Equal Pay in historical context -Chapter 1 of my History Honours dissertation

Equal Pay in historical context

New Zealand and Australia were settler colonies of the British Empire in the early 19th century. Many women migrants from Britain to New Zealand were domestic servants or seamstresses.[1] Settlers brought with them British values and cultural outlooks. In all three countries, ideology – if not reality- emphasised the male breadwinner, with dependant wife and children. While both countries gained greater independence from Britain in the early half of the 20th century these values continued to survive.

Many feminist commentators argue the state played a crucial role in upholding the male breadwinner ideology. It did this through creating a dual labour market with men in the primary and women the secondary sector of the economy.[2] The state also did this through gendered welfare systems.[3] Labour organisations were often proponents of the breadwinning concept as well. In the late 19th century the labour movement sought male wages that would be enough to support their dependants as well.[4]

Both Australia and New Zealand had a system of arbitration whereby disputes or contentious decisions regarding rates of pay or conditions were decided by an independent tribunal. The parties, namely the unions, the employers and the government would then be bound by the decision which was referred to as an Award.[5] In 1894 in New Zealand the Industrial Conciliation and Arbitration Act (IC & A Act) introduced compulsory arbitration for certain industries where the union and employer could not agree an outcome in bargaining.[6] A decision of the arbitration court was binding on all parties once made. For female labour the IC & A Act was a mixed blessing. On the one hand the introduction of arbitration set a minimum wage and level of conditions which eradicated the sweat shop conditions some women faced in the 19th century. Arbitration also resulted in wage rates that were lower for female employees, something usually favoured by unionists fearing that female workers would be used to undercut the male wage rate.[7] By the early 20th century some labour organisations supported equal pay as a way of discouraging employers from employing women as cheap labour.

Unlike Australia, In New Zealand the male breadwinner wage was not formalised in the arbitration system, but was included in the 1936 labour legislation.[8] In 1912 the Australian Arbitration Court ruled in the Mildura Fruit picking case that wage levels should be decided according to the sex of the job, and that jobs that were deemed men’s work would be paid at a higher rate.[9] In 1919 the Australian Arbitration Court set a basic rate of pay for women that was 54% of the basic male rate.[10]  While the New Zealand Arbitration system was never this blatant, the New Zealand system also sustained and systematised the wage advantages of men over women.[11] To protect male workers’ wages and status, arbitration courts in both countries would either prohibit the use of female labour, or impose conditions that would make it unattractive for employers to employ women.[12] A New Zealand example of this was the 1912 Typographers Award where the Union successfully sought a clause stating that women would be employed on the same rates and conditions as men.[13] Doing this made sure there was no monetary saving by employing women, meaning employers were more likely to employ men.

Further, when the depression of the 1930’s hit New Zealand, women were blamed for contributing to male unemployment. In 1931, Legislative Councillor Robert Masters argued that women taking up roles in offices and stores had caused the unemployment of men.[14] Tim Frank in his essay Bread Queues and Breadwinners: Gender in the 1930s argues, in an era where masculine identities were constructed around employment, occupational status and breadwinning were undermined by unemployment.[15]

The Public Service was not covered by the IC & A Act, but by the 1912 Public Service Act. New Zealand Public Service departmental wages and conditions were set centrally by the Public Service Commission for departments. This provided for an Appeal Board which had a similar function to the Arbitration Court.[16] Decisions on appointments and pay grades could be appealed and taken to the Public Service Appeal Board which, much like the Arbitration Court, made binding decisions about employment issues. The Public Service Act of 1912 set a basic minimum wage for adult males in the public service but had been silent on females.[17]

The New Zealand Public Service Association first put forward an equal pay resolution at its conference in 1914.[18] While officially supporting equal pay, the issue was not pursued in any serious way by the organisation.[19] While the PSA had female public service representatives on its executive from 1914, this did little to spur the PSA into action on this issue. One barrier to building a strong public service campaign was that not all public servants were covered by the Public Service Act. The Post Office and Railways had their own legislation.[20] But social attitudes of PSA members regarding women and work were the main reason this was not a priority issue for the union prior to the 1940s.

Raelene Frances and Melanie Nolan’s study of gender and industrial relations in Australia and New Zealand describes how the male breadwinning concept and, by extension, that of female dependency was found in most industrialised capitalist societies from the late 19th century.[21] This idea seems to have taken a much stronger hold in Australia with the ‘Manzone Country’ concept of masculinist culture marking the gendered division of labour.[22] While the male breadwinning concept had been imported from Britain, historians have made the case that in New Zealand the concept of women being bound to the house and children was stronger compared with other advanced capitalist countries.[23] In 1891 the total proportion of women in the New Zealand workforce was only 25%, increasing only to 28% by 1926.[24] It is in this context that an environment developed in New Zealand and Australia where centralised and compulsory wage fixing was designed to protect male wage-earners.[25]

As in New Zealand, the issue of equal pay for Australian women had been raised within the union movement and by feminist organisations for a number of years. An example of this was in 1902 when the Victorian Women’s Post and Telegraph Association led a campaign for equal pay and opportunity for women.[26] At this time the Australian Commonwealth Public Service had just been established after Australian Federation in 1901. Australian women could work in the Public Service but were expected to retire once they married. By contrast in New Zealand women were employed only on a temporary basis until the 1940s.

The Second World War resulted in significant labour shortages both in New Zealand and internationally, due to the number of men being called up to fight. In New Zealand, the National Service Department began a programme of industrial conscription to fill the labour shortages with women workers.[27] Popular images from the time show women entering traditionally male dominated occupations such as engineering or munitions. However the majority of women who entered the workforce at this time were in professions already regarded as conventional women’s job such as food processing and textiles.[28] The increasing number of women entering the workforce can be seen as accelerating the trend that began pre-war. The New Zealand government framed this situation as a necessary evil and that domestic responsibilities of women needed to be put on hold to contribute to the war effort.[29]

In Britain the Women Power Committee (WPC) was established in 1940 in response to the large number of women who were needed to enter the workforce.[30] In Britain labour shortages caused by the war were even greater than in New Zealand and Australia. Realising this would add weight to existing calls for equal pay, the British government introduced a scheme whereby, after an 8 month probation period and subject to satisfactory performance, women employed in men’s work could receive the male wage.[31] Most women conscripted into work did not receive equal pay as a result of this measure. A 1941 Gallup poll in Britain indicated that 68% of those interviewed supported equal pay.[32] Equal pay was to remain on the political agenda throughout the war in Britain.

