRNA COVID-19 vaccines rollout (and suppression of information: Here, here, here.

Please note, while Malhotra published a book on immune health in 2020, and has written previously on the COVID-19 pandemic response, this is not a focus of the NoPharma film.

MANY PATHWAYS REINFORCE INDUSTRY INFLUENCE & POWER

Iatrogenesis - side effects from drugs, known as adverse drug reactions or ADRs, that have been prescribed by a doctor, and consumed as prescribed.

‘iatrogenic ailments are those where doctors, drugs, diagnostics, hospitals, and other medical institutions act as “pathogens” or “sickening agents.” … “Iatrogenesis is any noxious, unintended, and undesired effect of a drug, which occurs at doses used in humans for prophylaxis, diagnosis, or therapy.” … an ADR as … ‘an undesired effect of a medication that either increases toxicity, decreases desired therapeutic effect, or both. The WHO defined iatrogenesis does not give a clear picture of ADRs. This definition does not include in it the therapeutic failures, intentional and accidental poisoning, drug abuse, incorrect drug administration, and noncompliance. This definition also tends to underestimate ADRs and incidences such as diagnostic procedures which include mechanical and radiological procedures, the therapeutic regimen which includes drugs, surgery, and invasive procedures, hospitalization and treating doctor himself/herself is also not accounted for. That too can cause iatrogenic effects.’

Medical fraud can involve marketing violations such as fraudulent marketing and misbranding, billing fraud and kickbacks; medical research fraud including falsification and fabrication of data and plagiarism. Then there are problems research design (which can shape an answer to suit a purpose) and unfairness in funding.

Then there is the journal problem. Journals can be quick to publish research that might be dubious but that might reflect the interests of the advertisers. As Richard Smith discussed in Medical Journals Are an Extension of the Marketing Arm of Pharmaceutical Companies editors have struggled with this for decades.

A paywalled JAMA paper just out shows just how much peer reviewers for the 4 top medical journals have financial conflicts of interest:

Among nearly 2,000 physician peer reviewers at JAMA, the New England Journal of Medicine, The BMJ, and The Lancet, 58.9% received at least one industry payment during that period,

Medical influence can lead to biased outcomes with industry funders (sponsors) influencing

‘research outcomes, such as by affecting the portfolio’s scope, specific questions asked, experimental design, and choice of principal investigator (PI). It might also bias result reporting, analysis, dissemination, and communication and data availability, reanalysis, and replication.’

Then there is the problem of regulatory capture (discussed at length here in chapter 8). Regulators start to problematise in ways that more closely reflects the interests of the regulated industry. This is more than old school capture with regulators and institutional moving in an out of a so-called revolving door, it’s cultural capture. When fees form a large part of regulatory incomes, regulatory agencies can see their drug sponsors as institutions to service rather than regulate.

People face barriers to getting authorities to recognise harm. Unfortunately, when there are injuries, such as from vaccines and companies have immunity from law suits, harm may not be recognised by authorities, and people compensated, if the injury pathways haven’t been identified.

Then there is the moral and ethical failure to our children. More and more adolescents and children are prescribed drugs at younger ages, locking them into a medical treadmill. Adolescents and children are also subject to drug side effects, such as from antidepressants. They are vulnerable to medicalisation at an early age, for illnesses that could be addressed by remedying social determinants over time.

But it’s more than that, when we believe drugs will fix complex problems, when we don’t dedicate ourselves to addressing environmental drivers which include nutrition, toxicity, and stress, we harm not just ourselves but our children. In a recent book Marty Makary challenges us to look at the Blind Spots in modern medicine, the overuse of medicine, the root causes of disease, the opportunities to improve policy.

MEDICAL NEMESIS

If you’re interested in reading on, Ivan Illich’s classic 1974 book Medical Nemesis gives a language to the problem of medicalisation and pharma/biotech influence that is now 50 years old. Illich argued that environment was the primary driver of health and disease, and that medical dependence was more likely to expropriate health than drive health outcomes.

While improved sanitation, nutrition and antibiotics vastly improved health and reduced death from infectious disease epidemics, as the twentieth century wore on Illich stated, ‘the modern epidemics took over: coronary heart disease, emphysema, bronchitis, obesity, hypertension, cancer (especially of the lungs), arthritis, diabetes, and so-called mental disorders.’

Medicine stepped in as treatments (and promised cures) - but all too often the treatments came with side effects, and the primary drivers were not addressed - placing vulnerable people on a treadmill of medicine. Fifty years ago, Illich stated:

For more than a century, analysis of disease trends has shown that the environment is the primary determinant of the state of general health of any population. Medical geography, the history of diseases, medical anthropology, and the social history of attitudes towards illness have shown that food, water, and air, in correlation with the level of sociopolitical equality and the cultural mechanisms that make it possible to keep the population stable, play the decisive role in determining how healthy grown-ups feel and at what age adults tend to die. As the older causes of disease recede, a new kind of malnutrition is becoming the most rapidly expanding modern epidemic. One-third of humanity survives on a level of undernourishment which would formerly have been lethal, while more and more rich people absorb ever greater amounts of poisons and mutagens in their food.’

When it came to adverse drug events:

‘The pain, dysfunction, disability, and anguish resulting from technical medical intervention now rival the morbidity due to traffic and industrial accidents and even war-related activities, and make the impact of medicine one of the most rapidly spreading epidemics of our time. Among murderous institutional torts, only modern malnutrition injures more people than iatrogenic disease in its various manifestations.’[47]

[47] Martin S. Feldstein, "Hospital Cost Inflation: Study of Nonprofit Price Dynamics," American Economic Review 61 (December 1971): 853-76. For a complementary prediction of a further increase in capital-intensive medicine see Dale L. Hiestand, "Research into Manpower for Health Services," Milbank Memorial Fund Quarterly 44 (October 1966): 146-81

NB: How can families and friends get off the cycle of giving into addictive ultraprocessed food you don’t necessarily want to eat - knowing that it drives poorer metabolic and mental health? Hop over to or PSGR’s Spotify account to listen to interviews discussing how food addiction can be formally classified and treated.

