There are two countries in the world.
That, at least, is a conclusion you could easily come to if you were to listen to the voices of too many political obsessives in the UK, particularly in discussion of constitutional reform. The UK’s political elite are so obsessed with the US that they invariably reach for the superpower across the pond as their only paradigm – positive or negative – for their own politics.
The latest offender is Simon Clarke, a minister under prime ministers Boris Johnson and Liz Truss. In response to a pledge by the Labour leader Keir Starmer to abolish the House of Lords, the upper chamber of the UK parliament, Clarke tweeted: “Anyone who has looked at the institutionalised gridlock in US politics can see the utter stupidity it would be to create an elected upper house, fatally undermining the primacy of the Commons.”
Clarke is no doubt correct to decry the dysfunction that would probably ensue if, for some reason, the UK decided to exactly duplicate the workings of the notoriously deadlocked US Senate. But one advantage of there actually being more than two countries in the world is that duplicating a system designed, rightly or wrongly, to give Rhode Island a disproportionate voice in federal politics means this is not the only option available.
Labour’s report setting out how the party would reform the House of Lords explicitly considers the dangers of a new elected chamber coming into conflict with the Commons. It offers several recommendations for how to maintain the primacy of the lower chamber in the legislative process, such as electing each chamber on a different electoral cycle or giving no role in fiscal matters to the new “Assembly of the Nations and Regions”.
This is unsurprising, because the commission that authored the report, led by the former prime minister Gordon Brown, examines constitutions written since 1789 in countries around the world. This stands in sharp contrast with much of the British elite’s unwillingness to look at political systems other than its own and America’s. The ultimate effect of that unwillingness is that many are unable to learn from the countries the UK most resembles – its European neighbours.
The UK’s second chamber is the world’s second-largest legislative chamber, after the National People’s Congress of China. The ranks of its 800 or so members are regularly swelled by the government of the day appointing its cronies and political allies as peers, while 92 members inherit their seats through mostly male-only hereditary peerages. Contrary to Clarke’s suggestion, there are clearly more options than maintaining this semi-medieval constitutional aberration or duplicating the US Senate.
Were he so inclined Clarke could have looked at the directly or indirectly elected second chambers across Europe, none of which suffer from the gridlock that plagues the US Senate. None is perfect but all are in many ways preferable to the UK’s archaic and bloated House of Lords.
Germany’s Bundesrat, for instance, represents the country’s 16 federal states in the legislative process, with members appointed by state governments. France’s Senate is elected by tens of thousands of local officials and although they grant the chamber a near-permanent conservative majority they have over time helped it to develop an identity as the “guardian of the institutions” against the whims of the lower chamber and the government. The Italian parliament’s “perfect bicameralism” allows the Senate frequently to block legislation from the lower house, but even it is not as much of an obstacle to effective governance as the US Senate.
Indeed, these very countries look at the UK’s archaic constitutional arrangements with a mixture of pity and bafflement. The French journalist Cécile Ducourtieux judged in Le Monde on 5 December that House of Lords reform is a “riskless” proposition for the left, the continued existence of a second chamber being an “eminent symbol of the persistence of a class system” in the UK. The same day the German magazine Der Spiegel wrote simply that the House of Lords is a “parliamentary absurdity”.
It is ultimately telling that it is easy to conceive of a British parliament with a second house similar to those of its large European neighbours. None of those countries, however, would dream of recreating the House of Lords.
[See also: Is Keir Starmer brilliant or just lucky?]