Senate reform has been in the news on both sides of the Atlantic recently, with both Ireland and Canada actively debating whether to keep, reform or abolish their respective Upper Houses of Parliament. The debate in Canada was sparked by the Harper government's proposals to reform the Senate, but has been back in the news mainly due to a series of scandals involving Senators. In Ireland, the issue has been pushed to the forefront by the Kenny government's proposal to abolish Seanad Eireann (the Irish Senate), which goes to a national referendum on October 4th. The abolition of the Seanad is part of a larger government programme of constitutional reform, but seems to have garnered public support largely as a cost-saving measure.
As a Canadian with Irish citizenship, I have been following with interest the debate in both countries. Apparently I am not the only one: politicians in Canada are reported to be watching with interest the possible countdown to extinction of the Seanad.
There are a number of obvious similarities between the Canadian Senate and Seanad Eireann. Both are based in the British Parliamentary model of a bicameral Parliament, or one made up of two houses, where the Upper House was meant to act as a check and balance, or a chamber of "sober second thought". However, in both countries, the Senate has too often been used as a convenient place to house political cronies, and both have had their share of political scandal over the years.
There are some obvious differences between the two Senates as well. While Canadian Senators are appointed until age 75, and entirely on the advice of the Prime Minister, the Taoiseach (the Irish Prime Minister) appoints only 11 of the 60 members of the Seanad. Another 6 are elected by graduates of certain Irish universities, and the remaining 43 are elected through a complex panel system by an electorate consisting of TD's (Irish MP's), Senators and local councillors. Irish Senators are elected only until Parliament is dissolved prior to the next general election, so they serve a maximum term of 5 years before seeking re-election.
The two Senates also differ in terms of powers. While the Seanad can only delay the passage of legislation approved by the Dail (the Irish House of Commons), the Canadian Senate has somewhat more power, having the ability to vote down legislation altogether.
Finally, while Seanad Eireann can be abolished through the support of a simple majority of voters in a national referendum (like other changes to Ireland's constitution), Canada's Senate can only be reformed or abolished with the support of a certain number of Provinces.
Proponents of Senate abolition in Canada are quick to highlight the similarities between the two Houses, and have also been quick to point out that Ireland would join a growing number of countries that have abolished their upper chamber, including New Zealand and some Nordic countries. They further point to the fact that many of the small democracies that emerged post-communism have chosen not to have a second chamber at all. The implication is that Canada should follow this lead, and eliminate the Senate.
However, this analysis misses one vital, fundamental difference between Canada and most countries that have no second chamber. Canada is a geographically large federal state: it was made up of separate colonies who joined together to form one large country, with significant regional differences. It has both a federal and a provincial level of government. Like other large federal countries such as the United States, Australia and Germany, Canada's Senate is meant to provide balanced representation of these different regional interests, and ensure that the voice of smaller regions is not drowned out by larger ones. In fact, equal representation of regions is one of the main reasons the Canadian Senate exists, and one of the reasons smaller provinces were willing to sign on to Confederation in the first place.
Ireland, on the other hand is a relatively small unitary state. It has no state or provincial level of government. And while there are certainly regional differences, they are simply not on the same geographic scale as Canada's. In fact, most, if not all of the countries that Senate abolitionists point to as examples of countries with no second chamber, tend to be small, unitary countries like Ireland. Getting rid of the second chamber might make sense for countries like New Zealand, Estonia or Sweden, which are relatively small and have no state or provincial level of government. However, most large, federal states like Canada have chosen to keep their second chamber.
So while Ireland's experience with the Seanad is interesting to politicos, it's not an example Canadians should blindly follow. As the debate on the future of the Senate continues to unfold in Canada, we need to bear in mind the uniqueness of our own particular situation, and the fact that our reasons for wanting to keep or kill our Senate are likely very different than Ireland's.