6 August 2010

The Chair
Education Select Committee
Parliament Buildings
Wellington.

Dear Sir,

Education Amendment Bill (No 2) – Submission

The Early Childhood Council is pleased to submit our views on this draft amendment
bill.
Our response concerns one policy focus of the draft bill, being the proposal to
“exempt limited attendance centres from early childhood education licensing
standards to make it easier for recreation facilities, shopping centres and similar
organisations to provide short-term childcare”.
In summary, while we support the intent to distinguish between early childhood
education (ECE) services and those shorter-term crèche-type services provided by
recreation facilities, shopping centres and similar organisations, we are concerned
about the following factors:
1. The robustness of the criteria proposed to distinguish between ECE services
and crèche services, and the risk that the distinction proposes, may allow
some services to avoid the responsibilities established under the ECE
licensing regime. How will this be managed?
We advocate that the provision of quality education services by licensed ECE
providers is a further distinction.
We are also concerned that the removal of these services from coverage
under the Education Act risks cutting the services adrift in terms of any quality
of service provision expectation, or in terms of responsibilities toward the
appropriate care and safety of the children who use them. Where will these
responsibilities be captured to ensure such services can be held to account
should an incident occur, and in order to provide parents some assurance?
2. The statement used to mean or define an ECE centre appropriately uses the
term “…for the education and care of 3 or more children…”. While this
phrase may be appropriately used to describe ECE services, ie: involved in
the delivery of quality education and care services for pre-school children, the
implication is that crèche services are also delivering education and care
services with the only distinction being the duration of exceeding two hours
per day or not.

P O Box 31672 Lower Hutt 5040

T: 0800 742 742 – ceo@ecc.org.nz – www.ecc.org.nz
 It is clear that crèche services are not qualified or resourced to deliver
education services at any level. There is no expectation for crèche services
to employ qualified ECE teachers or to be held accountable to deliver against
the ECE curriculum.
We advocate, therefore, for the inclusion of a definition that covers crèche or
limited attendance centres as referred to in the policy focus statement above.
This definition should include recognition that crèche services do not provide
education as part of their service package and therefore are not subject to the
same requirements as ECE services.
If you have any queries please do not hesitate to contact me.

Yours sincerely,

Peter Reynolds
Chief Executive Officer

P O Box 31672 Lower Hutt 5040

T: 0800 742 742 – ceo@ecc.org.nz – www.ecc.org.nz