For a government that has proclaimed itself the most open and transparent ever, sometimes it just doesn’t score that well on either count. Take, as an example, the centrepiece of New Zealand immigration policy – itself one of the key discretionary tools of economic/social policy – the New Zealand Residence Programme.
On Friday someone overseas sent me a copy of the latest Immigration New Zealand Policy Amendment Circular, issued on 30 April. As INZ describes it
We regularly review and update the Operational Manual. We publish these as Amendment Circulars. We publish the circulars when the changes have been approved and incorporate them into the Operational Manual on the day they come into force.
Second on the list of changes in the 30 April circular was this
New Zealand Residence Programme (NZRP) planning range
R6.1 New Zealand Residence Programme
R6.5 Allocation of places within the New Zealand Residence Programme
The NZRP planning range, which sets the upper and lower number for resident visa approvals, has been updated to 50,000 to 60,000 from 1 July 2018 to 31 December 2019.
That was both interesting and a little puzzling. Puzzling because the new circular was issued on 30 April, already more than halfway through the period from 1 July 2018 to 31 December 2019. And substantively interesting because the new target (“planning range”) was substantially lower than the previous target. In annualised terms the previous target had been 42500 to 47500 approvals per annum and this new target was the equivalent of 33333 to 40000 per annum. It was (is) by far the largest change in the planning range this century (until 2016 the planning range had been unchanged at 45000 to 50000 per annum for a long time).
Here is a chart of annual residence approvals going back 20 years
As I’ve highlighted in a couple of posts in recent months, it is striking how substantially the number of residence approvals has fallen (a fall well underway before the change of government). MBIE only publish monthly data for the last decade or so, and so here is a similar graph for that period but this time showing twelve month running totals of residence approvals, the last observation being the year to March 2019.
Annual approvals in the last 12 months have been lower than at any time since 1999/00.
Broadly speaking, operational policy is supposed to adjust to keep overall total approvals within the planning range (most obviously by varying the points threshold applicants have to meet). In this case, however, it appears that the target has been adjusted into line with the actual reduced number of approvals. That, surely, was somewhat newsworthy, especially given the debate at election time on what the various parties (Labour and New Zealand First) were and weren’t promising around immigration.
The open and transparent government was true to its word to some extent. When I went looking I stumbled on the Cabinet paper that was the basis for the decision. That Cabinet paper had been released onto the MBIE website on 19 February. Here is a copy of the paper itself cabinet-paper-new-zealand-residence-programme 2019
The Minister of Immigration appears to have intended that openness and transparency would prevail. Among the recommendations in the paper were these
58 Subject to Cabinet’s agreement to these changes, I intend to issue a press release announcing the details of the proposals in this paper.
59 I intend to proactively release a copy of this Cabinet paper under the Official Information Act 1982, with appropriate redactions, at the same time that I issue a press release announcing the details of these changes.
But I had a look at Iain Lees-Galloway’s page on the Beehive website. There was nothing there.
So I went to the MBIE website (always something of a dog’s breakfast) and looked for any releases in February. There was nothing there (or for March or April).
I checked Immigration New Zealand’s news releases page. There was nothing there either.
But, as I kept digging, I did at last find something. INZ has an email newsletter, called Korero, aimed specifically at immigration advisers
Kōrero is the Immigration New Zealand adviser-specific newsletter sent out as an email. Available every two months, Kōrero brings to you the latest news and information that affects you in your dealings with Immigration New Zealand.
And the February issue of this newsletter did contain the news about the residence programme.
It looks a lot as though Cabinet really didn’t like the idea of letting the general public know that they had been changing immigration policy.
But what of the substance of the policy?
In some respects, what the Cabinet paper is proposing – and was apparently adopted – is quite sensible. The residence approvals programme planning range has always been an odd beast, because it encompasses all sorts of streams under which approvals can be made, each set up for a variety of different motivations. And whereas when the residence programme was set up most approvals were granted to people offshore (and thus approvals regulated the number of non-citizens entering New Zealand to live), these days most approvals are granted to people already here (eg on temporary work visas, so that the overall planning range, at least on an annual or biennial basis, doesn’t even serve as much of a check on (for example) short-term pressures on housing or infrastructure.
Recognising all this, the government has apparently agreed that from 1 January 2020 each of the streams will be managed (or not) individually, rather than within an overarching planning range. The residence programme includes, for example, non-citizen spouses (in particular) and children of New Zealanders. We are never going to cap those flows, and management will mostly just consist of the tests to ensure that the relevant relationships are genuine. And, on the other hand, if we think that (say) granting 15000 skilled migrants a year residence is sensible that is a decision that probably shouldn’t be materially influenced by how many New Zealanders bring back foreign spouses in any particular year.
