US Political System Vs. British Parlimentary System

[paximperium]

So, I am pretty familiar with the US political system of the Executive, Judiciary and legislature with is checks and balances(as imperfect as they are).

I am less familiar with the Parliamentary System practiced by most of the world(British model vs. other European models). I understand that the Executive and legislature is not as separate since if I understand correctly, you vote for the party and the party selects the Prime Minister as opposed to the US system.

I would like to start a discussion on the pros and cons of both systems for a little education in both systems.

[gtc]

Originally Posted by paximperium

I understand that the Executive and legislature is not as separate since if I understand correctly, you vote for the party and the party selects the Prime Minister as opposed to the US system.

We usually vote for a candidate who may or may not be a member of a political party. There are exceptions (such as NZ and I think Scotland).

Under the Westminster system, the leadership positions (usually referred to as Prime Minister and Cabinet) are technically appointed by the Crown (or President if it is a republic) on the understanding that they enjoy the support of a majority of the lower house of parliament (equivalent to Congress). The lower house can vote to oust the Prime Minister.

At least in Australia, the Prime Minister is traditionally a member of the lower house of parliament with the Cabinet made up of members of the lower or upper house (Senate). I do not know if this is the case elsewhere.

[paximperium]

Does that mean in Australia, you actually do vote for the Head of State(I thought the Queen was the head of state?) while the Head of the Government(ie. Prime Minister) is technically appointed from the ruling party?

[geni]

Originally Posted by paximperium

I would like to start a discussion on the pros and cons of both systems for a little education in both systems.

On the pluss side under the UK system it is fairly easy for the goverment to get things done on the minus side it is fairly easy for the goverment to get things done.

Under the UK system less problems working out who to blame and earmarks are less common. On the other hand it is much harder to kill bad legislation that has got someone's ego attached to it.

Under the UK system ministers can be dirrectly questioned by parliment on a regular basis. The catch being that most work out how to deal with this.

One other big difference that isn't parliment based is the civil service. A lot of positions that in the US are filled by presidential apointments are in the UK filled by career civil servants. Diplomats are in some ways a rather extreme example of this.

On one hand this means that the civil service tends to be more political neutral and suffers less from the problem of people being there because the president owes them a favor. On the other hand the tallent pool is somewhat smaller (although I don't think this has been suggested as a problem in the case of the diplomatic service).

[gtc]

Originally Posted by paximperium

Does that mean in Australia, you actually do vote for the Head of State(I thought the Queen was the head of state?) while the Head of the Government(ie. Prime Minister) is technically appointed from the ruling party?

Not quite.

We have elections for the House of Representatives and the Senate. They are almost the same as American elections.

The Governor General (on behalf of the Queen) asks the leader of the party with the most members of the House of Representatives to form a government (i.e. become Prime Minister and appoint a cabinet from members of the House of Reps and the Senate). If the party has more than half the members of the House of Reps then there is no problem. In NZ and Canada at the moment, the Prime Minister doesn't have half the seats so he relies on members of other parties not to vote against him. See how it works, technically the Governor General appoints the Prime Minister on the understanding that the Prime Minister to be has the support of the lower house of parliament which means that the lower house won't vote against him or her.

The Governor General is appointed by the Queen on the advice of the Prime Minister of the day. Their role is almost entirely ceremonial unless it looks like the Prime Minister has lost the support of the House of Representatives.

Elections to the House of Representatives are held every three years or sooner (our terms aren't fixed but some states and countries do have fixed terms). The number of members of the House of Representatives varies by state according to population (but the smallest state gets more than it deserves). Voting is by instant run-off with one member per electorate (like district in the US).

Elections to the Senate are held at the same time, but new Senators have to wait several months as we do have fixed terms for the Senate. There are six senators elected per state every three years and they are elected for six years each. Elections are by a form of proportional representation.

[Zelenius]

Under the parliamentary system in Britain(or Canada, Australia), who is Commander in Chief of the military? How are their powers different from that of the American president?

How easy is it to remove lousy Prime Ministers? And what are the highest offices that a Prime Minister can appoint people to? I understand that they have fewer people to appoint due these positions being non-appointing positions, as they rise up through the civil service(I didn't realize this until I read this threat). For instance, we have a secretary of defense, secretary of commerce, secretary of state, among many other positions the president appoints his people to(far below these offices though, we have the same people working there regardless of who gets appointed). The president also appoints the justices of the Supreme Court(the judicial branch of government). Justices serve for life unless they retire.

