Submission to NALI (in full)

Submission to the National Archival and Library Institutions Ministerial Group


The Alexander Turnbull Library (New Zealand’s foremost library for research in the humanities, and the beating heart of the National Library of New Zealand Te Puna Mātauranga o Aotearoa) is an important cultural institution which houses much of the taonga and documentary heritage of New Zealand, and which makes a hugely significant contribution to both the national identity and the international profile of New Zealand.  We submit that the National Library (along with the Alexander Turnbull Library) needs independence to do its job properly.

Under the control of the Department of Internal Affairs (DIA):

  • the Library is starting to lose its status and identity as a world-class research institution;
  • as a subset of the Information and Knowledge Services branch of the DIA, the Library’s fundamental decision-making (including decisions on its spending priorities) is compromised, and the standing of the National Librarian and the Chief Librarian has been downgraded to third- and fourth-tier managers.
  • the flow of public donations to build the collections is starting to dry up.
  • over the period 2014—2018, the appropriation for Vote Internal Affairs has increased 20% to be $684.97 million, while the appropriation for “Managing and Accessing Knowledge Information,” the output class which includes spending on the Turnbull Library, has declined 5.21%.
  • this year’s Budget reduced the appropriation for Library collection and preservation functions by a further 1.5% (Vote: Internal Affairs).


The State Services Commission (SSC) has recognized that the National Library has a role that is of “national strategic importance for the government and public of New Zealand”, in similar vein to the Museum of New Zealand Te Papa Tongarewa and the New Zealand Symphony Orchestra (NZSO).  So why not a similar independent legal status for the National Library and the Alexander Turnbull Library?

We submit that the National Library should be removed from the control of the DIA and given a new legal status, similar to that of Te Papa and the NZSO, as an Autonomous Crown Entity under the Public Finance Act. This is necessary to begin restoring public confidence and trust in the Library’s role and functions, alongside achieving vastly improved transparency and democratic accountability, and thus ensuring the effective care and protection of New Zealand’s documentary heritage and taonga.

We urge that the necessary legislative action be enacted in time to coincide with the centenary in 2020 of the formal opening of the Turnbull Library in 1920.



(1)             The present Government’s clear policy statements that it will remove Archives and the National Library from Internal Affairs, and that it will investigate the Chief Archivist becoming an Officer of Parliament, are to be applauded. Both institutions have suffered badly since the ill-informed 2010 amalgamations. But we are under no illusions that these objectives will be easily achieved. There is already considerable evidence of bureaucratic ‘fight-back’, and the terms of reference for the present Ministerial review are somewhat more equivocal than Labour’s pre-election policy statement might have suggested.

The Alexander Turnbull Library

(2)             The Alexander Turnbull Library was opened in 1920, following the bequest of Alexander Horsburgh Turnbull on his death in 1918 to His Majesty the King. He bequeathed his collection of manuscripts, books, drawings, paintings, incunabula, maps, photographs to form “ …the nucleus of a New Zealand national collection”(Second codicil to the will of Alexander Horsburgh Turnbull).

(3) Since its inception, the Turnbull Library has grown in size, depth and comprehensiveness of its collections, the expertise of its curatorial staff and the volume and diversity of research and publications from its collections. It continues to build on its high reputation nationally and internationally as the foremost heritage research library in the country, and its collections are currently valued at $1.053 billion.

(4) The breadth and depth of the Turnbull’s collections must be emphasized:

  • It has New Zealand’s largest collection of artworks documenting the settlement of New Zealand; the published collections aim to contain every work written about New Zealand, by New Zealanders and/or published in New Zealand.
  • Its collections in media other than print and manuscript include photography, maps, charts, music, newspapers and oral history.
  • Its collections of digital materials are growing rapidly and will be New Zealand’s most comprehensive digital collection in the same way as its published print collections now are.
  • Its collections of Māori language and literature materials are unique and of fundamental importance in the evolving history of the peoples of New Zealand under the Treaty of Waitangi.
  • The rare books collection is not only internationally valuable but is internationally recognized and used by scholars throughout the world.