Yes, I have watched the No Pharma film and I recommend it. Yes, I have met Malhotra after the 2023 NZDSOS conference when we were both speakers. I spent a short time with Malhotra discussing not only the impact of dietary changes on metabolic health but on mental health. Transcript of my talk on democracy, institutional failure & justice, available here. Malhotra’s talk was a version of this one.

Then there is the technique of conflating two circumstances to expand a rationale, in this case, expand powers. An Australian government department, as discussed below, is inferring that people who criticise cancer screening must be stopped because it will harm health outcomes. Likewise, they are inferring that people who criticise 5G and electromagnetic field (EMF) technology should be stopped because their actions could lead to cell tower damage.

Physical injury is a serious harm. The Australian government now wants to expand the concept of serious harm is identified as risk to cancer screening rates and telecoms utilities. Think about that.

MEDIA SILENCE - & COMPLICITY

Cancer screening and 5G are inferred to be safe and effective. But -

- pick your technology which the government claims is safe and effective, but where unwanted exposures by that technology is recognised by non-government actors is recognised as being risky -

There will be an absence of critical scrutiny in the mainstream (legacy) media of these technologies. Over time it becomes evident. People are not permitted to challenge the State’s position on the safety and efficacy of a given policy programme or regulated technology.

Mainstream media silence is a form of bias. The silence over time amounts to a particular form of censorship by omission. Over time the silence becomes a voice - sociologically it can be seen as an expression of economic and political power.

What I have found over the years, is that official soundbites about safety and efficacy can be easily covered in under 600 words. It’s black and white – good or bad. Rebutting simple soundbites takes longer. One must turn to reasoning and judgement. This always uses a higher word count than OpEds permit. Reasoning is grey, it’s more nuanced. It involves navigating complexity, uncertainty and ambiguity.

But without reasoning, civic language then shapes inward. (Reasoning guides rationality, not the other way round.) People can become polarised in their beliefs and as a population, we can lose capacity to debate controversies, (which almost always traverses uncertainty and risk.)

Precaution becomes a difficult concept to navigate, and ultimately, we become separated into ‘for’s and ‘anti’s’. Polarised.

With media abstaining from critiquing political policies that claim scientific authority by locking in a position affirming cost-benefit of a regulated activity, government institutions can craft policies that reflect the interests of subsets of stakeholders.

INSTITUTIONAL CLAIMS ARE THEN NOT CONTESTED

The institution (such as a government department or regulatory authority) can claim scientific legitimacy but refuse to engage with criticism, refuse to acknowledge risks that are scientifically plausible, and/or ignore multifactorial issues that might render the policy absurd or dangerous, particularly to children.

So often in modern society, people struggle to avoid technologies and keep babies and children away from particular exposures. Years of research into the developmental origins of health and disease confirms that early life exposures can promote illness over the life-course.

When risk is downplayed, small groups who try to get an issue addressed can be easily marginalised and ignored by the relevant government institution. The only recourse then, is independent media or the courts.

It is deeply ironic that government agencies now spend a lot of time developing legislation to ostensibly protect minority groups from language, but demonstrate scarce interest in taking account of risk to actual minors from the technologies where harm pathways are demonstrated in the scientific literature.

Then there is the narrative shaping through the selection of strategic ‘key stakeholders’ who are invited to participate in consultation in early policy development for new legislation. For example, PSGRNZ might be 25 years old, we might have submitted to an enormous range of policies over the decades, so we should be known. But PSGRNZ are never contacted… we can only dream!

But we see in manifold ways, - which can be observed in the Australian government Impact Analysis discussed below, that certain forms of understanding when toggled to a particular scientific authority, become ideologically entrenched. This is, of course, is abjectly antiscientific.

Scientific authority is the scaffolding that underpins an extraordinary range of policy.

But now the Australian government want to turn their beliefs into dogma.

AUSTRALIAN GOVERNMENT - HAPPY TO CENSOR SCIENTIFIC INFORMATION?

Communications Legislation Amendment (Combatting Misinformation and Disinformation) Bill 2024. This is a new iteration following public criticism of the 2023 version. The Sept 12, 2024 Media Release states:

The Bill empowers the ACMA to oversee digital platforms with new information gathering, record keeping, code registration and standard making powers.
 
It will also introduce new obligations on digital platforms to increase their transparency with Australian users about how they handle misinformation and disinformation on their services.
 
The Bill will complement voluntary industry codes but allow the ACMA to approve an enforceable industry code or make standards should industry self-regulation fail to address the threat posed by misinformation and disinformation.

The Department of Infrastructure, Transport, Regional Development, Communications and the Arts decided that they need to do an Impact Analysis. As they clarified on page 8, the Impact Analysis was really an Economic Analysis. Six serious harms were identified:

1. Electoral process: Harm to the operation or integrity of this process.

2. Health: Harm to health outcomes in Australia, including reductions in the effectiveness of preventative health programs

3. Hatred towards groups: vilification of groups or individuals.

4. Physical injury to individuals: Intentionally inflicted physical injury.

5. Critical infrastructure or emergency services: Damage to critical infrastructure or emergency services, including utilities, transport, police, fire, ambulance and border protection services.

6. Economic harm: Harm to sectors of the Australian economy, including harm to public confidence in the banking system or financial markets.

This Department believe that censorship reform is required because online chat might lead to the subset of social costs that they have identified. They do not consider social costs, or risks that might be borne if their beliefs are incorrect.

The September 2024 Online misinformation and disinformation reform - Impact Analysis by the Department of Infrastructure, Transport, Regional Development, Communications and the Arts provides two examples of how a form of scientific belief which infers a consensus position, becomes inserted into policy as a scientific fact, to justify why that policy or law should be made.

The examples suggest that new laws would prevent people - including expert communities – from contradicting the stated position of the efficacy or safety of two particular examples cited in this Impact Analysis.

If your online chat and shared information contradicts the governments’ position on regarding the safety 5G and electromagnetic energy, and safety and efficacy of cancer screening processes, the Impact Analysis frames this as market failure. To contradict the States position would be to promote misinformation and disinformation.

The Department of Infrastructure, Transport, Regional Development, Communications and the Arts Impact Analysis claims that the benefits or risks of 5G and cancer screenings are concrete, have presumed a locked in scientific fact. This is … ideological!

THE TAKEN-FOR-GRANTED SAFETY OF 5G

What this would mean in real time – people would most likely be censored if they attempted to post content that contradicted the states position on the safety of 5G and the efficacy and safety of cancer screenings.

Therefore, I can infer that if I was sharing a published scientific paper by Dr Priyanka Bandara and colleagues drawing attention to the increase in 5G small cell antennas, the beam formation characteristics that produce risky hotspots, and the problem with a regulatory process that exclusively looks at thermal risk and ignores non-thermal effects (known as non-ionizing electromagnetic fields) such as oxidative stress and risk to small children, I would be censored. It is taken for granted that 5G and EMF fields from cell towers are safe. I would be seen as encouraging vandalism.

Then - if people were protesting the erection of 5G towers and small cell antennas near homes and vulnerable areas such as schools, kindergartens and hospitals - from local to central government level to – these people would be incorrect in their approximation of risk. The government wouldn’t engage with their concerns, even if symptoms arose after installation.

People getting angry and sharing evidence would have to be censored. Because all too often, when people are being harmed, and they remain unheard, they become desperate.

I would be complicit.

I’d be similarly troublesome if I shared information criticising government guidelines; information showing how radiation density levels are increasing; an international appeal letter to Antonio Guterres, Secretary-General of the United Nations, U.S. National Toxicology Programme data, case reports on what is being called microwave syndrome after 5G base stations are erected nearby, risk evaluations of impacted organisms; or public releases by organisations seeking to share scientifically referenced information about risks that contradicts government regulatory guidelines and standards.

Effectively – I would be part of the problem – I could be inciting violence through sharing this information - and require censoring.

Because there is a risk that property would get vandalised.

CANCER SCREENING

I would have to be censored if I was sharing information that shed doubt on the efficacy of cancer screening, and raised questions about the costs.

Most likely I would not be able to share a post by Dr John Mandrola that notes that while screening does safe lives, he then goes on to state: ‘I would wager that if we showed people the actual data behind screening, a lot more would forgo it’.

·       Colonoscopy? Data from a NordICC trial where the risk of death from colorectal cancer after three years was not statistically different (0.28% vs 0.31%).

·       Cardiovascular screening? Data from the Danish cardiovascular screening (DANCAVAS) trial suggested limited benefit, and found that screening did not lead to a decrease in all-cause mortality.

Mandrola then links to an article by Dr Vinay Prasad, co-author of the paper Low-Dose Computed Tomographic Screening for Lung Cancer: Time to Implement or Unresolved Questions? The paper raises the question of all-cause mortality, which is all too often, statistically indistinguishably, and the much-ignored problem of the harms of screening, which not only include radiation risk but the burden following false positive outcomes, which then require multiple diagnostic follow-up procedures which can be invasive and costly.

I’d also probably be a bad actor if I was sharing information on the benefits of breast thermography screening, and criticised government policies that extended mammography to women in their 40’s.

I’d probably be accused of misinformation if I criticised the efficacy of general health checks.

MISINFORMATION LAWS - A CHILLING EFFECT ON RISK-BASED DISCOURSE

Positing a given scientific position and then locking in legislation to prevent debate is a terrible idea.

Misinformation and disinformation laws that suppress public dissent, inevitably contradicts long held administrative and constitutional law norms which require that officials are open-minded, even when issues are controversial.

Misinformation laws will protect dogmatic positions and promote an abuse of powers. We can see that the serious harms identified - contain enormous potential for political and legislative overreach.

Impartiality, accountability, trustworthiness arise when officials take into account the open-ended nature of risk and the role of principles and values in navigating the changing dynamics of risk knowledge. Trust is sustained by not holding predetermined positions on the safety and efficacy of the technologies that surround us. Regulation and stewardship overlap. In PSGRNZ’s propaganda white paper we stated:

Principles are important. These societally accepted value-based systems of belief act as rails to guide reasoning. Principles are inimical to reasoning and therefore judgement. Such as in judging who, how and why a child is at greater risk of harm from a particular exposure, or mix of exposures, than their parent.

But when authorities lock in a predetermined position and create barriers to hearing and evaluating contradictory information and it becomes dogma, we’re not only the poorer for it, there’s a real risk that the public - and particularly babies and children - will be harmed.

This is the place where pregnant mothers, infants and children sit when they are exposed to modern technologies that their ancestors were never exposed to, that might or might not harm. This is a grey area, because of developmental, genetic, epigenetic and biochemical (including nutritional uncertainties.

But when legacy media persistently excludes, and fails to encourage debate on these uncertainties, over time, this is tantamount to censorship.

Misinformation laws lead to overtly lead to censorship, and they also result in self-censorship, a chilling effect where people will not raise an issue for fear of being accused of misinformation.

·       Government institutions can make scientific claims without being accountable.

·       People will have technologies imposed upon them.

·       Some people may be harmed.

·       People have no recourse and get angry.

·       Governments then accuse them of misinformation and disinformation.

·       They can be fined or go to jail.

·       There is a lag on recognising risk and over time more people are harmed.

·       Public trust in governing bodies declines, and government agencies then must choose to be more accountable and trustworthy, or to use legislation to enforce rules without accountability to individual health concerns.

Subscribe now

An OpEd I wrote recently, languished, unpublished. In my email I simply stated that I hoped it would be published online, as I realise the challenge editors balancing content and advertising in limited newspaper space.

Yes, editorial discretion is important. But when does it become bias? We can’t really put a finger on it.

After a presentation to Tauranga City Councillors, where fluoride was the topic discussed, and the Bay of Plenty Times reported on some of the content. The BOP Times omitted all content that directly criticised current policy and explained why the current policy was deficient (presentation notes provided to Councillors and the Bay of Plenty Times reporter who attended). I thought it was timely to suggest an OpEd. It remained unpublished. They have discretion not to publish.

Perhaps my article is pathetic bullshit, and of no interest to Tauranga residents.

But without this information publicly published, Tauranga public will continue to believe that the science that the Director-General relies upon for the order is perfectly acceptable, they will not know that children’s urinary levels of fluoride are higher than adults, they will be unaware of consolidating knowledge, particularly around risk to kids under 8 years old, and likely will not shift their stance on the safety of fluoridated water.

This is the Op Ed sent to the BOP Times:

Media omissions fuel division on fluoride?

Jodie Bruning. Physicians and Scientists for Global Responsibility, New Zealand.

In a Tauranga City Council meeting last Monday, 26 August, Councillors voted to seek an extension to the fluoridation deadline imposed by the Director-General of Health.

While the media have reported on court outcomes, they have refrained from evaluating why the science on fluoride’s safety is so deeply contested. In that Monday meeting Councillor Marten Rozeboom, discussing an earlier proposal that sought introduction stated:

‘The issue I have (with Option 3) is it doesn’t allow the robust debate in the community of what we’ve heard this morning. The debate in our press is too one-sided. Obviously, our Ministry of Health has a quite one-sided approach to this debate. We need to put what we have heard this morning into the public arena. … everything that was heard this morning needs to be in the mainstream press tomorrow morning so the wider public can read it and follow it, and allow the democratic process.’

Rozeboom is correct. New Zealand media are yet to report on an important fluoride-related issue that Physicians and Scientists for Global Responsibility (PSGRNZ) have been working to raise attention to: For the science on fluoride’s safety to be scientifically robust and trustworthy, impartial scientists must show the methods by which the data was selected. This has never been done in New Zealand.

In 2023 PSGRNZ addressed both the Bay of Plenty Regional Council and Tauranga City Council on this subject. Yesterday’s coverage of the council meeting also ignored this policy gap, even though NZME had received the notes to the PowerPoint presentation.

The Director-General of Health has relied on 2014 and 2021 reviews by the Office of the Prime Minister’s Chief Science Adviser (OPMCSA) to claim scientific authority. The 2021 review was released one day after a supplementary order paper was released in 2021. The timing could not be more political.

Democratic convention requires that either medical treatments or hazardous substances released into humans and the environment, should undergo either trials to prove safety and efficacy, and/or risk assessment to understand risk-based issues relating to hazardous (toxic) substances.

Fluoride has been released into municipal water since the 1960’s, but risk assessment has never been undertaken. Local councils are well aware that it isn’t a medical grade drug that is added to municipal water, but a slurry called hydroxyfluorosilicic acid. That hasn’t been assessed for safety either.  

The general public, and indeed the courts, seem not to be aware that the scientific rationale used by the Director-General is unfit for policy. Policy formulation must follow conventions to sustain public trust. Policies that claim to be based on scientific evidence, must follow robust and transparent processes. Risk assessment, and drug trials are required for this purpose.

Risk assessment is designed to shed light how a medical drug or toxic substance may cause harm, i.e. be hazardous, and at what level of exposure that harm might occur. Particular attention must be paid to infants and young children with developing organs (including brains). Babies and young children consume more by body-weight, and when it comes to fluoride, they absorb up to 80% of fluoride ingested, into their bones. Adults do not.

Without impartial, trustworthy risk assessment we cannot really know what the balance of risk really is.

Globally, topical fluoride treatments are often advocated for, ‘given the optimal risk-benefit ratio’.

PSGRNZ submitted on fluoride’s risks, to government committees in 2017 and 2021. The 2017 Select Committee and the 2021 Inquiry Committee promptly dismissed public concerns because comments on the safety of fluoride were ‘beyond the subject matter of the bill’.

Four years later, in 2021, the committee did not comment on public concerns because the bill ‘had already been through a full select committee process’ (in 2017).

Fairness is a guiding principle of administrative law.

Following the 2021 Inquiry the government inserted section 116 into the Health Act 1956.

Section 116 carries a low evidence bar. The Director-General of Health merely has to consider a reduction in the prevalence and severity of tooth decay. An obligation to consider safety is not required.

Risk-benefit questions, whereby infants and children may be exposed to levels of fluoride that lower IQ, are not required to be weighted inside any claimed marginal reduction in caries prevalence. Nor is the ethical dilemma where socio-economic inequalities track with ultraprocessed food consumption, encouraging dental decay rates far beyond any claimed reduction. This is ignored.

Moral jeopardy is not a problem for the Director-General.

The courts are clearly fatigued by fluoride-related court cases. Following a judgement against a group seeking to halt the introduction of fluoride to the urban supply of Hastings, Judge La Hood, accepted the Director-General of Health and Attorney-General’s submission that ‘in reality the case reflected the special interests of their members’ and awarded costs to Hastings District Council and the Crown.

The interest shown in Tauranga City Council’s meeting, where so many people attended that people were sent out to the foyer, and where some 1,500 views of the meeting occurred in the forty-eight hours afterwards, is testament fluoride’s safety as a much broader public-interest issue than Judge La Hood suspects.

Fluoride is not an essential nutrient. Healthy teeth depend on a wide range of minerals and trace elements, and limited access to sugar sweetened beverages and ultraprocessed foods.

Poor diets high in ultraprocessed foods and sugar sweetened beverages not only drive tooth decay, but chronic disease, including obesity, diabetes, cancer and mental illness. It’s time the Ministry of Health woke up. But they don’t have to, if the media won’t challenge Ministry officials on what might be considered to be deficient science and inadequate policy formulation.

J.R. Bruning is a sociologist (B.Bus.Agribusiness; MA Sociology(Res)) based in the Bay of Plenty, New Zealand. Bruning is a trustee of Physicians and Scientists for Global Responsibility (PSGRNZ). Her primary research focus is on the relationship between governance, policy, and the production of scientific and technical knowledge for public good. Her Master’s thesis focussed on funding barriers which prevent scientists from researching the drivers of chronic illness. Other writing can be found on JRBruning.Substack.com and at TalkingRisk.NZ

END.

If the broad categories of NBT food are declared non-GMO because of the proposed ‘paradigm change in regulation’ NBTs will evade all labelling requirements.

Points I am making here:

1. FSANZ must provide: ‘adequate information to make informed choices’.

2. If NBT GMO ‘substantially equivalent’ to conventional food. No label needed.

3. AU/NZ joins a global push to exclude some NBTs from pre-market assessment.

4. Reports of NBT consultations fail to disclose weighting of public responses.

5. FSANZ used to recognise the value of process-based risk assessment.

6. FSANZ pivot to technical clarity, prioritising the demands of corporate sector.

7. Framing compares NBTs to conventional food but dismisses scalar development.

8. Reviews/assessments lead with conventional food equivalence - predetermination.

9. The public recognise NBTs as a category of GMO.

10. FSANZ ignores the evidence that consumers pay a premium for GMO-free food.

My conclusion - FSANZ would rather place a burden on consumers by forcing them to navigate around a ‘not knowing’, i.e. contradict FSANZ's legal obligation to support ‘informed choices’; than conduct pre-market safety process-based safety assessments (place the burden on industry) and require NBTs to be labelled.

1. FSANZ has a legal obligation: ‘provision of adequate information to make informed choices’.

The object (s.3) of the Food Standards Australia New Zealand Act 1991 - requires that FSANZ staff work to protect health and achieve 4 goals:

2. If Gene edited food is declared ‘substantially equivalent’ to conventionally bred food it won’t be labelled.

• If there is novel DNA or novel protein it will be declared a GMO.

But FSANZ claim that insertions, deletions and nulls segregants that don’t end up as novel DNA or novel proteins will be excluded - because … this also happens with conventional food.

But if the legislation changes to a rule that is based around this single functional outcome (has the corporation declared it to have novel DNA or novel protein?) the ‘rule’ (based on substantial equivalence of NBTs with conventional food) is locked in.

Current process-based, case-by-case regulation aims to judge risk as risk changes.

For example, if the ‘novel DNA/protein’ GMO definition got locked in the legislation - changing knowledge (e.g. that shows gene editing changes really are different from natural changes) would simply not have to be considered.

FSANZ proposes to also exempt the following, (even if a big fat biotech patent is slapped on it):

• Cell-cultured food: Food derived from animal cell lines grown in cell culture and then further processed to resemble traditional meat or seafood products.

• Food derived from null segregants: A GMO that lost the insertion. End effect after biotech scientists have segregated chromosomes or deleted insertions. ‘The implication is that ‘segregants’ have been rebuilt into organisms that are not genetically modified.’

• Food from grafted plants: where that part does not contain novel DNA or *novel protein.

• Food additives, processing aids and nutritive substances.

3. AU/NZ joins a global push to exclude some NBTs from pre-market assessment (and labelling).

‘New breeding techniques’ (NBTs) = ‘precision breeding techniques’ (PBTs in the UK) and ‘new genomic techniques’ (NGTs in Europe).

UK groups have protested that the UK policy-makers moved too quickly and didn’t listen to them.

In Europe the organisation tasked with assessing NGTs, ANSES, stated in 2023 that

‘certain potential risks appear repeatedly in these case studies’ and that ‘These include risks linked to unexpected changes in the composition of the plant, which could give rise to nutritional, allergenicity or toxicity problems, or medium- and long-term environmental risks, such as the risk of gene flow from edited plants to compatible wild or cultivated populations.’

Recently, the European Food Safety Authority (EFSA) an published a July 2024 opinion that NGT plants would be equivalent to conventionally bred plants.

Professor Michael Antoniou and Claire Robinson disagreed, stating that:

EFSA ignores scientific publications showing that NGTs can create mutations that are different from those arising naturally, from conventional breeding, or even from random mutagenesis breeding (where plant material is subjected to radiation or treatment with chemicals to induce mutations). Therefore, scientists have warned that the mutations arising from the application of NGTs can present very different and more serious risks compared with conventional or random mutagenesis breeding.

While deregulation serves the biotech revolution; and the dominant agri-food system players retailing FMCGs: shelf stable ultraprocessed foods and the ultra-refined and synthesised inputs, not all EU companies agree.

4. Reports of NBT consultations fail to disclose weighting of public responses.

FSANZ has conducted several consultations on ‘new breeding techniques’ (NBTs):

• February 2018. Consultation paper: Food derived using new breeding techniques

• August 2018. Preliminary report: Review of food derived using new breeding techniques – consultation outcomes

• December 2019. Final report: Review of food derived using new breeding techniques.

• October 2021. (1st call for submissions.) Safety assessment: full technical report. P1055 – Definitions for gene technology and new breeding techniques.

• November 2022. The Stakeholder Feedback Summary Report. Proposal P1055 – Definitions for gene technology and new breeding techniques.

And now this latest one, deadline Sept 10:

• July 2024. 2nd Call for submissions – Proposal P1055: Definitions for gene technology and new breeding technique.

FSANZ August 2018 Preliminary report: consultation outcomes, and the November 2022 Stakeholder Feedback summary failed to transparently disclose the weight of opinions of the public, corporate industry, biotech developer groups, and groups concerned with human and environmental health. Instead FSANZ stated ‘views are divided’ and ‘many submitters desire’ and a number of concerns’.

While FSANZ have a duty to ensure food is safe, trustworthy and people must have access to information so as to make an informed choice, FSANZ has not disclosed the balance of opinion following the questions.

5. FSANZ used to recognise the value of process-based risk assessment.

December 2019. Final report: Review of food derived using new breeding techniques.

FSANZ notes that process-based definitions for triggering pre-market approval of GM foods have been widely adopted around the world. In terms of their advantages, such definitions can provide a simple and clear way to signal the regulatory status of certain products and make regulations more predictable in terms of outcome 9 . Capturing products on the basis of the process used can also provide an effective mechanism to prevent regulatory gaps in coverage and ensure comprehensive risk assessments are applied equally to all products derived using a specific technology.

The main disadvantage of process-based definitions is that they can quickly become outdated and therefore require periodic review and potentially need amendment as technology changes. Also, because some NBTs can result in foods that are identical or equivalent to conventional foods, a further disadvantage of process-based definitions is that they can result in identical products being regulated differently.

The second paragraph is correct. But this equally applies to decisions where legislation locks in NBTs as not a GMO and not suitable for pre-market assessment because the regulator claims any risks are the same as in conventional food. But in time, the proposed legislation might age badly - scientists might find that gene edited food may have unintended changes from gene editing that differ from random mutations in conventionally bred food.

Risk assessment should not stand still, and regulators should look for new ways to target risk. Companies will only declare what is required. Without curiosity-driven research, risk may not be understood.

6. FSANZ pivot to technical clarity, prioritises the demands of corporate sector.

FSANZ has adopted a simplified proposal in the 2nd Call for submissions claiming that feedback following the 1st call for submissions that the proposed approach was ‘too complex’ (November 2022 The Stakeholder Feedback Summary Report).

The proposed definitions revolve around ease of use for biotechnology developers and applicants. Is FSANZ undermining section 3, Object of the Act??

We can ask if there is bias towards large corporate industries? The public are not privy to information that may suggest that particular industry sectors considered the approach too complex, while many groups considered that complexity, i.e. process based to understand the elements of hazard and risk was necessary.

7. NBTs are compared with conventional food. Scalability - a key element of risk is ignored.

FSANZ is considering whether pre-market safety assessments are ‘justified in terms of risk’. However, their interpretation of risk when it concerns a single functional outcome, and declare equivalent risk in conventional breeds, is narrowly framed and patently disingenuous.

FSANZ in August 2018 stated:

key questions for FSANZ are whether the definitions in the Code remain fit for purpose, given the rapid pace of technological change, and whether requiring a pre-market safety assessment for foods derived from NBTs is justified in terms of risk.

Yet as I have stated, FSANZ appear unconcerned with:

‘the scale and pace with which NBTs can be developed in the laboratory and deployed into the environment, including into human bodies. It is important to understand scale and pace because risk assessment must not only identify hazards, the potential of an organism to cause harm to human health and/or the environment; but must concern itself with risk, the likelihood of a harm to occur and the severity of the estimated damage. … And what of scale gearing? Risk must be considered along the entire technological trajectory.’

The Centre for Integrated Research in Biosafety, University of Canterbury’s 2021 submission was quoted by FSANZ in the November 2022 Stakeholder Report:

‘Conventional breeding is limited by the spontaneous mutation rate, generation time of the organism, species, size of the organism, power of applicable intellectual property rights instruments, and number of breeders. NBTs have far fewer limitations. Their difference in radicalism and pace is, after all, why they have value and concomitantly how they can cause harm.’

The November 2022 The Stakeholder Feedback Summary Report reveals how FSANZ circled around concerns about the scale and pace of development, failing to evaluate the merit in the concerns. Again, FSANZ preferred to simply contrast some submitters concerns against others claims that there is no risk and not evaluate the context of assertions.

Biotech development as scaled up, incentivised by the relative ease and lower barriers to use with new gene editing tools. FSANZ have not attempted to recognise the potential increase in risk when both laboratory development, and release into human bodies and the environment is scaled up, which may be amplified should NBTs evade being declared a GMO.

The October 2021 Safety assessment reveals how FSANZ continues to persistently frame discussion regarding off-target risk by directing the reader to examples of the equivalent risks occurring with natural breeding.

8. FSANZ habitually deflects concerns citing ‘substantial equivalence’ with conventional food.

In a recent webinar FSANZ staff drew on the 2019 review as central to their belief that NBTs are equivalent to conventional food, unless they produce a novel DNA or a novel protein.

The Final report: Review of food derived using new breeding techniques - where (p.17)

The comparison focussed on the presence of foreign DNA in the final organism used for food as well as the potential for novel characteristics to be present in derived food products. A food characteristic is considered novel if it has not previously been present in a conventional food, or if it has been altered and now falls outside the documented biological range for conventional food.

Off-target and unintentional changes are discussed in the October 2021 Safety assessment. Somewhat misleadingly, FSANZ leads with a discussion on changes that occur in conventional food (part 2), before discussing the potential for this to occur in genome editing (part 3). The section on Food derived using new breeding techniques repeatedly emphasises the equivalence of NBTs with conventional food.

The language strongly suggests that FSANZ has crafted the text of the 2024 consultation to persuade the public to agree with their position that the end-point of a novel DNA/protein must be the only characteristic to declare a GMO - a GMO.

It’s evidence FSANZ’s top level priority in this submission is to arrive at a definition that is ‘not complex’ but is clear and objective, easy to comply with and enforce, and consistent.

9. The public recognise NBTs as a category of GMO.

2022 Survey:

‘general consumers do not conceptually separate NBTs from other genetic technologies’

10. FSANZ ignores the evidence that consumers pay a premium for GMO-free food.

Consumers globally prefer to pay a premium for GMO-free. Historically, food fraud, adulteration and contamination has been a major challenge at the consumer and regulatory level. Parents of infants and young children pay most attention to ingredient labels. But by relegating many ingredients to not being declared, people must then search specifically for GMO-free labels. Biotech developers and agri-food corporations have less onerous obligations - with the burden being placed on the consumer.

Globally there is strong evidence people will choose to avoid GMO food and pay a price premiums for non-GMOs. Much of the literature involves researchers researching the willingness to pay for GMOs and identifying strategies to reduce barriers to negative perceptions of GMO food. This may reflect funding parameters.

FSANZ assessment of Costs and Benefits consider none of these issues and the so-called benefits are unproven and hypothetical:

‘because new technologies, such as NBTs, although not widely available, could be useful tools that may contribute to more sustainable food production, climate change resilience and mitigation, cheaper food and innovative food products which benefit the food and agriculture sectors, where eventually consumers will benefit from these products of innovation (Brookes & Barfoot 2020; Qaim 2020; Kovak et al. 2022).’