One thing I like about the parliamentary system especially in the U.K is how the executive branch and legislative branch of government are not as separate as they are in the U.S. Under a more authoritarian president, they can use this separation to centralize too much power in the executive branch. Indeed, one of the more disturbing developments of Bush's 8 years in office have been his expansion of the powers of the executive branch, in ways that would seem borderline dictatorial("I am the decider") in much of western Europe. Even many people in Bush's own party were against this. Hopefully this neoconservative experiment is over.

[Phaedrus74]

In the Netherlands the seats of the "2e Kamer" (House of Representatives/House of Commons) are up for election every four years (sooner if the government falls).

Since there is a multi-party system in place the Head of State (currently the Queen) appoints someone to survey the new political landscape for viable coalitions (combination of parties that have a combined number of seats of 76 (50% + 1) and are willing form a government together).

After the initial survey a "formateur" is appointed (by the Head of State) who will then try to broker an agreement between the different parties to form a coalition. "Broker" should be taken extremely literally, Party A wants X and Party B wants Y? Fine, deal. Party A wants X but does not want Y? Also fine but Party B will demand Z. These negotiations will go on for several weeks (months) and result in a governing-agreement covering sometimes in detail the specifics of government policy for the coming 4 years.

A government will fall if it gets a vote of "no confidence", since the coalition parties hold at least a simple majority this requires that at least some members of a coalition party are "uncomfortable" with government policies or the performance of a particular minister. If this happens new general elections follow and the whole merry-go-round starts up anew.

The seats of the "1e kamer" (Senate/House of Lords) are not subject to direct democracy, these are subject to elections held in the "Provinciale Staten" (the elected "parliaments" of the provinces of the Netherlands (f.i. North- and South-Holland, Friesland &c.)....

[gtc]

Originally Posted by Zelenius

Under the parliamentary system in Britain(or Canada, Australia), who is Commander in Chief of the military? How are their powers different from that of the American president?

In Australia it is the Governor-General acting on behalf of the Queen. In the UK I think it would be the Queen directly.

The political control is, however, exercised by the Defence Minister and the Prime Minister.

Originally Posted by Zelenius

How easy is it to remove lousy Prime Ministers?

There are several ways this can happen.

Firstly, they can lose a confidence vote in Parliament. If someone else wins one, they take over as the new PM.

Secondly, they may be able to call an early election to try to get a mandate.

Thirdly, the Queen or Governor-General can intervene to sack the PM and appoint someone else who would have the confidence of Parliament or as a care-taker prior to an election. This would be rare and might be unconstitutional depending on the country. I think it has only happened once in Australia (the Dismissal of 1975).

Originally Posted by Zelenius

And what are the highest offices that a Prime Minister can appoint people to? I understand that they have fewer people to appoint due these positions being non-appointing positions, as they rise up through the civil service(I didn't realize this until I read this threat). For instance, we have a secretary of defense, secretary of commerce, secretary of state, among many other positions the president appoints his people to(far below these offices though, we have the same people working there regardless of who gets appointed).

The names differ from place to place but the Prime Minister appoints his cabinet from the House of Reps and Senate in Australia (may differ overseas). These people are Ministers - so we have the Minister of Defence who exercise political control over the defence forces. They are roughly equivalent to your secretaries of defence etc.

We also have positions with names like Secretary of Defence but these are the senior public servants and so are below the Ministers. In theory these aren't political appointments and usually these people come up through the civil service or the like but they can be recruited from outside. The degree to which these are non-political positions is, I think, eroding.

Originally Posted by Zelenius

The president also appoints the justices of the Supreme Court(the judicial branch of government). Justices serve for life unless they retire.

Again, I think these are appointed by the Queen or her representative on the advice of the Prime Minister and (I think) the judiciary. There is a mandatory retirement age in Australia.

[Damien Evans]

Originally Posted by gtc

In Australia it is the Governor-General acting on behalf of the Queen. In the UK I think it would be the Queen directly.

The political control is, however, exercised by the Defence Minister and the Prime Minister.



There are several ways this can happen.

Firstly, they can lose a confidence vote in Parliament. If someone else wins one, they take over as the new PM.

Secondly, they may be able to call an early election to try to get a mandate.

Thirdly, the Queen or Governor-General can intervene to sack the PM and appoint someone else who would have the confidence of Parliament or as a care-taker prior to an election. This would be rare and might be unconstitutional depending on the country. I think it has only happened once in Australia (the Dismissal of 1975).




The names differ from place to place but the Prime Minister appoints his cabinet from the House of Reps and Senate in Australia (may differ overseas). These people are Ministers - so we have the Minister of Defence who exercise political control over the defence forces. They are roughly equivalent to your secretaries of defence etc.