(5) The Turnbull, in other words, maintains and provides access to resources essential to a very wide spectrum of academic and public research on the humanities and cultural New Zealand, comparable to the research activities applied to natural New Zealand by the Crown Research Institutes.

(6) More generally, the National Library, and the Alexander Turnbull Library in particular, are important cultural institutions that house much of the taonga of New Zealand and which contribute to the national and international profile of New Zealand. By doing so they, in effect, provide a secure laboratory where experienced librarians and researchers interact to evaluate, digest and consolidate the raw evidence into publications in a range of media that provide ready access for the public to our cultural history and profile.

The cost of losing Independent status in the 2010 merger

(7) Since the transfer of responsibilities for the National and Turnbull Libraries to the DIA, the national and international profiles of the Libraries has been significantly damaged. The Libraries’ independent identity has increasingly been lost as they have become merely subordinate business units within the DIA whose focus has to be directed to such things as gaming control and the issuing of passports, expenditure on which is nearly 60% greater than the spending on Libraries. The lack of an independent legal status for both the National Library, and especially the Turnbull Library, who should be “contributing to a literate, participative community” does not sit well with the ongoing independent legal status of other important cultural institutions, such as the Museum of New Zealand Te Papa Tongarewa, and the New Zealand Symphony Orchestra (NZSO), which likewise serve the interests of the wider community rather than just the narrow transactional interests of government.

(8) Furthermore, being but a sub-set of the Information and Knowledge Services branch of the Department of Internal Affairs — the ”epicentre of information management, culture and heritage” — results in the National Librarian of New Zealand being a lowly third-tier manager and the Turnbull Librarian being only a fourth-tier manager within the DIA hierarchy, subject to the possibility of bureaucratic rather than professional direction. This means that they do not have the independence and authority to carry out fully the responsibilities of their positions. That can only be restored by removing them from under the control of the DIA and giving them stand-alone legal status.

(9)  In similar vein the Chief Archivist should be established as an Officer of Parliament in order to give the role sufficient authority to control fully and shape proper archival processes within government.  Archives are primarily the keeper of the public record, the memory of government, a constitutional role by which the actions of governments are recorded and evidence of the entitlements and rights of citizens is safeguarded.  The responsibilities of the Chief Archivist are analogous to those of the Auditor-General.  The secondary role of Archives is to reinforce the role of research libraries such as the Turnbull as a primary repository for research relating to history, culture and identity.

(10) New Zealand’s ‘brand’ emphasizes excellence. It is about our reputation as a world-class centre of research and scholarship, of academic integrity and academic independence. To maintain that reputation we must have institutions that themselves have world-class reputations. And you don’t get that by making those institutions part of a brand called “Department of Internal Affairs”, and their leaders third- or fourth-tier managers with a email address.

(11) Increasing concerns are also emerging as to the Collection-building experience of the Turnbull. In the past, donations of material to the collections represented about 50% of the value of new materials deposited each year. Without public support, which can be said to depend on the absolute assurance of the independence of the library in the management of its collections, this source of national heritage materials has been drying up. It would seem, therefore, that public trust in the identity and integrity of the Turnbull can no longer be taken for granted. This is compounded by a heightened tendency for the Turnbull to reject materials and personal papers that have been offered to them by prominent New Zealanders.

The importance of democratic accountability

(12) Before the 2010 merger the National Library was in receipt of a specific vote of monies within the yearly Government Budget. Despite repeated Ministerial promises of maintaining a separate Vote for the Library and the requirement that the National Library publish a separate Annual Report, both quickly disappeared and the Vote and Annual Report obligation were subsumed within that of Internal Affairs.

(13) The existence of an independent Vote is important simply because under the Public Finance Act 1989 monies can be moved around within a Vote and be transferred between output classes to some degree, but monies cannot be transferred between Votes. Having a separate Vote, therefore, is a source of financial independence and a financial safeguard. Those have now disappeared.