On paper all that sounds sensible enough. But, as so often, details can matter, and at present there are none. There is nothing in the Cabinet paper giving a hint as to how many residence approvals in total (or by stream) Cabinet expects to be agreeing to for the coming years. There is also nothing in the Cabinet paper evaluating, or reporting other evaluations, of the economic and social impact (benefits and costs) of the immigration programme to now – it seems to be a typical MBIE document in which the benefits are more or less taken for granted. The exception perhaps is this line (emphasis added)
In response to an overall trend of decreasing skill levels and remuneration amongst skilled migrant residence approvals, the previous Government tightened the requirements for the Skilled Migrant Category (ie the points system) and lifted the points level at which applications could be selected.
But even then there is no attempt to assess, or describe, the impact of those changes (or other changes which went in the opposite direction – more points for regional jobs), and thus no attempt to assess why residence approvals have dropped off so sharply, despite reasonably good labour market conditions at present.
The other substantive part of the paper was a recommendation to change the objectives of the Residence Programme. The paper reports that
The current objectives for the NZRP were agreed by Cabinet in 2001 and reflect an immigration context that was different from today. The existing objectives are:
24.1 Regulating the flow of foreign nationals wanting to come to New Zealand;
24.2 Prioritising among would-be migrants and avoiding the free flow from demand-driven immigration;
24.3 Trying to produce benefits to New Zealanders; and
24.4 Consistency and stability (market signalling around the number of residence places available in any particular year).
I was struck by the rather weak third objective (“trying to” produce benefits to New Zealanders – very different from the upbeat MBIE rhetoric of a few years ago in which immigration was a “critical economic enabler” for New Zealand). That list of objectives is very process-focused, and perhaps not unreasonable on its own term, but it provides no guide at all to ministers in actually setting the residence approvals planning range numbers.
The paper goes on to report that
The Government’s vision for immigration has changed and become broader. We intend to improve the wellbeing and living standards of New Zealanders, including through productive, sustainable and inclusive economic growth, by:
25.1 improving New Zealand’s labour market outcomes, including by filling skills and labour shortages and raising overall skill levels;
25.2 encouraging investment and supporting innovation and exports;
25.3 supporting foreign relations objectives and New Zealand’s international and humanitarian commitments;
25.4 supporting social inclusion, including through family reunification; and
25.5 protecting the security of New Zealanders and the border.
To better align the NZRP to this vision and focus on how to achieve it, I propose the following, equally weighted new objectives for the NZRP:
26.1 To maximise the contribution of the NZRP to the economic and social wellbeing of New Zealand and New Zealanders by:
– attracting skilled workers and business migrants;
– reunifying the families of New Zealand residents and citizens; and
– meeting international and humanitarian commitments.
26.2 To manage overall residence numbers through controlling each of the individual components of the programme.
I’m pleased to see that the focus is clearly on benefits to New Zealand and New Zealanders, but there is still no sign that they have any idea at all how “attracting skilled workers and business migrants” is going to benefit New Zealanders in future when it hasn’t in the last 20 years (on their own metrics, immigrant skills levels are on average lower than those of natives, exports have been falling as a share of GDP, and business investment has remained weak).
Which brings us back to the target numbers, and the reduced “planning range” for the current period. There is simply no explanation for why the government has chosen such a substantial reduction in the planning range, except – and they more or less say this – that it brings the target into line with forecast actuals. But “forecast actuals” are a response to things including the rules of the scheme (eg the points granted and points thresholds). It doesn’t have the ring of a particularly coherent policy.
Moreover, it is worth noting – the Cabinet paper does – that when the planning range was last approved around 60 per cent of visas were supposed to be for people in the business/skilled stream (principal applicants and their dependents). 60 per cent of 45000 would be 27000 annual approvals under the skilled/business streams (those which, as the paper itself claims, offer the greatest economic benefit). But on the revised policy now in place only 51 per cent of the approvals are allocated to the business/skilled stream: 18700 per annum. In other words, a 30 per cent cut in the number of skilled/business approvals.
Here are actual (12 month running totals) approvals under that stream.
In that sense, the new (temporary) policy simply adjusts the target to reflect the very substantial reduction in the number of actual approvals (again, to the lowest level seen since 1999/00).
My overall take?
- I support, conditional on seeing details, a move to managing individual streams individually (so long as it isn’t a mechanism to obscure overall actual immigration policy),
- I favour a substantial and permanent cut in the overall number of residence approvals granted, focused first on the (non-refugee) categories where there is no skill requirement, but also on the skilled/business side where (as MBIE themselves note) skill levels just haven’t been that high. Doing so would be likely to enhance New Zealand’s medium-term economic performance. The reduced target the government has adopted, if persisted with, looks to be a step in the right direction, but there is no indication as to whether they will persist with it,
- but I also strongly support open government, and don’t like the idea of substantial reductions in the residence approvals targets being done on the sly, with no consultation and an (apparent) attempt to minimise the visibility of the change,
- on which note, I hope that the government is planning some proper public consultation (not just, say, with business lobby groups) about the details of the new scheme, including the guidelines they will be adopting to manage the inflows of each of the individual streams and the overall number of residence approvals granted. Lack of transparency can hardly ever be defended when it comes to the design of major instruments of economic and social policy.