We also have positions with names like Secretary of Defence but these are the senior public servants and so are below the Ministers. In theory these aren't political appointments and usually these people come up through the civil service or the like but they can be recruited from outside. The degree to which these are non-political positions is, I think, eroding.



Again, I think these are appointed by the Queen or her representative on the advice of the Prime Minister and (I think) the judiciary. There is a mandatory retirement age in Australia.

Also, a PM can be voted out by his own party and replaced by a new guy if he manages to piss off the backroom too much.

[gumboot]

New Zealand is a constitutional monarchy with a single House.

Our Head of State is HM Elizabeth II, Queen of New Zealand. It is often mistakenly said that our Head of State is the Queen of the United Kingdom, however this is false - the positions of Queen of New Zealand and Queen of the United Kingdom are totally independent (though currently held by the same person). Theoretically two different people could hold each position, and theoretically the UK could declare itself a republic and Elizabeth II would remain our Monarch.

Because our Head of State does not live in New Zealand, she designates a representative - the Governor-General - who acts in her place. Typically the monarch will nominate a Governor-General based on the advice of the current Prime Minister.

The House is democratically elected under a system called MMP which even most New Zealanders don't understand.

Basically, every three years we have a general election, in which you get two votes. The first vote is for a candidate to represent your electorate in the House of Representatives. Most candidates belong to a major party however both independents and members of minor parties can be voted for.

In addition, you have a party vote, which determines what percentage of seats in parliament a given party will have. There is no requirement to vote for the candidate that is standing for the party you vote for.

Somehow this is all calculated out in terms of how many seats each party gets in parliament. For a party that does not win any electorates, they must reach a 5% threshold to gain a seat in parliament. For parties that win at least one electorate, there is no threshold.

There are two types of seat in parliament: electorate seats, which are won by the candidate vote, and list seats, which are won by the party vote.

Each party has a "list" which ranks their members in order of preference, and list seats are allocated in sequential order to those on the list, giving them the name "list MP". Often, the higher members on the list will win electorates and so take their electorate seat, and everyone else moves up the list.

In theory there are 120 seats in parliament, however due to these two systems of seat allocation you can have "hanging seats" - the current New Zealand parliament consists of 121 seats.

Theoretically, were one party to win all of the electorate seats, and another party to win 100% of the party vote, you would end up with an enormous parliament with a large number of hanging seats.

Once an election has occurred, the leader of the major party will announce to the Governor-General that they hold the confidence of parliament and have sufficient majority to pass motions of confidence and motions of supply. Due to our new system, typically no one party will have a majority, and the leader of the largest parties will have to seek confidence and supply agreements with minor parties to form a coalition government.

The Governor-General will then appoint the leader of the majority party as Prime Minister.

The Prime Minister then selects the members of their cabinet and their ministers. Under MMP the tradition has been for coalition partners to be allocated ministers outside of cabinet so they they can vote against the government on issues important to them - retaining some independence.

Ministers are allocated various posts overseeing aspects of the running of the country such as the Ministry of Education and the Ministry of Social Development. Not all of the government sectors are called ministries - for example the Department of Labour and the New Zealand Customs Service. I must confess I have no idea if these naming differences are significant or not.

The primary task of the House of Representatives is to pass legislation, and any member can present a Bill, however the government has control over the schedule for the House, and will typically shelve unwanted Member's Bills to the very end of a schedule as a delaying tactic.

In order to oversee legislation, there are eighteen Select Committees which include members from all parties. In addition they can call on public consultation for legislation.

The Police and Military directly serve the Monarch and swear their allegiance to the sovereign. Theoretically, at least, neither the military nor police can be used by a corrupt government to seize control as the Head of State could direct the military or police to remove the government by force if necessary.

By constitutional convention, both the military and police have independence from the government, although a government minister for each represents them in parliament, and there is a civilian Ministry of Defence which oversees administration of the Defence Force (no such ministry exists for the police).

The judiciary is headed by the Chief Justice (who is head judge of the Supreme Court) who is appointed by the Governor-General at the advice of the Prime Minister of the day. Of note is that law enforcement (the police) is distinctly separate from the Judiciary (Ministry of Justice) and prisons (Department of Corrections) are separate again.

So...

Executive - The Crown
The Crown is an abstract entity - a corporation sole and an artificial person. It is not the Sovereign, but "The Crown" who rules, and all government action is carried out in the name of the corporation. (For example a court case will be The Crown Vs. Mr Smith). It can be seen in the same way as the legal entity "The United States". However in terms of practical day-to-day activity, civil servants represent the crown, and are directed by ministers who are from the government.
"Officers of the Crown" (including police, customs officers, tax collectors, military officers, etc...) directly serve the interests of the Corporate and their powers (which vary dependent on their role) are issued by the Sovereign in the form of a Royal Warrant.

Legislature - The House of Representatives
Democratically elected, however the House is essentially controlled by the majority party who form the government.
Both the government and the opposition are in service to the Crown and swear allegiance to it - the opposition is officially termed "Her Majesty's Loyal Opposition".

Judiciary - Ministry of Justice
Although a government ministry overseen by a member of the government, technically independent, with allegiance to the Crown.

The Crown has only very limited powers - for example the power to dissolve parliament. These would generally only be used in the most extreme of cases because only parliament can raise taxes, and without taxes the entire government grinds to a halt.

I hope that makes some sense.

[JAStewart]

We can both probably learn from our respective systems. I think that Britain's incumbent party's ability to call an election whenever they want is anti-democratic.

[Phaedrus74]

Originally Posted by JAStewart

We can both probably learn from our respective systems. I think that Britain's incumbent party's ability to call an election whenever they want is anti-democratic.

Why? It is a referendum on current policies, on the face of it it seems very democratic...

[geni]

Originally Posted by Zelenius

Under the parliamentary system in Britain(or Canada, Australia), who is Commander in Chief of the military?

The Queen

Quote:

How are their powers different from that of the American president?

Now now hitting the difference between what can be done in theory (the queen can declare war in practice no) in practice (the prime minister can delare war) and what people chose to do (the prime minister may well take the matter to the house in any case for the look of the thing).

The queen or her representative can disolve parliment although in theory that should only happen at the request of the prime minister. In Australia theory didn't quite work out.

Quote:

How easy is it to remove lousy Prime Ministers?

Would require a vote of no confidence (which is tricky since generaly the Prime Minister's party or his party and it's allies tend to have a majority). Sometimes he can be removed by the party (it depends on the party) or he faces election with all the other MPs (although they tend to be in a very safe seat so probably less effort to remove their party from power) will in the UK at least once every 5 years

Quote:

And what are the highest offices that a Prime Minister can appoint people to? I understand that they have fewer people to appoint due these positions being non-appointing positions, as they rise up through the civil service(I didn't realize this until I read this threat). For instance, we have a secretary of defense, secretary of commerce, secretary of state, among many other positions the president appoints his people to(far below these offices though, we have the same people working there regardless of who gets appointed).

The top people are done in much the same way. Minster for defence, minister for trade Etc. Its the levels below that are civil servants.

Quote:

The president also appoints the justices of the Supreme Court(the judicial branch of government). Justices serve for life unless they retire.

Actualy that's one thing the prime minister can't do. I think that would mostly fall under the Lord Chief Justice of England and Wales until recent changes would I think have fallen within the power of the Lord Chancellor. The Lord Chancellor position was rather powerful (head of the judiciary, cabinet minister and the equiverlent of speaker in the house of lords).

Quote:

One thing I like about the parliamentary system especially in the U.K is how the executive branch and legislative branch of government are not as separate as they are in the U.S. Under a more authoritarian president, they can use this separation to centralize too much power in the executive branch.

The prime minister wields rather more power within the system than the president. A prime minister with a strong parlimentry majority has very few checks on their power. Remeber no constitution limiting parliment's powers so parliment can do anything up to an includeing abolishing itself (although no one is quite sure what would happen next). Throw in rather higher levels of party loyalty and US style checks and balances are more limited (there is the house of lords but the commons can abolish that as well).

[Wildy]

Do the British have to have an election after a certain period of time? I know that the Constitution requires the government to call an election after a certain amount of time.

Usually our elections are called earlier then that mark because we don't really like to vote around Christmas.

Originally Posted by paximperium

Does that mean in Australia, you actually do vote for the Head of State(I thought the Queen was the head of state?) while the Head of the Government(ie. Prime Minister) is technically appointed from the ruling party?

No we don't vote for the Head of State.

If I remember correctly the PM is the leader of the ruling party. But I don't know what exactly would happen if the leader of the party isn't elected in to the House of Representatives but his party wins anyway.

[geni]

Originally Posted by JAStewart

We can both probably learn from our respective systems. I think that Britain's incumbent party's ability to call an election whenever they want is anti-democratic.

While it allows parties to try and hold the election when they are least unpopular the electorate can take into account that they are trying that and vote accordingly. Asside from the referendum aspect it also limits the length of political campaining and reduces the chances of an election happening in the middle of an emergency.

[geni]

Originally Posted by Wildy

Do the British have to have an election after a certain period of time? I know that the Constitution requires the government to call an election after a certain amount of time.

Every 5 years although any party waiting the full five years would end up looking seriously weak.

Quote:

If I remember correctly the PM is the leader of the ruling party. But I don't know what exactly would happen if the leader of the party isn't elected in to the House of Representatives but his party wins anyway.

His position would become untenable and he would be expected to step aside. Within the UK you could almost solve the problem by makeing him a lord but it is generaly accepted that it is impractical to have a lord as Prime Minister.

[paximperium]

Originally Posted by geni

While it allows parties to try and hold the election when they are least unpopular the electorate can take into account that they are trying that and vote accordingly. Asside from the referendum aspect it also limits the length of political campaining and reduces the chances of an election happening in the middle of an emergency.

I can definitely see good and bad things about the power in calling for early elections.

Of course the main thing is that allows a significant amount of flexibility when it comes to the ruling party getting their votes when most popular. This would also allow a very unpopular PM to get voted out of office before the end of term(imagine we could've gotten Bush out a few years sooner).

It is impossible to implement a system like that in the US though. Too big a country and the logistics make spot elections impractical.

[paximperium]

Originally Posted by Zelenius

One thing I like about the parliamentary system especially in the U.K is how the executive branch and legislative branch of government are not as separate as they are in the U.S. Under a more authoritarian president, they can use this separation to centralize too much power in the executive branch.

That is why the separation of powers was developed in the first place.

The primary issue with how Bush gained so much power was the ineptitude of the legislature and judiciary. Imagine if Bush had complete control of the legislature and there was no push back...shudder...The separation of powers was developed to be inefficient so that laws move slowly while you have a President with set powers could act on emergencies.

As mentioned, the good thing about the Parliamentary system is the ability to move laws through quickly...and that is the bad thing as well.

Quote:

Indeed, one of the more disturbing developments of Bush's 8 years in office have been his expansion of the powers of the executive branch, in ways that would seem borderline dictatorial("I am the decider") in much of western Europe. Even many people in Bush's own party were against this. Hopefully this neoconservative experiment is over.

I blame this on the legislature and judiciary, not necessarily the system.

[paximperium]

Question:
If a 9/11 incident or any other major disaster(Earthquake in London!!!) occurs in a Parliamentary country,what are the emergency powers of the PM?

[geni]

Originally Posted by paximperium

I can definitely see good and bad things about the power in calling for early elections.

Of course the main thing is that allows a significant amount of flexibility when it comes to the ruling party getting their votes when most popular. This would also allow a very unpopular PM to get voted out of office before the end of term(imagine we could've gotten Bush out a few years sooner).

Not really. An unpopular PM is not going to hold early elections unless forced to by a vote of no confidence. Votes of no confidence are not that common in the UK although may be more common in countries with proportional representation.

Quote:

It is impossible to implement a system like that in the US though. Too big a country and the logistics make spot elections impractical.

India does it from time to time (2004 for example). Size isn't the issue rather the US's rather slow method of selecting candidates and the lack of a perminant high level civil service (the UK's civil service setup also makes it posible for a prime minister with an absolute majority to begin forming a goverment on the morning following the election).

[geni]

Originally Posted by paximperium

Question:
If a 9/11 incident or any other major disaster(Earthquake in London!!!) occurs in a Parliamentary country,what are the emergency powers of the PM?

For 21 days anything that doesn't breach the human rights act. The Civil Contingencies Act 2004 which grants this power is a major liability yes.

[CrikeyBobs]

Originally Posted by JAStewart

I think that Britain's incumbent party's ability to call an election whenever they want is anti-democratic.

I totally agree with that sentiment. This ability can be (and is) used as a political tool (in much the same way that interest rates used to be before the BofE was given a certain amount of independence).

Either parliaments should be of fixed term, or the leader of the house of commons should announce the date of the next election sometime during the first parliamentary session. In either case, the date could be changed only with the approval of the majority of the elected representatives, or if a national emergency is declared.

Maybe I should start a petition on the No10 web site. I wonder if BBC Radio 4 are going to do another "listeners' law" vote?

[geni]

Originally Posted by CrikeyBobs

In either case, the date could be changed only with the approval of the majority of the elected representatives

Which would result in little change from the current situation.

[CrikeyBobs]

Originally Posted by geni

Which would result in little change from the current situation.