The claim of ‘cheaper, higher quality and new food products’ has not been demonstrated in the USA, the most deregulated country with the highest level of GMO plantings. GMO’s targeted for food use in the USA is commonly used as stockfeed and as refined ingredients in ultraprocessed foods.

Real-world results reveal common aversion to GMO including gene edited foods.

People observe gene edited (NBT) foods in a continuum of foods modified using earlier technologies and would choose not to eat them, but would choose not to eat them less than foods modified with older technologies. Researchers often conclude that while people’s preference is values based, with more education and different language, particularly that emphasises nutrition, that gene edited food may become more acceptable. Language centres around potential nutritional benefits and educating people, for example:

it is important to enhance purchase intention by delivering information about genome editing technology and its benefits

Consumer preferences - Snapshot of recent studies:

Australia. (2022) P1055 – Consumer Survey Report Consumers’ perceptions of and attitudes towards genetically modified foods. FSANZ

China. David L. Ortega, Wen Lin, Patrick S. Ward, (2022) Consumer acceptance of gene-edited food products in China, Food Quality and Preference. doi: 10.1016/j.foodqual.2021.104374.

France and USA. Stéphan Marette, Anne-Célia Disdier, John C. Beghin, A comparison of EU and US consumers’ willingness to pay for gene-edited food: Evidence from apples, Appetite, doi:10.1016/j.appet.2020.105064.

Japan. Akihiro Mine, Sawako Okamoto, Tomoya Myojin, Miki Hamada, Tomoaki Imamura. (2023) Willingness of Japanese people in their 20s, 30s and 40s to pay for genetically modified foods (Preprint). doi: 10.1101/2023.10.29.564581

Russia. Anthony R. Delmond, Jill J. McCluskey, Mirzobobo Yormirzoev, Maria A. Rogova, (2018) Russian consumer willingness to pay for genetically modified food, Food Policy, doi: 10.1016/j.foodpol.2018.02.004.

Vietnam. Tong, Yen Dan Khuu, Dong Toan, Truong Duc Nguyen, Phuong Duy Pham, Nhai (2021) Consumer Responses Towards Non-GM Food: Evidence From Experimental Auctions In Vietnam. International Journal of Food and Agricultural Economics. doi: 10.22004/ag.econ.316274

Koralesky KE, Sirovica LV, Hendricks J, Mills KE,von Keyserlingk MAG,Weary DM (2023) Social acceptance of genetic engineering technology. PLoSONE 18(8):e0290070. doi:10.1371/journal.pone.0290070

One of the biggest barriers to consumer trust is the absence of independent funding for scientists, at a distance from the institutions who develop GMOs, who might independently research new knowledge of risk and advance knowledge on human biology and exposure to genetically modified foods.

Because right now the data supported by industry and by research institutions with problematic financial ties and conflicts of interest, predominantly controls the scientific information that is produced.

In effect there is no scientific freedom to conduct long-term research adverse outcomes from GMO foods in western countries.

In the meantime, consumers are right to be cautious.

• @PSGRNZ: recent podcast discussing the consultation.

• GE Free NZ: submission template.

• Organics Aotearoa: P1055 information.

• BioGro: Information on P1055.

• Organic and Regenerative Investment Co-operative: Information, survey and template.

• Biotechnology - Risk that scales up as efficiency increases. Heinemann on risk management & policy.

Topic: TCC Ordinary Council Meeting.

Presentation of Report: Fluoridation of Tauranga city's water supply. File Number: A16415420. Link to August 26 meeting.

Council to vote on: Fluoridation of Tauranga’s water supply.

Elected members voted to seek an extension to defer the fluoridation of Tauranga’s water supply (see NZH coverage here).

It’s evident that the Director-General (D-G) of Health’s orders to fluoridate water has flustered council management and elected officials across New Zealand- because of the extraordinary fines that the Director-General might or might not impose.

(To get a handle on fluoridation-related decision-making: PSGRNZ Fluoride Timeline.)

During the TCC meeting legal opinion by staff seemed focussed solely on the D-G’s order and the prospective fines.

Which begs the question:

Has the Council in our biggest city asked their Council-paid lawyers this very question?

Hence today’s Official Information Act request.

To Auckland Council

Subject: Official Information request - Fluoride - legal advice received by Council does S116E undermine and contradict other relevant legislation?

Dear Auckland Council,

Please note: Joseph on Constitutional and Administrative Law (5th Edition) (2021)

10.8 Obedience to convention: Every primary rule of obligation, including conventions, risks being flouted from time to time. Politicians will be guided by their political instincts and may weigh up the advantages of breaching a convention and risk the political consequences.

Politicians may seek refuge in the uncertainty of conventional rules and stand their ground. It may be disputed whether a convention exists, or what obligation it prescribes, or whether an agreed convention is applicable.

23.2.3: The duty to weigh mandatory statutory considerations extends to facts so relevant that Parliament would have intended them to be taken into account. Decision-makers cannot accord appropriate weight to contesting considerations without being in receipt of the relevant facts.

Public concerns reflect, following Joseph (2021), the fact that formal risk assessment, and medical drug trials are administrative law conventions where robust methodological processes must be followed; which promote trust in regulatory authorities; - may have been set aside with respect to fluoride's potential toxicity.

PSGR are concerned that a departure outside convention, for example, the failure of officials to follow good process, robust, trusted, methodological processes required in science and in the assessment of scientific information, may

1. Promote a breakdown in public trust of authorities, specifically, the Ministry of Health;

2. Deter and limit the capacity for officials to identify harm before it occurs;

3. Create alarming precedents for over-enthusiastic officials who may be unaware of the convention of risk assessment in the assessment of medical drugs (used for therapeutic purposes) and hazardous substances (emitted into human bodies and the environment).

The public have never been granted the opportunity to debate the Director-General of Health's claims that the Office of the Prime Minister's Chief Science Adviser's reviews of fluoride (2014 and 2021), are scientifically valid and fit for purpose as a policy document to permit mandatory fluoridation.

Judges appear to have not 'twigged' that without a robust and transparent methodological process to assess the available science, reviews by officials must be considered as politically dubious, and cannot be asserted as scientifically valid for policy purposes. I.e. as a 'single source of truth'.

