Canadian and American politics compared

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Though there are many similarities between the politics of Canada and the politics of the United States, there are also important differences. Many of the differences and similarities were the foundation for debates in the 19th century about how "republican" or even Americanized Canada should become.^[1]

Key among the differences are Canada's use of the parliamentary system rather than the US congressional system, related differences regarding the separation of powers and powers of the head of government (President vs. Prime Minister), and the much greater American role of a written Constitution (as interpreted by the Supreme Court). Both nations have a federalist system with strong powers controlled by the states/provinces. Canada lacks the historic commitment to republicanism that characterizes American political values, though the differences have been lessening due to political reforms. The US lacks the commitment to biculturalism characteristic of Canada, though this difference has been lessening due to a fast-growing Spanish-speaking population. Overall, both nations have a very similar system of political, cultural and social values.

Contents 1 Origin of differences 1.1 American Revolution and republicanism 1.2 Fragment thesis 1.3 Laurentian thesis 1.4 Religious thesis 1.5 Staples thesis 1.6 Court or Statist thesis 2 Division of powers 3 Legislature 3.1 Municipal powers 4 Equalization payments 5 Political parties 6 Bureaucracy 7 Centralization of power 8 Judicial system 9 Size of constituencies and campaign financing 10 Multilateralism 11 See also 12 Notes 13 References

[edit] Origin of differences

There is much discussion, particularly in academic circles, of the differences and similarities between US and Canadian politics. There are a number of explanations for why Canadian and US politics are different:

[edit] American Revolution and republicanism

Christie notes, "Until recently influential historians of early Upper Canada have sought to highlight a single climate of opinion which was antidemocratic, anti-American, and wholly prescribed by the conservative values of the political and social elite. This uniform portrayal...has been challenged by Jane Errington's The Lion, the Eagle, and Upper Canada." According to these authors, Canada and the U.S. shared many similar political values in 1776 regarding rights, then diverged, and now have started to converge to a common outlook on political rights and responsibilities. To the extent that antidemocratic elites blocked republicanism in Canada by suppressing revolts in 1837 and other points, there was divergence. Thus it is Errington's view that in the 20th century the deference to British elites and hierarchical modes of deference have fallen away in Canada. However, recent survey research conducted by Michael Adams and summarized in Fire and Ice (2003) tends to confirm continuing differences in American and Canadian political values[1]. Adams points to a "counter-revolutionary tradition" in Canadian politics, in contrast to the "revolutionary tradition" of the U.S. (Neidhardt, 2005).

Some believe that the differences date to the American Revolution. This view was the dominant one in most of the studies of Canadian history. With the creation of the United States, the founders of that nation embraced republicanism and rejected the British monarchy, aristocracy and the Westminster system. In contrast, Loyalist refugees from the United States exerted a strong influence in Canada, bringing with them a degree of republicanism and democratic opposition to aristocracy. The Loyalist refugees were closely watched. Lieutenant-Governor Parr wrote, March 8, 1788, "Whatever Loyalty these Lawyers may have brought with them from the States, is so strong tinctured with a Republican Spirit; that if they meet with any encouragement it may be attended with dangerous consequences to this Province. One of them (Sterns) aims at being the Wilkes of Nova Scotia" (Clark, 132). The fears were exaggerated for the Loyalists who basically were loyal to the Crown, and sought a role in the British Empire.

The republicanism that motivated the Americans stressed independence, innovation and the rejection of class systems, as well as fear of corruption and devotion to civic duty. Many Americans (led by Thomas Jefferson) feared a strong central government similar to Britain. Indeed the Jeffersonians repeatedly denounced their Federalist opponents like Alexander Hamilton of being too monarchical and undemocratic. Canada, whose Anglophone population included a large proportion of United Empire Loyalists chose a more pragmatic, non-ideological path. George Woodcock has argued (in The Century that Made Us: Canada 1814–1914) that Americans are revolutionaries, dedicated to an ideology they believe makes their country the best in the world and a beacon of democracy, while Canadians are rebels who want chiefly to be left alone with their own traditions and loyalties.

