From BBC comedy Yes Prime Minister, a discussion between the fictional Prime Minister and Sir Humphrey, his most senior civil servant:
PM: “Who is it who has the last word about the government of Britain ? The British Cabinet or the American president?
H: “You know it’s a fascinating question. We often discuss it.”
PM: “What conclusion have you arrived at?”
H: “Well, I must admit to being a bit of a heretic. I think it’s the British Cabinet, but I know I’m in the minority.”
As the UK general election approaches tomorrow it has been interesting to watch the reaction in the US to the first televised debates between the party leaders during the campaign.
Hendrik Hertzberg at the New Yorker wrote :
“I was struck by how superior this event was to its typical American counterpart, in a number of ways:
– the crispness and clarity of the debaters.
– the businesslike, non-preening moderator, David Dimbleby—the Brits, it seems, still have a Cronkite.”
Jon Stewart took the opposite tack and pointed out in his own inimitable style that the UK was a rookie at democracy as the debates had 76 rules of engagement including:
“Maximum three Churchill quotes,” “no insulting participants’ 15th century ancestors,” “no headlocks,” “the Queen’s Corgi must be given equal time,” and “no Hitler costumes.”
In the UK we have extension coverage of the US presidential elections – from the potential candidates in the primaries, to the primaries themselves and then the election results being covered heavily by all the newspapers and TV channels . But despite all of this, it wasn’t until I moved to the US that I became fully aware of the huge differences between the two democracies. As with English, the two systems of government have a lot less in common that I thought :
– timing
In the UK general elections must be held at least every five years and the Prime Minister gets to choose when they happen. Gordon Brown did not formally announce the current election until April 6 so actual campaigning is just a few weeks – in contrast to the months-long US system of primaries and caucuses.
However, since witnessing the last presidential primaries at first hand, I have found myself favouring the more open and transparent way in which the US people get to choose their candidates. In some way, the strenuous campaign may be necessary in order to prepare someone to lead a country that is so huge and diverse.
In the UK the process is called a general election because Parliament is dissolved and every seat in the House of Commons becomes vacant. I had mistakenly assumed that Americans would vote for the House of Representatives and the Senate at the same time as they chose their president.
However all 435 members of the House, who are divided amongst the states in proportion to their populations, are up for election every two years giving them little time to actually achieve anything. Each state, regardless of population, also has two senators who serve staggered six-year terms so that roughly one-third of the 100 senators face re-election every two years – as a result US politicians seem to spend far more time raising money than governing.
– money
And speaking of money, UK politicians can only dream of being able to spend as much in the US where Michael Bloomberg can get through $15,000 dollars an hour to become the Mayor of New York City.
Registered parties in the UK are restricted in their spending for the 365 days before a general election to a maximum of £30,000 for each seat they contest – or £19.5m if they fight every constituency. One of the reasons the UK parties need far less money is because they are not allowed to advertise once an election has been announced. In contrast, the US Supreme Court has controversially rolled back the limits on how much corporations can spend on political ads, which multiply during US elections from not only the candidates but also special interest groups – thankfully something we don’t see in the UK as political ads and issue campaigning have always banned from TV and radio.
– religion
Another striking difference is the use of religion by the candidates when they campaign for public office. In the UK senior bishops from the Church of England have seats in the House of Lords but despite this, religion is considered a private affair and not relevant when running for office. Nick Clegg has admitted that he does not believe in God and no-one bats an eyelid. I find it ironic that in the US, where religion and the state are allegedly separated by the Constitution, the same admission would pretty much disqualify any candidate running for the Presidency.
– time between winning and appointing an administration
The day after a general election, assuming that one party wins a majority of seats in the House of Commons, the Queen invites their leader to become prime minister and form a government so they can actually start governing. In the US elections are in November but the inauguration of the next President is not until January and the new administration then spends months getting appointments through the Senate.
It may be hard for those outside the US to believe, but even last month, more than a year after President Obama was inaugurated, the Republicans blocked votes on 97 federal nominees leaving a backlog of 101 Administration appointments. It strikes me there can sometimes be too much democracy as I don’t see why every Tom, Dick and Harry needs to be approved by the Senate before they can start work.
– ability to pass legislation
Overall, I still prefer the parliamentary system as it usually enables the party who wins more than half of the seats in the House of Commons to actually pass the legislation that UK voters have decided they want. Ironically this year no single party may win an overall majority leading to a hung parliament.
As Simon Schama writes in The New Yorker:
“Though early signs of Clegg fatigue may be showing, and though in the debate he, unlike the others, refused to stoop to the popular immigrant bashing, his party seems on course to gain a bigger share of the popular vote than Labour and enough seats to deny the Conservatives a parliamentary majority.
If that holds, we will find out whether Clegg—whose party, under the current system, will be awarded proportionately far fewer seats than either of the others—has the stuff of the revolutionary parliamentarian Oliver Cromwell in him (minus the disagreeable beheading of the monarch).”
A hung parliament could lead to the legislative gridlock that you see in Washington DC as a president who wins the majority of the public vote and with a majority in both the House and the Senate still has trouble passing legislation. Thanks to the filibuster 41 senators, even if they represent the states with the smallest populations, can block any bill leading to what critics have called the tyranny of the minority.
But whatever system is used, Winston Churchill, summed it up perfectly in a speech to the House of Commons in 1947:
“Many forms of government have been tried and will be tried in this world of sin and woe. No one pretends that democracy is perfect or all-wise. Indeed, it has been said that democracy is the worst form of government except all those other forms that have been tried from time to time”
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