I see what you're saying, but at least there would have to be a debate in the chamber, so that would stop misuse, or at least expose it to public scrutiny.

[geni]

Originally Posted by CrikeyBobs

I see what you're saying, but at least there would have to be a debate in the chamber, so that would stop misuse, or at least expose it to public scrutiny.

Questionable. The standard aproach would be to anounce that the election will be held 5 years after the previous then get an act to hold the election before that. The oposition is hardly going to complain too loudly about an early election.

[Seismosaurus]

Originally Posted by Phaedrus74

Why? It is a referendum on current policies, on the face of it it seems very democratic...

I wouldn't call it especially pro or anti the democratic principle as such, but it does have a significant effect on politics. It allows an otherwise unpopular government to cash in on sudden popularity - for instance Bush could have called an election a month or so after 911 when his popularity was at an all time high. You risk the public seeing through it, but Thatcher's big win in 1983 after a largely unpopular few years was widely said to be a result of the "Falklands factor", for instance.

Conversely, if a government knows that the economy is in the process of tanking and next year will be a bad one, they may sneak an election in early. Gordon Brown was widely rumoured to be planning to have an election earlier this year, but backed off it when his party sank in the polls. So it clearly does give the party in power a very significant advantage over the opposition.

Another thing it does, along with other factors, is reduce the length of the election process hugely. British elections are brutually fast affairs compared to American ones; from calling the election to going to the polls typically takes a month or so, but can take less. And once held, the changeover is immediate; the former PM vacates Number 10 literally the morning after the election. We have nothing like the year long campaign of the American system, and that's at least in part due to the fact that often nobody knows they are going to happen until shortly before they do.

[gumboot]

Originally Posted by paximperium

Question:
If a 9/11 incident or any other major disaster(Earthquake in London!!!) occurs in a Parliamentary country,what are the emergency powers of the PM?

In New Zealand Civil Defence is primarily handled by local government, and there are regional Civil Defence Emergency Management Groups maintained by local government who are responsible for providing this service. At least one person in each group must be granted the authority to declare a local state of emergency.

Alternatively, the Minister of Civil Defence and Emergency Management can declare a local state of emergency or (more usually) a national state of emergency.

A state of emergency can be maintained indefinitely, however a given declaration automatically expires after 7 days. When a national state of emergency is declared the House of Representatives must convene within 7 days, at which point they can choose to extend the state of emergency with a new declaration, extending it by a further 7 days.

CDEM Groups have some very limited emergency powers relating to immediate emergency response - clearing roads and sites, employing people to assist with response, coordinating emergency response, control of traffic in the affected area, provision of food/shelter, etc, and spreading information.

Various people such as the Director of Civil Defence, police officers, incident controllers, local CD managers, etc have some other special powers which include (different powers apply to different people):
-power to require information (this can be appealed in a District Court)
-power to gain a warrant of entry to any premise other than a dwelling to search for vital information (excludes medical history of an individual or other confidential information protected by legal privilege)
-order evacuation of any place, or to restrict access to any place
-forcibly enter any place to save life, prevent injury, recover injured person, or relieve distress of suffering
-Closure of roads and public places
-Forcible removal of any vehicle that is a hindrance
-Requisition of pretty much anything (in exchange for written confirmation of the requisition)
-Direct any person to stop certain action or perform certain action that may affect emergency response or cause/escalate an emergency
-examine, mark, seize, sample, secure, disinfect, or destroy any property, animal, or any other thing in order to prevent or limit the extent of the emergency

Any of these authorised people must carry identification and present it if asked, and give a reasonable explanation of the powers they are using and what their justification is.

ETA... In other words as far as I am aware the PM has absolutely no special powers. However there may be some other provisions that can be utilised in conjunction with a state of emergency, such as declaring martial law. I'll have to look that up.

[gumboot]

It appears that, on the request of the police, the Prime Minister can direct any part of the Defence Force to provide assistance to the police in the case of any sort of serious emergency that the police cannot handle (it must involve an attempt or threat of killing or serious infliction of damage). Defence Force personnel operate under the authority of the police in this situation and have the same powers and protections as the police. This situation expires after 14 days unless extended.

The military can also be directed to provide general assistance and public service at any time.

[gumboot]

One more...

There are special emergency powers for the advent of an international terrorism emergency:

-Police Commissioner must inform PM of an emergency
-PM must meet with 3 minister of the Crown to authorise police use of emergency powers
-Expires after 7 days (can only be extended by parliament, who can also revoke powers)

Police can, in the area of the emergency:
-order evacuation of any place or vehicle (or prohibit entry)
-forcibly enter any place or vehicle
-close roads or public places
-forcibly remove any vehicle
-destroy any property which constitutes a danger
-requisition pretty much anything
-restrict or prohibit all vehicle use/access

In addition, police can authorise any member of the Armed Forces to do any of the above.

