Written evidence submitted by George Cooper,
Chair, London Branch Association of Electoral Administrators (PVSCB
26)
I am writing on behalf of the London Branch
of the Association of Electoral Administrators (AEA) to commend
to you the response of the national Association to requests for
evidence on the above Bill.
In addition to endorsing this detailed and important
response, we would emphasise two particular points.
Firstly, the Referendum deriving from the Bill
will be the first occasion that the Electoral Commission is service
manager, as well as "Watchdog," in a UK poll. It is,
thus, an important new test for the Commission. The national AEA's
more detailed comments are contained within section 5 of their
submission.
Secondly, the determination of the Bill to achieve
equality of electoral constituency size by reference to a 5% margin
of difference will make the problems of cross-boundary administration
not merely more prevalent, but the norm. Local Government Boundary
Reviews have long attempted to use this benchmark and it has meant
that their other criteria for boundary delineation, of community
identity and strong "physical" boundaries, have been
sacrificed for a mathematical purity that does not add to the
quality of representation.
The technical and administrative issues are
again set out in detail in section 10 of the AEA submission, but
we would very much draw your attention to the comment in 10.6
that "Electoral areas need to function as administrative
entities as well as representative ones ... the impact on voters
should not be underestimated." This is not a mere self-regarding
argument.
These "cross-boundary" issues are
complex not only for administrators but also for electors and,
surely, for the representatives who serve them. They may involve
liaison across councils for often quite small numbers of electors
to ensure, for example, that poll cards are distributed and ballot
papers properly collected and transported to the appropriate count.
The time taken up in such arrangements on count night attracted
much criticism this year in places where they applied.
In some London (and indeed other) Boroughs,
transferring one ward from an oversized to an undersized constituency
in pursuit of the 5% rule will merely reverse their status, leading
to the need to use Polling Districts as building blocks, itself
innately undesirable as Polling Districts are an entirely flexible
unit of geography built around a Polling Station for the convenience
of voters. They should not be set in set in stone as they might
have to be under the 5% proposal.
Further, to have to deal with an additional
set of different County, Borough or Parish Councils, Associations,
Companies, Media Organisations and Voluntary organisations "just
over the border" for the sake of mathematical purity, is,
we submit, even more of a workload burden for Members of Parliament
as it is for administrators.
The 5% benchmark will mean that many more principal
area and County—whether historical or administrative—Boundaries
will be breached in drawing up new Parliamentary Constituencies,
and this includes London. The capital is clearly delineated at
present for Parliamentary, European, Mayoral and Assembly elections
and the possibility of outer London Boroughs reaching into all
the surrounding Counties will surely be vexing for more than just
the psephological industry.
In London especially, electoral equality in
Parliamentary Constituencies does not equate to an equality of
workload for either the elected or the officials who serve. We
serve many thousands of EU electors, and others who are not entitled
to register for parliamentary elections, who are still a large
part of our community with all the needs that that entails, who
will not feature in the calculations.
Finally, we doubt that either the equality or
quality of representation and administration will be benefitted
by applying an abstract percentage benchmark in preference to
community identity and strong, sometimes historic, boundary considerations.
These should still feature strongly in any move to achieve or
maintain greater overall equality.
16 September 2010
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