Some have argued that the treaty should be further incorporated as a part of the New Zealand constitution, to help improve relations between the Crown, Māori and other New Zealanders. The Fourth Labour Government's "Bill of Rights White Paper" proposed that the treaty be entrenched in the New Zealand Bill of Rights Act 1990. This proposal was never carried through to the legislation, with the attitude of many Māori towards it "suspicious, uneasy, doubtful or undecided". Many Māori were concerned that the proposal would relegate the treaty to a lesser position, and enable the electorate (who under the original Bill of Rights would be able to repeal certain sections by referendum) to remove the treaty from the Bill of Rights altogether. Geoffrey Palmer commented in 2013 that: