Unit 6C: Comparative UK and US Politics Alan Dobson Professor at the Department of Politics at the University of Dundee writes for the BBC Parliament

The British Parliament allows people to have their say

In Britain the legislative assembly consists of the House of Lords and the House of Commons, in the USA it consists of the Senate and the House of Representatives.

In both countries, the so-called lower house is elected by the people by universal franchise and a first-past-the-post system.

In this way the candidate with the most votes wins even if she or he has a minority of the overall votes cast.

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For example, in a three-horse race where candidates get 34%, 33% and 33% of the votes cast the candidate with 34% wins.

In the USA the Senate is also elected by this method, but similarities between the two systems more-or-less end there.

Even though terms like party whips are common to both they mean different things and, of course, the House of Lords is made up of a mixture of hereditary and nominated peers along with bishops and law lords, which is totally different from the whole ethos of the US governmental system.

Elections and representation

The two houses in the US have different constituencies and different terms of office.

Senators are elected on a state-wide basis for a six year term and one third of the senate stands down for re-election every two years.

Representatives are elected by districts of roughly equal population size for a two year term.

In Britain, general elections have to be called within a five year frame, but the actual decision lies with the incumbent part leadership.

The Senate has certain prerogatives. It requires a two-thirds majority to approve treaties, and senior administrative and judicial appointments.

It is a relatively small house with 100 members (two for each state) and the rules of procedure are highly flexible with the possibility of a filibuster or of endless debate to oppose a legislative proposal.

This usually ends in the proposal's demise though there is a way to bring cloture (end the debate) but it is very difficult to achieve.

The Senate also has strong powers of oversight to monitor the government and ensure it is not doing anything improper.

The House has its own prerogatives.

The most important of these is the right to initiate revenue-raising bills. Its procedures, largely because of its much greater size, are much more rigid and usually laid down by the very powerful Rules Committee.

The House of Lords is an important debating chamber with limited power to delay non-financial legislation.

The law lords also play an important role as the highest court of the land.

But the House of Commons is the real legislative powerhouse. It has ability to pass laws quickly and effectively because of a tightly disciplined party system.

The USA by contrast does not have such a disciplined party system and the result is that legislation in the US Congress often has to go through a lengthy process of accommodation and compromise to muster sufficient majorities at the various stages of the passing of a bill for it to be successful.

In the Commons if the majority party wish it can forcefully impose its will with regard to legislation but powers of oversight in the Commons are nowhere near as strong as in the US Congress.

Parliamentary committees

Overall two of the greatest contrasts are: the presence of a strong committee system in the USA and a weaker one in Britain and a strong disciplined party system in Britain and a less disciplined one in the USA.

The consequence of this is that debate in the US Congress can often be more meaningful and represent the true feelings of the member whereas in the Commons members often have to take the party line.

But while there may be more genuine debate in the US Congress than in the House of Commons, there are less clear lines of accountability.

In Britain it is always clear which party to hold responsible for a piece of legislation.

In the USA finding out whom to hold responsible for legislation is more difficult because of weak party discipline and cross party voting.

� Professor Alan Dobson 2004
Department of Politics
University of Dundee