The difference between the origins of the two nations is often said to be illustrated by the contrast between a key phrase in the American Declaration of Independence, "Life, Liberty, and the Pursuit of Happiness," and a key phrase in the Canadian 1867 constitution, "Peace, Order, and Good Government."

Well over half the Nova Scotia settlers in 1776 were Yankees from New England. (Christie) When the militia refused to turn out to defend Nova Scotia against a possible Yankee invasion (which never came), one captain reported in late 1775 to the governor, "I made it my constant employment...to converse with Many of the Inhabitants of the several Townships through which I passed--in order to discover their Principles--Views --Sentiments--Wishes--Hopes & Fears. Very sorry am I to report on this occasion that their Principles are Republican. Their Views, to Subvert the English Constitution in this Province" (Clark, 61). Nor was republican sentiment limited to Nova Scotia, for as S. D. Clark reports, "The English-speaking residents of Montreal were prepared, in the spring of 1775, to go about as far in resisting British authority as were most of the residents of the other colonies" (Clark, 81).

[edit] Fragment thesis

The fragment thesis, first advocated by Louis Hartz and later applied by Gad Horowitz to Canada, argues that a nation's political culture is the product of the immigrants who formed that nation. Thus the American political tradition originates with those leaving Britain, either because of religious persecution or to pursue trade and make money. Neither of these groups was keen on powerful government and they were much affected by the writings of British political philosophers such as John Locke and the advocates of republicanism. By 1800 most of the English speakers in Canada were Loyalists who were defeated in the American Revolution and chose exile in British Canada rather than life in the new United States. They called themselves United Empire Loyalists. French Canada comprised peasants loyal to an autocratic monarchy and, especially, an authoritarian and highly traditional Catholic Church. Canada's population thus was originally far more conservative than the US. In the late 19th century, however, Canada was a destination of Eastern European socialists and British Fabians and trade union members who have given modern Canada a somewhat stronger leftist bent than the United States. Many of the American draft dodgers who arrived during the Vietnam War may also have contributed to Canada's anti-American political culture, although that contribution may well have consisted of replacing Canadian socialism's traditional class analysis with American identity politics.

[edit] Laurentian thesis

The Laurentian thesis ascribes the differences between Canada and the United States to a period much earlier than the revolution. It argues that the differences are based on differing trade patterns. While the US' trade in its early years ran almost entirely north-south along the eastern seaboard, Canadian trade patterns ran east-west along the St. Lawrence River. This thesis was advocated by Donald Creighton. This dependence on one river led to the domination of Canada by Ontario and Quebec and the peripheralization of the Maritimes and the West.

[edit] Religious thesis

The religious thesis ascribes the differences between Canadian and American political cultures to the differing religious make up of the countries. The United States for most of its history was overwhelmingly radical Protestant, with most of its people belonging to churches that were evangelical and non-hierarchical. In Canada by contrast the Anglican Church dominated English Canada while the Roman Catholic Church dominated Quebec. Both of these churches were hierarchical in nature, leading, it is argued, to Canada's long standing predisposition to deference towards authority. In recent decades however, the Catholic Church in Quebec has grown much weaker, and Canadians have been seen as less deferential to authority than they had been in the past. Methodists moved in large numbers from the United States to Canada in the early years of the 19th century, causing some alarm among conservatives who feared they also brought republican and democratic ideals that threatened the hierarchical Canadian system. In 1827 Archdeacon Strachan's published his "Ecclesiastical Chart." He complained "the teachers of the different denominations . . . are for the most part from the United States, where they gather their knowledge and form their sentiments; indeed the Methodist teachers are subject to the orders of the Conference of the United States of America, and it is manifest that the Colonial Government [cannot] . . . prevent them from gradually rendering a large portion of the population . . . hostile to our institutions, both civil and religious." The Methodists finally cut their ties with the U.S. [Lower p. 183] English visitors were often shocked at the egalitarianism found in Canada. They decried "Republicanism", and the invasion of American attitudes. As Lower notes, the critics "rarely realized that equality was in the very essence of pioneer life." [Lower p. 202]

Meanwhile organized religion in the U.S. has retained enormous strength, but with a weakening of the more liberal denominations, and a strengthening of the more conservative fundamentalist, evangelical, Mormon and Catholic elements. Thus organized religion in Canada has weakened and become more liberal, while organized religion in America has strengthened and become more conservative -- to the extent, some argue (including Michael Adams in his recent book, "Fire and Ice") that Canadians today are less deferential to authority than are Americans.