To preserve life police officers may
-connect to or in anyway interfere with the telecommunications system
-intercept private communications (these communications cannot be used as evidence except in relation to the incident)

The PM can restrict:
-Publication or broadcast of anything that may identify a person involved in the incident
-Publication or broadcast of any techniques/measures designed to deal with the incident

[dudalb]

One of the things about a Parliamentary system I dislike, although this is a "unoffcial " flaw, is that there seem to be few primary elections, in which the average member of a political party has a strong say about who will run for office. I get the feeling that party officials decide who is going to represent the party in a given election,and the average Labor or Conservative or whatever party member does not have much say about it.
Another thing is that "Carpetbagging" (running for parliament in a district where you are not a resident, or have moved in specifically for the purpose of running for office) is not frowned upon in the UK, where it is in the US. Not forbidden in the US, as long as you have been a legal resident of the state of district where you are running for a year, but it really, frowned upon. If Franken loses Minnesota, the "carpetbag" factor will be considered a major reason.

[gumboot]

Originally Posted by dudalb

One of the things about a Parliamentary system I dislike, although this is a "unoffcial " flaw, is that there seem to be few primary elections, in which the average member of a political party has a strong say about who will run for office. I get the feeling that party officials decide who is going to represent the party in a given election,and the average Labor or Conservative or whatever party member does not have much say about it.

I think that would depend on the party. I know that the New Zealand Labour Party select a leader by sitting down and all voting collectively on who the new leader will be. But bear in mind that the leader of a given party does not "run for office" - in MMP, for example, individual candidates run for electorate seats and the rest are party seats. A party leader could be rejected by their party at any time, and replaced.

Originally Posted by dudalb

Another thing is that "Carpetbagging" (running for parliament in a district where you are not a resident, or have moved in specifically for the purpose of running for office) is not frowned upon in the UK, where it is in the US. Not forbidden in the US, as long as you have been a legal resident of the state of district where you are running for a year, but it really, frowned upon. If Franken loses Minnesota, the "carpetbag" factor will be considered a major reason.

This may be considered worse in the US because you're representing states which theoretically have a degree of independence.

[gumboot]

Originally Posted by paximperium

his would also allow a very unpopular PM to get voted out of office before the end of term(imagine we could've gotten Bush out a few years sooner).

If the unpopular PM's party had any brains at all they'd dump them as their leader and replace them with someone else well before an election. If the PM won an electorate seat they'd stay in parliament either as a lowly member of the party (or if they were really bad, as an independent).

[lionking]

I'm not sure the two systems are that different. In theory in Australia, people vote for a local candidate who, if elected, selects a Prime Minister from within the party. In practice, our elections have long been "presidental" with people voting for a party and it's leader and neither knowing nor caring who their local member is (with a few exceptions of course). If you ask people who they voted for last year they will say "Rudd" or "Howard".

And the concept of an independent civil service providing advice freely and fearlessly is a myth now (and probably always was).

[gtc]

Originally Posted by geni

The prime minister wields rather more power within the system than the president. A prime minister with a strong parlimentry majority has very few checks on their power. Remeber no constitution limiting parliment's powers so parliment can do anything up to an includeing abolishing itself (although no one is quite sure what would happen next). Throw in rather higher levels of party loyalty and US style checks and balances are more limited (there is the house of lords but the commons can abolish that as well).

For those who are unfamiliar with the Westminster System:

The situation is quite a bit different in Australia where the constitution is more explicity about the powers of the Prime Minister and Parliament. Australia also has a Senate which is elected, is effectively independent of the House of Representatives and is quite an effective check on the actions of the Prime Minister.

In the UK, the Prime Minister can appoint new people to the House of Lords if he or she needs to get a piece of legislation passed. In Australia they would need to trigger a double dissolution election in which all the Senate seats and all the House of Representative seats are up for election. Afterwards both houses sit together as one to debate the legislation.

Originally Posted by geni

Every 5 years although any party waiting the full five years would end up looking seriously weak.

Why is that?

Originally Posted by geni

His position would become untenable and he would be expected to step aside.

I guess in theory you could ask someone from a safe seat to resign so that they could be 'parachuted' into parliament but I couldn't imagine they would have much credibility even if they won the by-election.