(14) Recent pronouncements by both the Minister and Senior DIA managers have suggested that a continuation of the present legal and structural arrangements are necessary because the DIA “needs the money”. This is disturbing since it implies that monies have been, and may in the future, be transferred, by various creative accounting means such as overhead re-allocations, away from the Libraries to other DIA functions and activities in possible breach of the Public Finance Act. The absence of a clear appropriation for Libraries means that there can be no public assurance, or safeguards, as to the financial independence and finances of the National and Turnbull Libraries.

(15) It is worth noting that while the recent Budget increased Core Government Expenses by around 6%, the appropriation for Library collection and preservation functions, was reduced by 1.5% (Vote: Internal Affairs, Departmental Output Expenses, B.5 Vol 5 p 135).

(16) In a broader context, over the period 2014—2018, the appropriation for Vote Internal Affairs has increased 20% to $684.97 million, while the appropriation for “Managing and Accessing Knowledge Information”, the output class which includes spending on the Turnbull Library, has declined 5.21%, which gives weight to the concern about the neglect that the Turnbull has come to suffer under the DIA’s control.

(17) Interestingly, while in the 2018 Budget documents it is possible to locate a line item for “Managing and Accessing Knowledge Information”, in the actual Bill put to Parliament to authorise the expenditure included in Vote Internal Affairs, spending on the Libraries and Archives is lumped together with the spending on Passports, Births, Deaths and Marriages, Citizenship and the publication of the New Zealand Gazette, in a new category of “Civic Information Services”. Transparency and full disclosure at its finest!

(18) In terms of accountability, within the 2017 Annual Report of the DIA, for example, the National Library barely gets a mention and the financial dimensions of the Turnbull Library, in particular, are well buried and are really available only to highly skilled financial analysts. In a 189-page Annual Report, only two pages disclose financial information on the Turnbull’s collections. The Turnbull Library and its collections are legally part of the DIA but are not carried on the DIA’s Balance Sheet. Instead they are reported as ”Non-departmental Assets managed on behalf of the Crown” and included in the separate Crown Balance Sheet. The use of the phrase “Non-departmental Assets managed on behalf of the Crown” suggests a clear contradiction as to the role, operational, and legal status of the Turnbull Library within the DIA, as well as significant operational confusion as to the supposed “national strategic importance of the National Library” that was used by the SSC to justify the 2010 merger.

(19) In this context, it is worth noting that at $1.053 billion, the value of the Turnbull collections is $106 million greater than that of Te Papa Tongarewa the Museum of New Zealand, which has both a separate legal status and a separate Board and publishes a full detailed Annual Report devoted to its activities.

(20) On a wider canvas, it is difficult to locate the Annual Report, or for that matter, any report, from the Guardians of the Alexander Turnbull Library, who are supposed to be the Guardians Kaitiaki of the health and well-being of the library for the Public of New Zealand. The Guardians report to the Minister, but not to the public since their reports are not deemed to be public documents, and are not published by Parliament. At least one previous Minister made it clear to the Guardians that if any report was critical then he would refuse to see them or talk with them! And, of course, the former right of the National Librarian, or the Turnbull Librarian, to have direct access to a Minister Responsible for the National Library has been eliminated, since this separate Ministerial responsibility has disappeared. Instead, the responsible minister is the Minister of Internal Affairs (who in the previous administration was not even a member of Cabinet), and both Librarians, as noted above, sit at a lower level in the departmental hierarchy.

(21) The National Library is focussed on three themes of “Turning Knowledge into Value” – taonga, knowledge and reading — and their interrelationship is said to be fundamental to the purpose and future operation of the Library. According to the Major Strategic Review of the Library, the future will require substantial investment

  •  in robust technology,
  • in leadership capability,
  • and, essentially in the digital age, in leading and supporting national efforts in digitisation at scale,
  • in capturing born-digital material, making these resources universally available through a range of effective networks, and
  • in actively encouraging and participating in creative reuse.

(22) But while new digital strategies are necessary to collect records that are “born digital”, the necessary resources will continue to be required to allow true access to centuries of records that are not digital and never will be. Digitisation, therefore, is not and never will be, the prime driver of research libraries such as the Alexander Turnbull Library, or of national archives. Furthermore, even with the advent of records that are “born digital” it will be a very long time before information “held within the on-line domain” predominates over that which is not within that domain.