During the Second World War calls for equal pay in New Zealand grew due to increased female participation in the workforce. In 1943 the PSA set up a sub committee to investigate equal pay, but within the context of the male wage being required to support a family, therefore, the investigation also looked at enhancing the family allowance.[33] At this time, most rank and file PSA members and many New Zealand workers generally believed that male workers should be the breadwinners of the family and their wages should reflect this.[34] Mary Boyd was one of the PSA women’s representatives in the mid-1940s. Boyd recalls that women in the public service were not all of one mind. Many women agreed that women should finish employment after they were married. Those who were driving the PSA equal pay campaign were university graduates such as Rona Bailey (nee Meek) who went on to become president of the PSA women’s committee in 1945.[35] For many women who supported the concept of rate for the job, they supported this as a way of protecting the male breadwinner income at a time when women were entering the workforce during the war.[36]

See the source image
During the Second World War women entered the workforce in high numbers.

Mary Boyd was asked to write a report outlining the arguments for equal pay in the public service in 1944, which she did with the help of civil servant Bill Sutch.[37] The report titled the case for equal pay for equal work reviewed changes social at home and overseas, also the forms of exploitation women had suffered in history. The report recommended that men and women should receive equal remuneration for work of equal value and that this be observed throughout the New Zealand Public Service.[38]

In 1943, the PSA Executive made the decision that any campaign for equal pay, and specifically rate for the job without gender discrimination, would need to be coupled with calls for a universal family allowance.[39] Prior to 1946 family allowances were not universal. At the time 83% of women public servants, when surveyed, said they wanted both equal pay and a universal family allowance.[40] Universal family allowances meant families no longer were as dependant the male breadwinner wage, removing a significant barrier to the equal pay campaign.

In Australia, both Liberal and National Coalition governments (the conservative political block in Australian politics) and Labor Governments used the Australian arbitration system as a way of avoiding the issue of equal pay. As in New Zealand, the onset of war resulted in women entering the workforce in significant numbers. In March 1942, the Curtin Labor Government established the Women’s Employment Board, which operated independently from the federal arbitration system.[41] This board made the decision to raise the minimum rate for women from 54% to 60% of male rates.[42]  This board was scrapped in 1944, but was the first move towards shifting female rates at a time when women were needed in the Australian workforce. The official position of the Australian union movement’s peak body, the ACTU was to lift the rates of women workers. In 1937, the ACTU had put forward the basic wage claim to lift women’s wages to 60 percent[43] as a first step towards equal pay for women. The official policy of the ACTU was to support equal pay for work of equal value, however it and its affiliate members continued to press for a family wage, buying into the male breadwinner concept which undermined their position.[44] Despite the ACTU’s official position on equal pay, much of the movement was less than wholehearted about women entering the workforce, let alone equal pay.[45]  Even as late as 1952, the President of the Queensland branch of the Australian Workers’ Union declared the union should not tolerate employment of females in industry while a breadwinner was unemployed.[46]

These ‘masculinist’ attitudes in Australia did not necessarily mean public opinion was against the concept of equal pay. A poll conducted by the Melbourne Herald in October 1941 found that 59 percent of those polled supported equal pay for women.[47] In 1943, Arbitration Judge A.W. Foster believed that ‘the community in the future, if not in the present, will have to face the problem of so-called “equal pay” much more earnestly than it has so far done.[48] Statements like this show that arbitration judges in Australia were feeling some pressure on the issue of equal pay. However, both state and federal governments continued to avoid the issue for many years by leaving the decisions in the hands of the arbitration system.

Strong comparisons can be made between the Australian and New Zealand campaigns in the 1940s. Because both countries used similar arbitration systems, unions used the Arbitration Courts as a tool to seek equal pay or at least to draw attention to the issue. Like the ACTU, in New Zealand the Federation of Labour (FOL), the private sector union peak body, was calling for women’s wages to be increased in awards. The FOL position was that achieving one rate for the job in awards was the job for affiliates, rather than the central organisation.[49] Like many Australian unions, in New Zealand a number of male dominated unions were opposed or indifferent to equal pay.[50] Other unions supported calls for equal pay but not out of any belief in women’s equality.

In 1945, equal pay was awarded to tram conductors and postal clerks in Australia.[51] This compares with New Zealand where, according to PSA equal pay activist Mary Boyd, Tramways was the first union to gain equal pay in an award through Arbitration in the 1940s.[52] In Australia this issue was complicated in 1956 when the Tramways Board tried to employ female tram drivers on equal pay rates. In this case the union threatened strike action to stop the move.[53] In Britain the Transport and General Workers Union demanded equal pay for fully trained bus and tram conductors.[54]  When the matter went before the Industrial court in April 1940 it ruled in favour of equal pay, making this one of the first group of workers in Britain to achieve this.

At the start of the Second World War female conductors were employed on the Auckland buses.[55] To cover for the shortage of male conductors the employer proposed to extend working hours. The Tramways Union responded to this by proposing that female conductors and the 40 hour week be maintained. At the conclusion of the war, despite having actually campaigned to bring women into the workforce as a way of retaining conditions, the union executive voted to close membership of the union to women in 1946.[56]  In a union publication towards the end of the war it was stated “I am sure our women comrades will be only too happy and will make way for the men folk when the time comes.”[57] The employer did not heed the union’s call to stop employing female conductors until 1956 when the last public tram in Auckland stopped running.[58]

In both Australia and New Zealand, the Tramways Unions were not advocating equal pay on the basis of women’s equality. Instead, Tramways members were seeking to protect male’s breadwinner wages by making the employment of women more expensive. Despite this, the Tramways Union in New Zealand was still viewed as the leading union advocates for equal pay in the 1940. This example did provide encouragement to women within the New Zealand PSA who were advocating equal pay for their members at this time.[59]

A turning point for the campaign was in 1946 when the New Zealand Labour government made the family allowance universal rather than means tested.[60] As outlined earlier, until this point it was widely believed male wages should assume that men were the breadwinners in the household. Making the family allowance universal removed a significant barrier in arguing for rate for the job and ending wage discrimination based on gender.

Another significant step in the public service was when the PSA successfully campaigned to allow women to have permanent roles in the public service.[61] At this time, Rona Bailey and Kath Ross had been elected representatives to the PSA national executive.[62] These two had been active on the PSA Women’s subcommittee set up in 1943 along with Mary Boyd and a number of other women who became active at the time. This subcommittee engaged in regular meetings and surveys of women members in the service, which increased pressure on the PSA executive to be stronger advocates for their women members. Rona Bailey cites the change in PSA leadership, and specifically that Jack Lewin was elected PSA President in 1946, as shifting the PSA to take a stronger position on women’s issues.[63] He was at the centre of a group of young activists, known as the Korero, who increasingly challenged the leadership’s deferential attitude to the government and the public service commissioner.[64] In 1952 at the height of the cold war his Korero grouping were accused of being a communist front organisation. In subsequent executive elections Lewin and the Korero group were defeated by what Lewin claimed were National Party supporters.[65]

Women involved with the PSA equal pay campaign in the 1940s looked overseas for ideas on how to successfully promote the cause. Canada was viewed by New Zealand equal pay campaigners as a country that had made significant advances in the cause. In May 1944, Helen Harrison, Secretary of the NZ PSA women’s committee, wrote to the Canadian High Commission about women civil service employees.[66] In a detailed response the High Commission explained that under the Canadian Civil Service Act of 1927 there were no formal differences in pay grades for men and women.[67] This was in contrast to New Zealand where there were salary bars for women in the public service. However, during the Second World War the Canadian National War Labour Board was established to set wages.[68] This board set a lower minimum rate for women employed on government contracts.[69]  The justification for this was that Canada, like most other countries, had increased numbers of women entering the workforce but women were not as experienced or productive as male workers.[70]

Universal family allowances and inclusion of women as permanent members of the Public Service removed two major obstacles to equal pay in New Zealand. In New Zealand and Australia, there were still powerful ideological and institutional obstacles to overcome. Unions would continue to use Arbitration Courts and the public sector equivalents to highlight the issue of equal pay in the 1950s. International developments at the ILO strengthened arguments for equal pay.

[1] WB Sutch Poverty and Progress in New Zealand AH & AW Reed 1969

[2] Nolan 25

[3] Nolan 25

[4] Nolan 25

[5] Arthur Sullivan and Steven M Sheffrin Economics: Principles in action. Pearson Prentice Hall 2003 324

[6] Robin Ingram The Politics of Patriarchy: The response of capital and organised labour to the movement of women into the paid workforce Auckland University 1988  205

[7] Ingram 205

[8] Cybele Locke Workers in the Margins Bridget Williams Books 2012 51

[9] Marilyn Lake The Independence of Women and the Brotherhood of Man: Debates in the Labour Movement over Equal Pay and Motherhood Endowment in the 1920s Labour History number 63, November 1992 9

[10] Nolan 22

[11] Stephen Robertson Women, Work and the New Zealand Arbitration Court 1894-1920 Labour History, Number 61, November 1991 30

[12] Robertson 33

[13] Robertson 34

[14] Barbara Brookes A History of New Zealand Women Bridget Williams Books 2016

[15] Tim Frank Bread Queues and Breadwinners: Gender in the 1930s in The Gendered Kiwi, Auckland University Press 1999

[16] Burt Roth Remedy for Present Evils: A history of the New Zealand Public Service Association from 1890 New Zealand Public Service Association 1984

[17] Nolan 238

[18] Nolan 235

[19] Nolan 235

[20] Nolan 234

[21] Ralene Frances and Melanie Nolan Gender and the Trans-Tasman World of Labour: Transnational and Comparative Histories Labour History Number 95 November 2008 29

[22] Frances and Nolan 29

[23] Frances and Nolan 29

[24] Nolan 30

[25] Frances and Nolan 29

[26] Kath Williams The Unions and the fight for equal pay Melbourne 2001 75

[27] Deborah Montgomerie Man-powering Women: Industrial Conscription during the Second World War Women in History 2 1992 184

[28] Montgomerie 188

[29] Montgomerie 186

[30] Harold L Smith The Womanpower Problem in Britain during the Second World War The Historical Journal Volume 27, Number 4 1984 929

[31] Harold L Smith The Womanpower Problem in Britain during the Second World War The Historical Journal Volume 27, Number 4 1984 935

[32] Harold L Smith The Womanpower Problem in Britain during the Second World War The Historical Journal Volume 27, Number 4 1984 935

[33] Corner 22

[34] Nolan 235

[35] Mary Boyd, interviewed by Alison Lash, epcas 38, series 38,  August 9 1985

[36] Mary Boyd, interviewed by Alison Lash, epcas 38, series 38,  August 9 1985

[37] Mary Boyd, interviewed by Alison Lash, epcas 38, series 38,  August 9 1985

[38] Mary Boyd The Case for Equal Pay for Equal Work Women’s Consultative Committee, 4 April 1944

[39] Nolan 235

[40] Nolan 235

[41] Patmore 173

[42] Patmore 177

[43] Williams 79

[44] Patmore 177

[45] Sheridan and Stretton 136

[46] Sheridan and Stretton 136

[47] Williams 81

[48] Sheridan and Stretton 135

[49] Ingram 235

[50] Ingram 235

[51] Sheridan and Stretton 135

[52] Mary Boyd, interviewed by Alison Lash, epcas 38, series 38,  August 9 1985

[53] Williams 103

[54] Harold Smith The Problem of “Equal Pay for Equal Work” in Great Britain during World War II The Journal of Modern History Volume 53 Number 4 1981

[55] Ingram 224

[56] Ingram 230

[57] Ingram 229

[58] Ingram 231

[59] Mary Boyd, interviewed by Alison Lash, epcas 38, series 38,  August 9 1985

[60] Nolan 235

[61] Trevor Richards interview with Cath Kelly and Margaret Long for special Journal lift out 1986

[62] Corner 25

[63] Corner 25

[64] Colin Hicks. Lewin, John Philip from the Dictionary of New Zealand Biography. Te Ara – the Encyclopedia of New Zealand, updated 5-Nov-2013  http://www.teara.govt.nz/en/biographies/5l9/lewin-john-philip

[65] Roth 130

[66] Correspondence Helen Harrison to Canadian High Commission, May 1944

[67] Correspondence Canadian High Commission to NZ PSA, May 1944

[68] Niemann 37

[69] Niemann 38

[70] Niemann 38

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Introduction to my History Honours dissertation on the 1950s equal pay Campaign

Introduction

In 1956 the New Zealand Public Service Association (PSA), as part of its campaign for equal pay, used litigation to promote the cause. The central question under investigation is how did this use of litigation compare to contemporary campaigns in Australia and the United Kingdom? This essay studies the equal pay campaigns in these three jurisdictions up to 1960. It explores the role litigation played in equal pay campaigns, looking at both similarities and differences in the way that this campaign tool was used. Specifically it examines the 1956 Parker case taken by the PSA in 1956. In this case the PSA used litigation to challenge gender pay discrimination in the New Zealand public service. This case is then compared with litigation in the two other jurisdictions.