Please note that the third document cited by the D-G, a Cochrane study (2015), was rigorous, but was not a review of the literature of the safety of fluoride, as the only risk factor considered was fluorosis.

Please note that neither the public, nor relevant scientific experts have been permitted to formally respond to the OPMCSA 2014 and 2021 papers. In 2017 the Select Committee declared that public input on safety of fluoride was out of scope of the consultation, and later in the 2021 Inquiry, the Inquiry Committee then stated that the science had been settled in the 2017 process.

Links to fluoride decisions, including committee documents are available on this page:

Science, Stewardship & Scalability. PSGR New Zealand.

Fluoride Timeline - New Zealand Decisions & Key International Findings.

We’ve just updated PSGRNZ’s Fluoride Timeline (PDF) to take account of this August 2024 release by the U.S. National Toxicology Program…

Read more

2 years ago · 6 likes · PSGRNZ

The public are increasingly concerned that local authority officials may risk limiting their consideration relating to fluoridation of drinking water to orders under s116 in the Health Act (1956) to the exclusion of other legislation that this newly inserted s116E may unfortunately undermine or contradict.

Please advise on which dates Auckland Council have sought legal advice, and received a response on the following issues:

1.The Health Act 1956 requires that Auckland Council protect health. s.116E of the Health Act requires that you fluoridate municipal water:

a. Legal opinion on protecting health, if under the S.116 purpose, or s.116E there is no clause requiring that the Director-General of Health must consider the safety of fluoridated water, either into human bodies or the environment.

b. Legal opinion on the authority of the OPMCSA reviews (2014, 2021), should judicial review take into account the absence of risk assessment undertaken, with the dilemma that the only claimed scientific opinion are these OPMCSA reviews where the authors did not include a methodology and transparent process to review, assess and update the quality of information relating to the hazard and risk of fluoride. Not limiting such an assessment to potential IQ loss in young children under 8 years, but including other risks including dental fluorosis, skeletal fluorosis, paediatric arthritis and other neurodevelopment and cognitive risks.

c. Legal opinion on the precedent that the OPMCSA reviews potential establish with regards to an absent to risk assess future medical treatments in drinking water, the absence of consideration of the full compound hydroxyfluorosilic acid, and hazardous chemicals that are released into municipal water and into the environment.

d. Legal opinion on the authority of the recent NTP monograph on cognitive neurodevelopmental risk to young children exposed to fluoride. Where NTP toxicological assessments are recognised globally as an authoritative source of scientifically valid information, and where domestic regulatory agencies themselves have not conducted such a review.
NTP Monograph on the State of the Science Concerning Fluoride Exposure and Neurodevelopment and Cognition: A Systematic Review. NTP Monograph 08. National Toxicology Program Public Health Service U.S. Department of Health and Human Services.

e. Legal opinion on risks and benefits to health as s116E requires the Director-General of Health to consider financial cost and savings of adding fluoride - but does not require the D-G to balance or weight a claimed reduction in dental caries with potential adverse health outcomes which may include but is not limited to the following, a reduction in IQ, dental fluorosis, skeletal fluorosis, paediatric fractures and osteoarthritis. Legal opinion on whether this s116E does in fact undermine the purpose of the Health Act as does not appear to require officials to consider health-based trade-offs.

f. Legal opinion on the dilemma that only fluoride is required to be added, but it is not medical grade fluoride that is added, but a slurry, hydroxyfluorosilicic acid.

2. Legal opinion on whether the s116E may contradict or remove the capacity for officials to take the Local Government Act 2002 into account as they are acting directly under the orders of the Director-General of Health?

s125(f)- TA must ‘identify and assess any other public health risks relating to the drinking water services supplied to the community’

3. Legal opinion on whether the s116E may contradict or remove the capacity for officials to take the Water Services Act 2021 into account with respect to the fact that 'other causes' could lead to higher exposures that might impair the IQ of young children, and harm people on dialysis machines. s116E may lead to officials setting aside obligations under Water Services Act s.7(1) orders of the Director-General of Health?:

Water Service Act - s.7 (1) Meaning of safe in relation to drinking water means drinking water that is unlikely to cause a serious risk of death, injury or illness,-
Immediately or over time; and/or - whether or not the serious risk is caused by (ii) other causes together with the consumption or use of drinking water.

Specifically - legal opinion on whether 'other causes together' may include:
a. Issue of children having higher urinary fluoride levels than adults.
‘t Mannetje A, Coakley J, Douwes J. (2018) Report of the Biological Monitoring of Selected Chemicals of Concern. Results of the New Zealand biological monitoring programme, 2014-2016. Technical Report 2017-1. March. Centre for Public Health Research (CPHR). Massey University. Wellington.
b. Toothpaste exposures.
c. History of MAV exceedance, even remote possibility that this might happen.

And legal opinion on whether precaution should be taken into account under the Water Services Act (2021) with regards to the potential risk to very young children.

4. Legal opinion on whether risk assessment, and the requirement that hazardous substances and medical drugs undergo trials to assess risks to health by age and bodyweight, using rigorous methods to assess risk to health by age and bodyweight, are conventions that promote trust in regulatory decision-making, and whether the Ministry of Health ignoring such a convention is appropriate in a constitutional monarchy and parliamentary democracy.

5. Legal opinion the legality of the New Zealand Environmental Protection Authority failing to conduct risk assessment of fluoride and hydroxyfluorosilicic acid for 40 years, and also failing to assess emissions from wastewater treatment plants into receiving environments for 40 years.

Increasing numbers of the New Zealand public are concerned that officials may not be taking steps to understand the safety of fluoride under the full extent of their powers, and that a newly added s116 may be undermining existing responsibilities under different laws, including acting to undermine the greater purpose of the Health Act (1956), as there is not capacity in that legislation, and hence no obligation, for officials to balance competing health-based risks in an appropriate, scientifically and methodologically rigorous manner.

Yours faithfully,

J Bruning.

Share

Subscribe now