(23) It is also worth noting that Parliament’s Governance and Administration Committee in its July 2018 review of the Estimates for Vote Internal Affairs said that a key objective of the newly formed National Archival and Library Institutions Ministerial Group would be to better store, preserve, manage and increase access to information through digitisation, and that the Committee “concurred that digitising New Zealand’s precious archives is a commendable goal, but wondered how successfully this could be actioned considering that there is minimal ongoing funding available for this.”

(24) Government may fund the National Library and the Alexander Turnbull Library, but the essential relationships that the Libraries have are with their users and stakeholders, rather than with Government. Digitisation and the financing of new technological developments are financial matters that are best addressed through the parliamentary budgetary process. They did not in 2010 require a structural or constitutional solution, and history has shown that they do not require the continuation of that solution. Whatever the constitutional form and structure of Archives and Library, these financing issues have continued (as the Governance and Administration Committee have noted in their 2018 Report), and will continue; and they will therefore always need to be addressed through the yearly parliamentary budgetary process. The budgetary process can require particular outputs and outcomes and therefore ensure that technological and services collaboration, and back-office cost-sharing arrangements are implemented, along with necessary and appropriate levels of funding.

The need for independence

(25) To ensure their independence, and their ability to exercise an ownership and stewardship role rather than just a policy or operational one, the structural position and legal status of the National Library and the Alexander Turnbull Library need to be addressed. In a 2010 Paper the SSC acknowledged that:

The purpose of the National Library is ‘to enrich the cultural and economic life of New Zealand and its interchanges with other nations by, as appropriate,

  1. a) collecting, preserving, and protecting documents, particularly those relating to New Zealand, and making them accessible for all the people of New Zealand, in a manner consistent with their status as documentary heritage and taonga; and
  2. b) supplementing and furthering the work of other libraries in New Zealand; and
  3. c) working collaboratively with other institutions having similar purposes, including those forming part of the international library community.’

 This statement of purpose describes a role that is of national strategic importance for the government and public of New Zealand.”

(26) The same things could, be said of Te Papa and the NZSO, and their national importance for and to the public of New Zealand.  Yet both Te Papa and the NZSO have a legal status as Autonomous Crown Entities under the Public Finance Act, a status that they also share with:

  • Arts Council of New Zealand Toi Aotearoa
  • Heritage New Zealand Pouhere Taonga
  • New Zealand Film Commission

(27) The obvious question that arises, therefore, is why not a similar independent legal status for the National Library and the Alexander Turnbull Library?

(28) Such a status — as an Autonomous Crown Entity, legally separate from the Crown — would recognize the rights of the public to shape, build and control the taonga and heritage that belong to them and to which they contribute. Governance, should be awarded to a Board of Trustees representing the people of New Zealand and the interests of iwi, scholars, librarians, and community, with a retired Governor General, perhaps, being the Chairperson of the Board in order to recognize and acknowledge, the mana the board should have as the storehouse of the nation’s taonga, and the concerns and values of the wider community. In this context it is appropriate that we remind ourselves that Alexander Turnbull made “…The most generous bequest to the people of New Zealand ever made by a New Zealander since the beginning of New Zealand time” (New Zealand Times, July 1918) — not to the Government, but to the people of New Zealand.

(29) To the extent required, Government influence over the Libraries, in both their policy development and collecting roles, could still be provided by:


  • Funding through the Estimates process
  • Power to appoint board members
  • Power to remove board members
  • The requirement that an entity must “have regard to” policy that relates to the entity’s functions and objectives if directed by the responsible Minister
  • Power to set direction and annual expectations
  • A whole-of-Government approach which they must “give effect to” if directed by Ministers of Finance and State Services
  • The requirement that the responsible Minister alone can answer to Parliament for the performance of the entity.


(30) In conclusion, we submit that this proposed change in the legal status of the National Library of New Zealand Te Puna Mātauranga o Aotearoa (and the Alexander Turnbull Library, in particular) could well be timed – most appropriately – to coincide with the centenary in 2020 of the formal opening of the Turnbull Library in 1920.