The end goal for the equal pay campaigns was described as ‘rate for the job’. This meant that a role should be paid at a certain rate, and the salary band or rate should not be different for male or female workers. This compared two workers doing the same job and did not look more broadly at different jobs that were of equal value. For campaigns like that being promoted by the PSA in the 1950s, the focus was on abolishing the lower salary bars for women, and having a system where a job had one wage or salary rate regardless of gender. Those involved with the campaign believed a broader call for equal pay for work of equal value would have struggled to get any traction within conservative 1950s society. Many still believed women’s place was in the home rather than at work once they were married. During this period, the International Labour Organisation (ILO) passed a convention which went further and called for work of equal value to be paid the same. This raises the question of whether the social values held in New Zealand, Australia and the United Kingdom were more conservative than other countries during this period. The ILO Conventions and other nations’ moves towards equal pay place these three campaigns in a global context, during a time when demands for equal pay for women were becoming louder.

The New Zealand campaign paid close attention to international developments. The PSA would often report on international developments where moves were made towards equal pay for women. The PSA’s own campaign used litigation, the most notable being the Parker case taken in 1956. In this case the PSA went to the Public Service Appeal Board to challenge female salary caps in the public service. Other historians have looked at this case in the context of the New Zealand campaign in the 1950s, leading up to equal pay legislation in the 1960.

Margaret Corner’s No Easy Victory: Towards Equal Pay for Women in the Government Service 1890-1960 gives an overview of the PSA campaign for equal pay. Specifically it details the early calls for equal pay not long after the union was founded, and how these calls increased as women entered the public service in greater numbers throughout the Second World War. The 1956 Parker case is described as a turning point in the New Zealand Equal Pay movement.[1] This was due to increased public support for equal pay after this case. Corner then discusses the political impact of the PSA taking litigation on behalf of Parker, arguing this action eventually led to the 1960 legislation.

Bert Roth’s Remedy for Present Evils draws similar conclusions to Corner about the significance of the Parker litigation. Roth places the 1950s equal pay campaign in the context of the overall development of the PSA as a union. The Parker litigation and the equal pay campaign are the subject of Roth’s chapter dealing with the 1950s.

Megan Cook’s Gender and Paid work in New Zealand, 1950 to 1972 places the New Zealand campaign within the global equal pay movement in her introduction. Specifically Cook mentions the 1955 moves towards equal pay in the British Civil Service, and the New South Wales equal pay amendment to that states Industrial Arbitration Act in 1958.[2] Cook’s main thesis is about the political campaigns in New Zealand. Specifically Cook explores the reluctance of both Labour and National to implement equal pay measures in the 1950s.[3]

Melanie Nolan’s Breadwinning: New Zealand women and the state builds on the work of Corner and Roth. Nolan explores social attitudes to gender and labour relations and how these influenced the campaign. Specifically the ideology of the male breadwinner wage where men’s income was expected to support a family. Nolan examines the PSA equal pay campaign from 1943 through to the 1960 equal pay legislation. The PSA followed the lead of its international sister organisations in calling for the government to implement the ILO equal pay convention, Nolan argues.[4]

W B Sutch’s Women with a cause, describes the New Zealand PSA’s role in the equal pay campaign as essential.[5] Sutch argues The ILO Convention 100 passed in 1951 calling for equal remuneration for men and women as a significant step for that organisation. Sutch does not access how the ILO or other international developments influenced the PSA or others campaigning for equal pay in New Zealand.

While not specifically mentioning the Parker case, Raelene Frances and Melanie Nolan’s Gender and the Trans-Tasman World of Labour compares social attitudes to gender and labour relations in New Zealand and Australia. This essay draws the conclusion that the two countries have similar economies and cultures and as a result have had comparable outcomes for female workers.[6] Frances and Nolan argue that when looking at the history of women and work the two countries have not been compared properly. Specifically on the equal pay issue they highlight that studies on equal pay face focussed on either New Zealand or Australia but not Australasia.[7]

Linda Hill’s Equal pay for equal value: The case for care workers gives the historical context of equal pay legislation. Hill begins by saying New Zealand women had been calling for equal pay since they gained the right to vote in 1893.[8]  The ILO Convention in 1951 is cited by Hill as providing impetus for women public servants in New Zealand to begin campaigning for equal pay.[9] This claim is not entirely accurate, as other events such as the equal pay developments in Britain had a far greater impact on New Zealand equal pay supporters.

Pragmatic Procrastination: Government, Unions and Equal Pay 1949-68 By Tom Sheridan and Pat Stretton examines how the political establishment in Australia for many years avoided calls for equal pay legislation. This essay describes how the Menzies government in 1951 claimed to support the principle of equal pay. The Menzies government abstained on the ILO equal pay convention, not wanting to commit to something that could be used against it by the equal pay campaign.[10] The essay also studies the increasing calls for equal pay from within the Australian Council of Trade Unions (ACTU) from the 1930s onwards. It outlines the events leading up to the New South Wales (NSW) state government equal pay legislation in 1958. Sheriden and Stretton also assess efforts to get equal pay campaigns in other Australian states in 1950s, and how these struggled to gain support.

Brandon Ellem’s Women’s Rights and Industrial Relations under the Postwar Compact Australia explores the greater movement of women into the workforce in the first half of the 20th Century. Ellem explains how during the Second World War increased calls for equal pay for women exposed the conflicting views with the trade union movement on this issue. Many union leaders at this time supported equal pay only as a mechanism to protect male wages. Ellem’s conclusion compares Australia to other industrialised countries as having increased female participation in the paid work force.[11]

Raymond Markey’s Organisational Consolidation and Unionateness in the NSW Public Service Association 1899 – 1939 studies the development of this organisation. The NSW Public Service Association consistently lobbied for equal pay for women and in 1915 a women’s organising committee was formed.[12] This is similar to the New Zealand PSA who first took a position in favour of equal pay for women in 1914, though no mention of this is made by Markey. Studies of the Australian equal pay campaign say little about the influences of international campaigns occurring at the same time.

Harold L Smith has written much on the topic of the British equal pay movement. His work British feminism and the equal pay issue in the 1930s gives an overview of the feminists lead the equal pay campaign in 1930s. Smith rebuts claims that the feminist movement became moribund after the 1920s in Britain, citing the 1930 equal pay campaign for civil servants as evidence of it still functioning. In 1936 a vote in the House of Commons for equal pay in the civil service narrowly passed, only to be reversed by the government a short time later.

Smith’s essay The Womanpower Problem in Britain during the Second World War, assesses how women entering the workforce in the Second World War further built the movement for equal pay in Britain. Smith goes into more detail in The Problem of “Equal Pay for Equal Work” in Great Britain during World War II. Smith outlines how increasingly unions and women who had been required by the government to work demanded the same wages as men.

In Smith’s The Politics of Conservative Reform: The Equal Pay for Equal Work Issue 1945-1955 explores the political response to growing calls for equal pay after the Second World War. This outlines how both Labour and Conservative Party’s in government were reluctant to progress the equal pay issue. By 1955 the Conservative Government, as a result of growing public pressure, did introduce equal pay for the Civil Service. Smith talks a great deal about the campaign in Britain, but says little about how international influenced this. Nor does Smith say much about how developments in Britain influenced the campaigns in New Zealand, Australia or elsewhere.

This dissertation will build on the concept of international comparative histories and compares the use of litigation as part of the equal pay campaigns up to 1960 in New Zealand, Australia and the United Kingdom. These countries have been chosen due to their similar political institutions and their relationship as Commonwealth countries. This study will explore these campaigns and how the New Zealand equal pay movement was influenced and inspired by Australian and British campaigns. The frameworks for industrial relations in these countries were similar during this period, as were the social attitudes and politics. The dissertation will look at the development of equal pay campaigns in the decades leading up to the 1950s.

Specifically it studies the impact of women entering the workforce in increasing numbers during the 1930s depression and further during the Second World War. It studies the impact of the ILO moves to implement international conventions regarding equal pay, and how this impacted the New Zealand campaign’s use of litigation. From there it assesses the New Zealand Parker case and whether similar strategic litigation was used in Britain or Australia. It assesses the role litigation played as leverage to bring about political change.  Oral histories from those involved with the PSA equal pay campaign, along with PSA journals and other PSA publications are studied as part of this research. Finally, the dissertation will explore the political responses to litigation as part of the wider equal pay campaign during this period. Parliamentary Debates, media report, interviews with PSA activists and PSA publications have been used in this research.

[1] Margaret Corner No Easy Victory Public Service Association, Wellington, 1988 49

[2] Megan Cook Gender and Paid Work in New Zealand, 1950 to 1972 Otago University, February 2000 15

[3] Cook 80

[4] Melanie Nolan Breadwinning: New Zealand women and the state Canterbury University Press 236

[5] W B Sutch Women with a cause New Zealand University Press 1974 125

[6] Ralene Frances and Melanie Nolan Gender and the Trans-Tasman World of Labour: Transnational and Comparative Histories Labour History Number 95 November 2008 36

[7] Frances and Nolan 26

[8] Linda Hill Equal pay for equal value: The case for care workers Women’s Studies Journal, Volume 27 Number 2, December 2013

[9] Hill 15

[10] Sheridan & Stretton Pragmatic Procrastination: Governments, Unions, and Equal Pay 1949 -68 Labour History number 94 May 2008 135

[11] Brandon Ellem Women’s Rights and Industrial Relations Under the Post-war Compact in Australia University of Sydney 1999 61

[12] Raymond Markey Organisational Consolidation and Unionateness in the NSW Public Service Association 1899-1939 Labour History number 99, November 2010 105

Political responses to Equal Pay (Chapter 6 of my History Honours dissertation)

Political responses to Equal Pay

In Britain, early attempts to pass equal pay measures through the House of Commons nearly succeeded. In 1936 a private member’s bill was introduced, attempting to introduce equal pay for women, in the common classes of the civil service on the same scales of pay as men.[1] The first vote narrowly carried 156 votes to 148, much to the surprise of the government.[2] The government then insisted that the vote be retaken and threatened to resign if the bill passed again. This second vote defeated the equal pay motion 149 to 134.[3] Eight years later a similar occurrence happened in the Commons over an amendment to the Education Bill, seeking to introduce equal pay for teachers. On this occasion the equal pay amendment passed by one vote, and was the only time the Churchill government lost a vote in parliament during the war.[4] Once again the vote was sent back to the Commons and the government threatened to resign unless the amendment was defeated. Again this threat resulted in the equal pay amendment being defeated, this time with a Royal Commission set up to investigate the matter.[5] The Conservative Government hoped this would defer the issue till after the war, by which time fewer women would be needed in the workforce.

The shift of the British Conservative Party on the issue of equal pay, has parallels with that of the New Zealand National Party, in that from the 1940s through to the late 1950s its position changed significantly. In both countries the Labour Party, once in government, was reluctant to support equal pay for women. Between 1936 and 1944 the British Conservative Party votes were instrumental in defeating parliamentary proposals for equal pay in Britain.[6] However, once in opposition, the Conservative Party found it could make political mileage on the issue. In 1947 the then Labour Government in Britain announced that it would not introduce equal pay, despite being sympathetic while in opposition.[7] Conservatives, particularly the moderates within the party saw this as an opportunity to win votes off Labour, so also began making sympathetic statements in favour of equal pay. Once back in government in 1951 The Conservatives delayed any decision on implementing equal pay citing economic difficulties. Public opinion meanwhile was turning in favour of women, and in 1954 opinion polls indicated a majority supported equal pay.[8] In response Labour in opposition by 1954, announced it would introduce equal pay if elected government. The Conservatives responded by announcing their own 7 year plan to phase in equal pay for the civil service from 1955 to 1962.[9] This was achieved using existing public service pay setting mechanisms rather than through passing equal pay legislation, which did not happen in Britain until 1970.[10] The campaign used litigation or the threat thereof as pressure on the government to achieve this change.