[edit] Staples thesis

The staples thesis, introduced by Harold Innis argues that Canada became a distinct entity based upon the exploitation of certain staples by the Europeans. New France and then Canada until about 1800 was completely dependent upon the fur trade for its existence. Since it was dependent upon exports to Europe no revolutionary zeal took hold there. Innis argues that the borders of the fur trade very closely reflect the borders of modern Canada. The fur trade was eventually superseded by the timber trade and the wheat trade but the close links with Europe remained.

[edit] Court or Statist thesis

This thesis developed by Michigan State University professor Gordon T. Stewart in his book The Origins of Canadian Politics: a Comparative Approach argues that the differences in Canada's political culture stem from developments which occurred between 1760 and 1848 in the Canadas: sharp partisan battles, intense use of patronage, strong one-man dominance in party leadership, and a "statist" orientation. Responsible government in the central Canada came only after a "prolonged, violent and bitter struggle," unlike the maritime provinces or other British settler colonies. The struggle between Loyalist, British monarchical, and French-Canadian values led to a unique political culture.

[edit] Division of powers

Both countries are federations. In Canada the sub-units are known as provinces and territories; in the United States they are known as states and territories. There is also one U.S. federal district — the District of Columbia.

Between 1848 and 1854, a significant and articulate minority of conservatives in Upper Canada advocated constitutional changes modeled on the American federal-state system and the US Constitution. They critiqued Canada's imitation of British parliamentary government as both too democratic and too tyrannical. It destroyed the independence of the appointed governor and Legislative Council and further concentrated power in the Cabinet. This critique led many conservatives to argue that the American model of checks and balances offered Canada a more balanced and conservative form of democracy than did British parliamentary government. These "republican conservatives" debated a series of constitutional changes, including annexation to the United States, an elected governor, an elected Legislative Council, a federal union of British North America, and imperial federation, within this framework. These conservatives had accepted "government by discussion" as the appropriate basis for political order. A historiographical tradition that stresses the existence of a conservative, pro-British, and anti-American political culture in Upper Canada cannot do justice to the extent, thoughtfulness, and discerning nature of political debate in this period. [McNairn 1996]

Some consider the Canadian government to be more decentralized. Canada is one of the few countries in the world where the combined budgets of the provinces exceed that of the federal government, if one ignores transfer payments organized by the federal government. Canadian provinces are responsible for most of Canada's social safety net, including health care, welfare, and education.

In the United States residuary or reserve power (i.e., power not enumerated in the constitution) is reserved to the states. Originally, Canadian residuary power was reserved to the federal government by the British North America Act, so that Canadian government was highly centralized. In 1896 the Judicial Committee of the Privy Council ruled that the federal government could exercise its residuary power only to safeguard "peace, order and good government". However, Prime Ministers as recent as Jean Chrétien have used such powers in milder forms, such as in the Black v. Chrétien case.

The British North America Acts had assigned property and civil rights to the provinces at a time when responsibility for these rights involved little more than regulating civil law. However, once the federal government lost its reserve power, new areas of government activity such as labour laws, pensions, and social insurance became the responsibility of the provinces, as regulators of civil rights, rather than of the federal government. Standards of social service soon varied widely from province to province.

In order to reduce these differences, national programs in fields of provincial jurisdiction, such as health care, have gradually been negotiated between the federal government and the provinces, and are coordinated by the federal government, which largely finances them through transfers to the provinces (chiefly the Canada Health and Social Transfer; territories receive an additional transfer to compensate for higher costs in the North). Provinces retain the option of raising their own taxes to pay part of these programs, although they may be unable to make use of this expedient for economic or other reasons. Provinces may also withdraw from these programs; Alberta has considered leaving the national health care program. Finally, provinces retain other powers in the areas covered by national programs.

The provinces have exclusive jurisdiction in many fields which are federal responsibilities in the United States. Primary and secondary education are the most prominent, each province's education system being unique, most noticeably in secondary education. Quebec is responsible for handling immigration into Quebec, and other provinces have the option of taking responsibility for immigration. Quebec also collects its own corporate and personal income taxes. (Other provinces have their personal income taxes collected by the federal government, and all but Alberta and Ontario have their corporate income taxes collected by the federal government.) Quebec runs a pension plan parallel to the Canada Pension Plan; other provinces also have these options. In the United States education is the sole responsibility of the states (although many public and private schools receive some federal funding) and all but seven states collect an income tax.

In the past, the Canadian federal government has periodically deducted health and social transfers to provinces which strayed from federal standards for health care and social programs. This has proven controversial in Canada, however by comparison the American federal government has used the threat of withholding federal highway funds in a much more aggressive manner, threatening to withdraw funding to any state which fails to enact various non-highway-related policies mandated by the federal government. In contrast, Canadian government threats to withdraw health and social funds have generally been done on rationale that is restricted to issues directly related to health care and social programs.

In the United States the federal government exerts a great deal of power but because of the checks and balances in the US system this control is often tempered by the different branches. While in Canada the criminal code is federal legislation, US states may make criminal laws, creating differences in everything from gun control measures to capital punishment. While each state has its own police force, unable by law to arrest in another state, several Canadian provinces contract with the federal police force, the Royal Canadian Mounted Police, to provide provincial police services.

[edit] Legislature

The United States has a bicameral legislature made up of the United States Senate and House of Representatives. Each state has equal representation in the Senate, regardless of population, and representation based on its population in the House of Representatives. American state governments are like smaller copies of the federal government—only Nebraska has a unicameral legislature; the rest are bicameral. Like the United States, Canada also has a bicameral legislature made up of the Queen, The Senate and the House of Commons. Canadian provinces had bicameral legislatures. Over time, however, they have eliminated their upper houses, and are now all unicameral.

The Canadian Senate is also an unelected body that unlike the elected US Senate does not generally have a record of representing provincial interests. Seats in this Senate are allocated based on the relative equality of regions rather than individual provinces. It also acts as a body of review or "sober second thought". Canadian Senators tend to adopt a longer term view regarding legislation and has generally been more progressive in many ways than their elected counterpart the House of Commons. This is said to be because Canadian Senators have a term of office that ends only upon reaching the age of 75, or by their removal according to the Constitution of Canada.

Similarly, executive power is consistent between states and provinces and the federal government in both countries. American governors are similar in role to the American president. In Canada however, there is a separation between the Head of State (The Queen of Canada represented by her Governor General at the Federal level and Lieutenant-Governors at the provincial) and the Head of Government (Prime Minister at the federal level and Premiers at the provincial). While in the U.S., the president and each governor is both head of government and head of state simultaneously.

Provincial premiers are also comparable to the Canadian prime minister, as are Lieutenant-Governors to the Governor General of Canada. However, an additional difference between the American Executive offices and the Canadian is that the President of the United States of America is a separate office from those of the state governors. In Canada the executive authority in the right of Canada, as well as in the right of each province is vested in the monarch simultaneously. There is only one shared monarch, represented by the Governor General and Lieutenant-Governors repectively.

The distinctions between "head of state" and "head of government" are not largely relevant in day-to-day governance in Canada, as the Governor General, Lieutenant-Governors, and Queen are largely symbolic figurehead offices. In the United States the Lieutenant Governors of states and the national Vice President often perform similar symbolic duties. What is relevant in the Canadian context, however, is how the reserve powers of the monarchical offices come to be exercised by the head of government directly, which in turn consolodates the power of the latter position.

Many would consider the Canadian government to be highly centralized due to the fact that the Prime Minister's Office controls an inordinate amount of power within the government. Though the Prime Minister is appointed by the Queen of Canada, the Prime Minister is responsible for advice regarding the appointment of the Governor General, Cabinet, Supreme Court Justices of Canada, and the nomination of Canadian Senators. The Cabinet, as a committee, of the Queen's Privy Council for Canada may, by an act in council, also establish treaties, declare war, and is responsible for advice on the use of other executive powers by the Queen's representative (the Governor General).

[edit] Municipal powers

In both nations municipalities have no constitutional rights independent of state or provincial government. That is they are "creatures of their province/state" and at any time the state legislature can intervene in local affairs. Provinces and states may thus merge and divide cities at will, without consultation, and may ignore results of any referendum at the municipal level. For details of a current controversy, see either the Toronto, Ontario article, and a discussion of the 1998 amalgamation by the Ontario government or Montreal, Quebec which was amalgamated in 2002 by the Quebec Government.

provincial powers and Quebec Canadian provinces may opt in or out of several national programs, especially those which are the results of federal-provincial negotiation. The province which has opted out of the most programs is Quebec. Quebec is primarily French-speaking and like Louisiana in the US, follows French civil law. Quebec's public pension and social insurance schemes are kept in separate funds from those of the rest of Canada, and are managed by the powerful Caisse de dépôt et placement du Québec, which often provides investment capital to Quebec-based businesses that are deemed strategic by its government. Quebec also regulates immigration to its territory, and has refused entry to people who had been accepted by the federal government for immigration to Canada. Other provinces have the option of instituting systems like Quebec's, and governments of both Ontario and Alberta have expressed interest in doing so.

The politics of Quebec tend to revolve around the question of Quebec nationalism. On several occasions, this has led to debate about Quebec's separation from Canada, to create a new French-speaking, sovereign, nation state, associated in an economic union with Canada inspired by the European Union. The major provincial political parties in Quebec are divided on the question, often called the National Question in Quebec. The Parti Québécois is independentist, while the Liberal Party of Quebec is federalist.

There is no state in the United States, by contrast, where state politics is so dominated by a party with the goal of separation from the USA. Puerto Rico, which is a non-state commonwealth within the United States, shares some parallels with the Quebec situation, as its population is primarily Spanish-speaking (as opposed to the English-speaking USA). Nevertheless, at the last plebiscite, Puerto Ricans voted to remain a commonwealth, with that option narrowly getting more votes than the option of becoming a state, and with the option of political independence coming in a very distant third.

[edit] Equalization payments

Federal tax revenue contributes to an equalization fund which makes 'provincial equalization payments' to the poorer regions to ensure that comparable levels of service are provided throughout the country at comparable rates of taxation. Seven of the ten provinces currently receive such payments. British Columbia, Ontario and Alberta are the only provinces which do not.

The negotiations of provincial relief, and the draining of human capital (properly individual capital) from poorer provinces to richer ones, are constant concerns of Canadian provincial premiers. In the post-World-War-II period, Atlantic Canada lost many people to Central Canada (especially Ontario) and to Western Canada (to mostly Alberta in the 1970s and 80s oil boom, and to British Columbia later).

From time to time, Canadian premiers have made intolerant remarks about this situation in public. Alberta Premier Ralph Klein once famously offered any unemployed person "a free bus ticket to Vancouver" (to exploit that government's more generous assistance). Former Ontario Premier Mike Harris once famously referred to Atlantic Canada as "welfare bums". Both reflected underlying resentment of making payments to poorer regions, often voiced by constituents in the generally more politically conservative provinces, who feel they are paying for the social assistance in these other places.

Although these politics of 'have' and 'have-not' states are also present in the United States, there is less subsidy of the latter by the former, and more appreciation of the role 'have-not' states play in providing labor to 'have' states, and in serving in the military. Federal taxation and wealth transfers do redistribute wealth between the 'have' and 'have-not' states, but primarily on an individual basis rather than statewide. Differences in cost of living between wealthier and less wealthy states creates controversy, as an individual living in a wealthier state may be forced to subsidize a resident of a poorer state, despite having a lower real income (but higher nominal dollar income.) The dispute over the Alternative Minimum Tax is primarily related to this issue.

[edit] Political parties

There are four political parties with seats in the Canadian House of Commons, and two in the US Congress. Both countries continue to use a first past the post system of electing representatives. This can sometimes work to exaggerate regional differences and interests, whether in the name of Quebec or of the southern "Dixiecrats". The rise of the Bloc Quebecois party and the decline of the Progressive Conservative party very drastically changed the political landscape of Canada. Before that, federal politics were dominated by two parties, as in the US; the Progressive Conservatives and the Liberals, though the Liberals held power for the vast majority of the 20th century, and were commonly referred to as "Canada's natural governing party" as a result.

The vote-splitting effect on the Canadian parliamentary system has often resulted in governments that have an absolute majority of representatives elected by far less than half of the overall popular vote, and effectively accountable to no one until the next election. For example, in the 1997 Canadian federal election the government of Jean Chrétien won a majority of seats in the House of Commons despite winning only 38 per cent of the popular vote. In the 1979 Canadian federal election Progressive Conservative Joe Clark won a minority government with a lead of 22 seats over Pierre Trudeau's Liberals, despite the Progressive Conservatives winning only 35.9 percent of the vote compared to the Liberal's 40.1%. However, the Tories had won the most votes in seven provinces and the difference was almost entirely due to the Liberals' strong lead in Quebec. These instances led some in Canada to demand proportional representation to create a more representative parliamentary system. In the United States, similar results can be produced by the presence of third parties or by the Electoral College. George W. Bush became president with fewer votes than his opponent, Al Gore, because he carried states with more Electoral College votes, while Bill Clinton became president with less than half the popular vote in 1992 and 1996 because of the presence of a strong third party.

In both countries it is rare for individuals to get elected from outside of one of the main established parties. In Canada, because of the parliamentary system, independent candidates can rarely aspire to much influence in government, or aspire to any high executive office, although exceptions occur in cases of minority governments, as in 2005. Likewise, in the United States it is difficult for third parties or independents to be represented in the United States at any level below the presidency (this usually requires an exceptional personal popularity, such as Jesse Ventura in Minnesota, or great wealth, such as that of Ross Perot), third parties have played important roles in many presidential elections. Since the Second World War alone, parties led by Strom Thurmond, George Wallace, and Ross Perot have obtained significant percentages of the popular vote for the presidency. Other third parties which played important roles in post-World War II presidential elections were Strom Thurmond's Dixiecrats and George Wallace's American Independent Party. In more modern times, the rise of the Reform Party of H. Ross Perot in 1992, and the rise of the Green Party in 2000, could both be said to have 'split the vote' and thus exercised considerable influence. By contrast, new parties have been significantly influential in recent Canadian politics, with both the Reform Party and Bloc Québécois holding the status of Official Opposition (Canada) within a decade of their formation.

The four Canadian political parties currently represented in the House of Commons are:

• the Liberal Party of Canada which held power from 1993 until 2006
• the Conservative Party of Canada which won a minority government in 2006
• the Bloc Québécois which is an exclusively regional Quebec party
• the New Democratic Party which is similar to a European social-democratic party, with some 'green' elements, including strong affiliations with Canadian trade unions, the peace movement and ecology activists

Despite the fact that the Canada features more political parties than the United States, the political culture of both nations and the lack of proportional representation tends to encourage broad-based coalition parties, rather than more narrowly-divided ideological parties, as found in many European states. The separate existence of the Progressive Conservative Party of Canada and the Canadian Alliance party was widely criticized by many members of the Canadian political right as a needless division, and the two parties eventually agreed to merge in 2003. Red Tories however, maintained that the new party was more in the mould of the US Republican party than it was of the older Conservative tradition in Canada. The presence of the Red Tories and the NDP in Canadian politics remains the biggest key difference between Canadian and American political party culture, though it can be argued that views similar to those espoused by the NDP are held by a minority element of the Democratic Party, such as the "progressive" caucus. It is worth noting that the NDP has historically not held much influence at the national level, always placing a rather distant third (or more recently fourth) in national elections. Likewise, provinces in which the NDP has been elected to power, such as British Columbia and Saskatchewan usually feature only two standing political parties, thus making provincial NDP parties often more ideologically moderate than their federal counterpart.

Both countries have generally seen a shift in ideology towards the center in recent years, especially among parties of the left. Both Clinton-era Democrats and Chrétien-era Liberals have moved to dominate the center of the political spectrum, at the expense of harder left factions. This strategy has provided great long-term success for the Liberal Party of Canada, but less so for the Democratic Party of the United States.

