Abstract
This paper begins by outlining the concept of multi-level environmental governance, as it will be used for the purpose of considering the three potential responses available to central government. This is followed by a brief discussion of the constitutional context within which this conflict over GMO regulation is occurring. The specific factual and legal background is then introduced. This provides the basis for discussion of three possible responses available to central government. In respect of each of these responses, this paper considers what they reveal about the current state of multi-level environmental governance in New Zealand. This paper concludes by making some general observations about sustainable development in New Zealand which, it is suggested, underpin central government's approach to GMOs.
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