In New Zealand the Parker Appeal and her subsequent demotion resulted in a debate in Parliament. Leader of the Opposition Walter Nash, in opening the debate, said that women being paid less than men was “discrimination that had been shown against women for centuries, but I think we are becoming a little more enlightened now.”[11] He went on to say that what happened to Jean Parker was “class discrimination of the worst kind, to say that a women who can do the job as well as a man should receive less than a man.”[12]

National MP Dame Hilda Ross, when speaking in this debate, said it was a pity that this had happened. She went on to say any women who stood for a position in public life knew there would be a great deal of prejudice against her just because she is a woman.[13] When Prime Minister Sid Holland interjected shouting “not in your case” Ross responded that yes, she had, saying she had experienced National Party men not support her because she was a woman.[14] Ross was known to have supported the equal pay cause, unlike most of her National Party caucus colleagues at the time.[15] Mark Derby, describes Ross as well intentioned but deluded in that she argued that Parker should not be concerned at her loss of status and income since “she is young, she is attractive and she has got a husband.”[16] While Ross did repeat the National Party line that Parker had been poorly advised by the PSA in taking the case, she also expressed sympathy for Parker’s position. PSA executive women’s representative Joyce McBeth confirms Ross’s sympathy for the PSA position. McBeth recalls Ross being supportive despite her National Government’s position on equally pay. Ross had spoken in favour of equal pay four years earlier in 1952 saying “equal pay for work of equal value…it will come and I see no reason why it should not come.”[17] Ross organised meetings with women Labour MPs such as Iriaka Ratana to build support for equal pay.[18] Ross talked of women with many years’ experience in the public service having to put up with young men in junior clerks’ positions being considered more senior in the public service. Ross remarked “if some young man in this house was my senior, I would resent it.”[19] According to one Labour MP, Reginald Keeling, the world was moving towards equal pay in 1956.[20] Keeling mentioned that Tram conductors and grocery store employees had already achieved equal pay.[21]

After the Parker case, the PSA made a decision to shift its focus to the government and to seek legislative change. The use of litigation as a tactic had helped raise public awareness, but had failed to deliver the desired outcome of lifting Parker’s pay rates up to that of her male colleagues. The PSA initially applied to the Government Service Tribunal for the lower salary cap on female employees to be removed, which was subsequently rejected in 1957.[22]

The response from the National Government was for Prime Minister Sid Holland to call a ‘tea party’ of women from these organisations to discuss the issue.[23] The PSA was not invited to this event at first, as Prime Minister Holland argued that the PSA was not a Womens’ Organisation.[24] There were also questions within the PSA as to whether they should attend the event. PSA Women’s sub-committee member Margot Jenkins held the view they should not allow the government to fob women off with tea and biscuits.[25] Eventually the government was forced to back down on this issue as the PSA had support from the National Council of Women, and other women’s organisations after the Parker Case. At this ‘tea party’ Holland was quoted as saying: “Men used to be the breadwinners, but now I know that thousands of women have dependants, and these women should be getting paid the same as men.”[26] However, the government was of the view that this could not be implemented in the public service without the private sector also changing. In March 1957, the National Government announced it would set up a Commission of Inquiry into equal pay.[27] The main focus of this inquiry was working with government departments to examine practical and procedural issues involving implementing equal pay in the public service.[28]

The position taken by the Labour opposition was to support equal pay, which had nominally been their policy since 1927.[29] Despite Nash’s depiction of women being paid less as class discrimination of the worst kind, he was slow to act on the issue after winning the 1957 election. At first Labour did not accelerate the process of lifting women’s wages in the public service.[30] In part this was due to Labour winning the 1957 election with a majority of one. Megan Cook disagrees that this was the case as the previous National Government had already declared its support for equal pay, and set in motion a process that was likely eventually to lead to its implementation in some form.[31] Another explanation is the budget crisis of 1958. On taking government in 1957 Labour were informed by treasury that the country’s economic situation had deteriorated rapidly.[32] Finance Minister Arnold Nordmeyer and Nash began adopting delay tactics regarding equal pay during this crisis.[33] It is also likely that social attitudes of the time influenced Nash view, who still to some extent believed in the male breadwinner ideology. Cook agrees with this position claiming that Nash, while supporting the Parker case when in opposition, based on a commitment to egalitarianism. Yet Nash held a conservative view on the position and women and he still believed at heart it was the role of men to provide for dependents.[34] Grace du Faur agreed with this assessment and thought Nash was surprised public service women were pushing this. She believed Nash’s outlook was based on the fact that his own mother did not have equal pay.[35] This prompted the PSA once again to look for ways to apply pressure on the government. According to Jim Ferguson the PSA believed legislation needed to be passed by Labour, as the chances of passing such legislation under a National administration were slim.[36] This time they did so on the international stage, with Margaret Long making her infamous announcement at the 1958 ACTU women’s conference as already discussed.

In March 1958, NSW Premier JJ Cahill announced that he would legislate for equal pay, which he did later that year.[37] Other Australian states and the federal government did not follow this move until a number of years later. When the NSW state government announced it would legislate for equal pay, the federal Labour Minister Harold Holt responded. Holt claimed he did not oppose the principle of equal pay, but that the matter should be decided by the appropriate tribunals.[38] Supporters of the campaign sent letters to the Prime Minister, leaders of the state political parties and members of the state parliament. Officially the NSW opposition supported this bill introduced by the NSW Labor government, but one opposition MP spoke against saying it would have a bad effect on marriage and the NSW birth-rate.[39] While this campaign was successful in achieving legislative change in NSW, in other states and federally the change did not occur until the 1960s.

In 1958, the ILO debated and eventually passed Convention 111 regarding discrimination in employment. This specifically stipulated that there should be no discrimination against women in employment.[40] Like the Holland National government in 1951, the Nash Labour government took a ‘neither for nor against’ position and abstained on this ILO Convention.[41] The Australian government federal government also abstained as it had in 1951 on the earlier convention. In response to this, the New Zealand Council for Equal Pay, which was a coalition of women’s organisations and unionists, called on the government to ratify both the 1951 and 1958 ILO Conventions.[42] The Council for Equal Pay also issued a statement to the media expressing concern about the government’s stand on the ILO Conventions.[43] While this did not change the government’s position at the time, it continued to build public awareness and support for the issue of equal pay.

See the source image
NZ Prime Minister Walter Nash 1957 to 1960. Eventually passed Equal Pay legislation in the dying days of his government.