I seem to remember a few cases of Australian Senators who were wanting to become PM resigning their Senate seat to contest a hastily vacated House of Reps seat.

[gtc]

Originally Posted by dudalb

One of the things about a Parliamentary system I dislike, although this is a "unoffcial " flaw, is that there seem to be few primary elections, in which the average member of a political party has a strong say about who will run for office. I get the feeling that party officials decide who is going to represent the party in a given election,and the average Labor or Conservative or whatever party member does not have much say about it.

It really depends on the party. Some of the minor parties get ordinary party members to elect their leaders. Others get ordinary members to select the candidate in each electorate. The leaders are then determined by the members of parliament after the election is held. Under the parliamentary system it is important that the leader have the support of their parliamentary colleagues (or at least a degree of support). It seems less important for Bush to be the preferred President of the House Republicans.

I think it works out evenly over time as an unpopular party leader will lose their party votes at the next election.

Originally Posted by dudalb

Another thing is that "Carpetbagging" (running for parliament in a district where you are not a resident, or have moved in specifically for the purpose of running for office) is not frowned upon in the UK, where it is in the US. Not forbidden in the US, as long as you have been a legal resident of the state of district where you are running for a year, but it really, frowned upon. If Franken loses Minnesota, the "carpetbag" factor will be considered a major reason.

Districts (called electorates) move around a bit in Australia so it would be rare if people objected to someone who stood for their neighbouring electorates.

We don't call it carpet bagging but politicians who don't want to live in their own electorate are often considered to be 'party hacks' who can only survive if their party is popular. Sooner or later they get replaced by a real local.

We have fewer regional differences than the USA. Moving interstate isn't generally frowned but I guess they might need to show they want to be a part of the local community.

[CapelDodger]

Originally Posted by geni

On the pluss side under the UK system it is fairly easy for the goverment to get things done on the minus side it is fairly easy for the goverment to get things done.

Spot on . Except that we pronounce it "government", and a government has to bring its party with it. The UK party-system is very different from the US's.

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Under the UK system less problems working out who to blame and earmarks are less common.

The blatant earmarking in the US system is simply impossible over here, except in the desperate days of a dying administration, and they don't survive it.

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On the other hand it is much harder to kill bad legislation that has got someone's ego attached to it.

On the other hand, there are no fixed terms and Parliament works on the "open outcry" system.

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One other big difference that isn't parliment based is the civil service. A lot of positions that in the US are filled by presidential apointments are in the UK filled by career civil servants. Diplomats are in some ways a rather extreme example of this.

That is indeed a major difference.

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On one hand this means that the civil service tends to be more political neutral and suffers less from the problem of people being there because the president owes them a favor. On the other hand the tallent pool is somewhat smaller (although I don't think this has been suggested as a problem in the case of the diplomatic service).

The civil and diplomatic services give the system a great deal of inertia. Which is a bit of good and a bit of bad.

ETA : oops on the "we"

[geni]

Originally Posted by dudalb

One of the things about a Parliamentary system I dislike, although this is a "unoffcial " flaw, is that there seem to be few primary elections, in which the average member of a political party has a strong say about who will run for office. I get the feeling that party officials decide who is going to represent the party in a given election,and the average Labor or Conservative or whatever party member does not have much say about it.

The rules vary from party to party. The rules can get rather messy (mixes of centeral lists with local nominations etc) but local party organisations generaly have a fair bit of say over their candidate.

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Another thing is that "Carpetbagging" (running for parliament in a district where you are not a resident, or have moved in specifically for the purpose of running for office) is not frowned upon in the UK, where it is in the US.

It is disliked to an extent but well most of the voters will have lived in various constituencies are various times so less of an issue.

[geni]

Originally Posted by gtc

Why is that?

Because convention is that you hold an election every 4 to 4 and a bit years so not doing so and hanging on for the full five is basicaly adminting you can't win.

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I guess in theory you could ask someone from a safe seat to resign so that they could be 'parachuted' into parliament but I couldn't imagine they would have much credibility even if they won the by-election.

In the UK it would make a complete mess of forming a new goverment. Giveing an MP a seat in the lords so that their seat can be used to get someone in is not unknown but in this case would take too long.

[gtc]

Originally Posted by geni

In the UK it would make a complete mess of forming a new goverment.

It would do that here as well. Its not a realistic proposition.

[Wildy]

Originally Posted by gtc

Districts (called electorates) move around a bit in Australia so it would be rare if people objected to someone who stood for their neighbouring electorates.

Do they really move about a bit? I know that they are changed based on population but I never really thought of that as common.