In the dying days of the 2nd Labour government in 1960, there was a real push by the equal pay campaign to get legislation through before the general election. Nash by this time was casting doubt on whether Labour had gone into the 1957 election with a promise to take action on equal pay.  At meetings Nash would say Labour supported the principle but had made no commitment to legislate. Nash, however, was a notorious hoarder of old paperwork and it was believed the evidence of this promise would be found in his collection.[44] Nash’s private secretary Joan Evans was friends with a many of the people campaigning for equal pay. Evans was able to find the policy document that proved Labour had promised to legislate for equal pay in the 1957 election.[45] This document was produced by the PSA delegation at their next meeting with Nash, who rather changed his bluster once the document was released.[46]

When PSA national secretary Jack Turnbull meet with Nash in mid-1960, Nash expressed concerns that there would not be time to get the bill drafted.[47] Turnbull responded that the PSA and the campaign group had already done quite a bit of work on this so were happy to help the draftsmen put together the bill, which Nash agreed to.[48] The Government Service Equal Pay Bill finally reached parliament in October 1960.[49] The Bill, much like the British one was to implement equal pay in a phased way between 1960 and 1963.

The National opposition had up to that point given the impression that they would oppose equal pay. They claimed greater analysis was needed into the impact this change would have.[50] By this stage the government commission looking into this issue had reported back but it was thought the opposition would argue that more information was required. Deputy leader of the Opposition Jack Marshall did indeed make this claim when the Bill was first introduced into parliament.[51] Much to the surprise of equal pay supporters when the Bill returned to parliament for its second reading the opposition announced it would support it. Much like the British Conservative Party, the New Zealand National Party had caucus members supportive of equal pay. Also some feared that women voters might be put off voting for National if they opposed equal pay.

In 1960 the Government Services Equal Pay bill passed with support of Labour and National. The goal of the PSA campaign from 1955 onwards had been to get an equal pay act for public servants. Margaret Long later reflected that this was a fairly limited goal and explained that in organisations like the PSA people had to work within allowable parameters.[52]

 

 

[1] Harold L Smith British feminism and the equal pay issue in the 1930s Women’s History Review 1996 105

[2] Harold L Smith British feminism and the equal pay issue in the 1930s Women’s History Review 1996 105

[3] Harold L Smith British feminism and the equal pay issue in the 1930s Women’s History Review 1996 105

[4] Harold L Smith The Problem of “Equal Pay for Equal Work” In Great Britain during World War II The Journal of Modern History Volume 53 Number 4 1981 668

[5] Harold L Smith The Problem of “Equal Pay for Equal Work” In Great Britain during World War II The Journal of Modern History Volume 53 Number 4 1981 668

[6] Harold L Smith The politics of conservative reform: the equal pay campaign for equal work issue, 1945-1955 The Historical Journal Volume 35 Number 2 1992 401

[7] Harold L Smith The politics of conservative reform: the equal pay campaign for equal work issue, 1945-1955 The Historical Journal Volume 35 Number 2 1992  404

[8] Harold L Smith The politics of conservative reform: the equal pay campaign for equal work issue, 1945-1955 The Historical Journal Volume 35 Number 2 1992  409

[9] Harold L Smith The politics of conservative reform: the equal pay campaign for equal work issue, 1945-1955 The Historical Journal Volume 35 Number 2 1992  409

[10] Glew 169

[11] New Zealand Parliamentary Debates, 1956, Volume 309 1549

[12] New Zealand Parliamentary Debates, 1956, Volume 309 1549

[13] New Zealand Parliamentary Debates, 1956, Volume 309 1576

[14] New Zealand Parliamentary Debates, 1956, Volume 309 1577

[15] Bronwyn Dalley. Ross, Grace Hilda Cuthberta from the Dictionary of New Zealand Biography. Te Ara – the Encyclopedia of New Zealand, updated 28-Jan-2014  http://www.teara.govt.nz/en/biographies/5r25/ross-grace-hilda-cuthberta

[16] Derby 122

[17] Cook 81

[18] Joyce McBeth, interviewed by Alison Lash, epcas 38, series 38, August 1 1985

[19] New Zealand Parliamentary Debates, 1956, Volume 309 1577

[20] New Zealand Parliamentary Debates, 1956, Volume 309 1585

[21] New Zealand Parliamentary Debates, 1956, Volume 309 1584

[22] Nolan 239

[23] Nolan 239

[24] Margaret Long interviewed by Alison Lash, epcas 38, series 38, August 10 1985

[25] Margaret Long interviewed by Alison Lash, epcas 38, series 38, August 10 1985

[26] Derby 123

[27] Nolan 240

[28] Nolan 240

[29] Nolan 240

[30] Nolan 240

[31] Cook 90

[32] Mary Logan Nordy, Arnold Nordmeyer A political biography Steele Roberts Wellington 2008 306

[33] Keith Sinclair Walter Nash Auckland University Press Auckland 1976 346

[34] Cook 90

[35] Grace du Faur, interviewed by Cath Kelly, epcas 38, series 38 August 9 1988

[36] Jim Ferguson, interviewed by Cath Kelly and Margaret Long, epcas 38, series 38, November 22 1986

[37] Sheridan & Stretton 138

[38] Marian Quartly and Judith Smart Respectable Radicals: A history of the National Council of Women of Australia 1896 -2006 Monash University 2015 294

[39] The Canberra Times Equal Pay bill passes through all stages, 11 December 1958 13

[40] Corner 3

[41] Corner 81

[42] Corner 82

[43] Corner 82

[44] Grace du Faur, interviewed by Cath Kelly, epcas 38, series 38 August 9 1988

[45] Grace du Faur, interviewed by Cath Kelly, epcas 38, series 38 August 9 1988

[46] Grace du Faur, interviewed by Cath Kelly, epcas 38, series 38 August 9 1988

[47] Jack Turnbull, interviewed by Cath Kelly, epcas 38, series 38 April 19 1986

[48] Jack Turnbull, interviewed by Cath Kelly, epcas 38, series 38 April 19 1986

[49] Roth 155

[50] Corner 89

[51] Roth 155

[52] Margaret Long, interviewed by Alison Lash, epcas 38, series 38, August 10 1985

My Post graduate dissertation

In 2016 I completed my History Honours degree at Victoria University of Wellington. After 4 long years of hard slog while working full time, I was relieved to get it done.

My honours dissertation was a study of the Jean Parker Equal Pay case taken by the New Zealand Public Service Association in 1956. My dissertation did a comparison of this campaign in New Zealand, and similar campaigns in the UK and Australia at the same time.

Over the next few days I will post the chapters from this dissertation.

The topic of my dissertation was the following:

How did the use of litigation to push for equal pay for women in the New Zealand public service compare to contemporary campaigns in Australia and the United Kingdom in the 1950s?

Acknowledgements;

Thank you to everyone who have helped and supported me in this work, and over the four years I’ve completed my honours degree.

In particular I’d like to acknowledge my late mother Stefanie Kelly, who helped me so much when I started this degree. My father Chris Kelly, who has also helped me considerably through this process. My thanks to Christine Ross and Jim McAloon who introduced me to this topic. And to all other friends and family who have put up with me while I have been studying.

A special thank you to Cybèle Locke, whose guidance always galvanised me to do better.

Finally, I would like to acknowledge all those who have fought and continue to fight for equal pay, and ending discrimination of all forms at work.

 

Walk 10: City Streets and Alleys

Walk 10 in from the 1980s AA guide book was titled City Streets and Alleys. This was was done on Friday 27 July 2018.

Walk 10
From the 1980s AA guide book of London

The first landmark to see on this walking tour was The Temple of Mithras. These remains were discovered in 1954. For many years the temple foundations were viewable at street level.

I got a bit lost finding the Mithras, as they weren’t located at the place the guidebook stated. After wandering about for awhile I eventually asked for directions, and was sent to the Bloomburg building.

The site after being found in 1954, had in fact been moved from the location it was found. The remains having been moved to their Victoria Street site, had the middle bit filled in with concrete. A campaign started to have these ruins moved back to their original site nearby, and to have the 1950s concrete removed.

The Temple is now in the basement of the Bloomberg entry, and is free entry to see.

Temple display
View of the temple ruins at its old location

img_1243.jpg

After a good look at the temple ruins, I continued up Watling Street towards St Pauls.

IMG_1259
Ye Olde Watling – Where Christopher Wren stopped for a Pint while Building St Paul’s Cathedral. 

From here I continued up the street to St Paul’s Gardens and then through Paternoster Row.

Having past around the outside of St Pauls, the walk took me up Giltspur Street to Pye Corner – said to be the mark where the Great Fire of London was finally put out.

 Following this the walk took me to Bartholomew’s Hospital, the oldest hospital in London and St Bartholomew’s Church which is the oldest church in the city.

From here the walk headed past Smithfield market through to Roman Wall.

IMG_1271
Smithfield Market

The Roman Wall is the site of an old Roman Fort. Next to this is the Museum of London.

From here the tour took me onto Cheapside, the high street of medieval London. It was called Chepe – from the Anglo-Saxon word for Barter.

IMG_1287
Cheapside

The tour ended back at Bank Station. IT passed the Old Grocers Hall, a casualty of a 1944 German bombing raid. It was rebuilt only to be guttered by fire in 1965. The grocers company dates back to 1428.

 

Antisemitism, Islamophobia and the sad state of politics

I have mentioned before my increasing dislike of modern politics.

This week UK Labour leader Jeremy Corbyn responded to ongoing accusations of antisemitism in the Labour Party, issuing this public video statement.

Meanwhile the Conservative Party face renewed accusations of Islamophobia after Boris Johnson’s comments about women in Burka’s caused considerable offence.

Image result for May and Corbyn
The political Establishment need to show leadership and stand up to racism. 

The media has been reporting  both antisemitism in Labour and Islamophobia in the Conservatives all year. Some journalists and commentators have speculated as to which of the two major parties is worse for their bigotry. The simple answer is that both are an absolute disgrace, and these sorts of discriminatory and xenophobic prejudices should have no place in modern politics. But sadly it does.

Racism is nothing new, it has existed throughout human history. And racism is out there in society. Politicians are elected by the people, and yes there is a market for racist politics. The rise of the far right throughout much of Europe globally is evidence of this. But this doesn’t make it inevitable. The two main political parties in the UK need to show leadership and stand up to racism. Both May and Corbyn have come out against racist remarks made by party members. But in both cases, a stronger stance was needed much sooner. Not just by the leaders, but by all MPs and people in leadership roles. And most importantly by party members.

The UK is far from alone from having problems of racism in politics. But in the UK this issue has come to ahead in 2018. There is nothing good in what has come out, but this can be an opportunity for the political establishment in the UK to draw a line in the sand. If from this Labour and the Conservative’s to vow to take a much stronger stand against racism and bigotry within their parties, this would be a very positive development. Whether this happens remains to be seen…

 

VSM – why it needs to go.

Originally posted on The Standard. 

In 2010 the ACT Party with the help of National managed to pass a piece of legislation that damaged student democracy, and blatantly ignored public opinion. Voluntary Student Membership or VSM sounds like a horrendous STI, and its impact has been to screw student democracy.

Prior to 2010 students had a choice as to whether membership of their students’ associations at tertiary institutions would be universal or voluntary. This was due to New Zealand First who in coalition with National in 1998, could see the contribution democratically elected students’ associations make. In 1999 all campuses had a vote on whether students’ association membership should be universal or voluntary. In the University sector all but Auckland and Waikato voted to retain universal membership, and Waikato voted to return to universal membership shortly.

Students’ Associations provided democratic representation at all levels of tertiary institutions. They represented students who faced difficulties with the institution and provided support for dealing with agencies like Studylink. They lobbied institutions for welfare services like foodbanks and hardship grants, and in many cases helped provide these services directly.

When ACT put forward the bill to make all students’ associations voluntary, the National Party said it would listen to submission at select committee and then make a decision. Over 90% of submissions were against this bill sponsored by Roger Douglas. Students from around the country highlighting importance of democratic representation.

More of Roger's harmful policies
Roger Douglas did the same to Students’ Associations in 2010 as he did to the NZ economy in the 1980s. In both cases his polices have done lasting damage.

Recently on my blog I have been talking about my time on the students’ association exec. Looking back much was achieved. Students’ Associations provide strong representation on campus and valuable services to students. The student movement struggled for nearly 30 years to end crippling student fees, and in 2017 a Labour led government was elected on the promise they would do just this. Students’ associations continue to play an important role. Sadly after half a decade of VSM many of them are now struggling to survive.

The legislation NZ First got National to pass in 1998 putting the question of membership of Students’ Associations to a democratic vote of all students work well. NZ First, now in coalition with Labour and the Greens should unlike national, listen to the 90% of submissions on the current law and repeal Roger Douglas’s 2010 VSM legislation.