In the United States, splits in the solidarity of 'the right' and 'the left' have generally been rather temporary, and quickly re-formed by binding together new coalitions, despite a more distinctive and enduring "liberal vs. conservative" culture that tends to make American political culture more dualistic. However, one of the most important changes in American politics over the last 40 years has been the switch in allegiance of many Southern white voters from the Democrats to the Republicans.

[edit] Bureaucracy

A key and often unnoted difference between Canada and the United States is the role of professional bureaucrats. In Canada, as in the UK, very few appointed officials lose their jobs during a shift of government even to a new party. While the Prime Minister of Canada has power within his government, these powers do not extend to the unionized public service.

In the United States, by contrast, over 2500 jobs are direct appointments of the President of the United States, cabinet ministers need not be drawn from elected Members of Congress/Parliament, and "the whole top rank of every federal department is swept away and replaced" with each election. This is very different from the UK public service and Canadian public service situation, and creates very different dynamics, most notably in the conduct of Ministers vs. Secretaries:

A British or Canadian Minister is often in his or her job for a short time, not a specialist in the particular area of government, and must trust his or her Deputy Minister to convey his or her requests to the bureaucracy underneath.

An American Cabinet Secretary always takes one job for the duration of the Administration, unless they are replaced or resign from the government entirely, and must be confirmed by the Senate, a process considerably less automatic than in Canada since the Senate may be controlled by the opposition party. Cabinet Secretaries are generally specialists in their fields, and have great power to replace their assistants, which extends considerably farther down into the agencies they control than in Canada. Originally nearly all civil service positions were assigned by patronage. However, since the Pendleton Civil Service Reform Act of 1883, the majority of the civil service, especially at the lower levels, is appointed by merit and belongs to the American Federation of Government Employees labor union. These jobs of these employees, like in Canada, are not dependent upon election results.

While there are plenty of globally-experienced Americans appointed by each President, they are of course different people, and tend not to be 'insiders' to international institutions, which engage in constant diplomatic and interest-group intrigue, requiring constant attention.

[edit] Centralization of power

In Canada the "checks and balances" are very different from those in the United States. It may be argued that the Prime Minister within Canada has vastly more power than the American President does. Since Canada's legislative and executive branches draw from one another, the Governor General (the representative of Canada's head of state, Queen Elizabeth II) rarely exercises the real legal powers available. Such instances are usually brought on by, or the cause of, constitutional crisis' such as King-Byng Affair, the last instance of a Governor General actively and independently exercising power over a Canadian government.

In Canada the Prime Minister must always have the largest group of supporters in the Canadian House of Commons in order to retain her/his position, as a result the Prime Minister's Office maintains strict discipline over his/her party caucus. This control has been tightened since 1968 as governments have consolidated power in the Office of the Prime Minister.

In the United States there are often periods of cohabitation where Congress is controlled by a different party than the White House. The president also has very limited control over the members of congress and must often bargain and make deals for support there. On the other hand, the Prime Minister does not have the luxury of cohabitation. If a majority of the House of Commons votes against the government on a matter of confidence, the Prime Minister must resign or call an election. The Prime Minister of a minority government, therefore, is in a far more precarious position than any American president, whose term is guaranteed by law. The minority Clark government of 1979–80 is famous for having attempted to govern as if it held a majority in the House of Commons; it fell in nine months.

The centralization of power in Canada has certain benefits and certain liabilities when compared with the American system. A clear line of authority means it is very clear who in government is responsible for any given issue. Unlike in the US, the Prime Minister is wholly accountable for the economy, security and other national concerns. The rigid control of Members of Parliament in Canada also serves to discourage corruption and reduce the influence of money in on Canadian Members of Parliament. Unlike American Senators and even Representatives, MPs do not need to raise great deals of money (one of the reasons why is described in the next section), and because they are far less powerful there is far less interest from companies to donate to them. While there is still great advantage in companies and unions donating to political parties as a whole, campaign finance reform in Canada recently outlawed such practices. The advantages of the US system include that it is more flexible and more representative as each congressperson can make their own decisions on each issue. This leads to greater regional representation by each party and helps discourage the proliferation of third parties which occurs often in Canada, although one may reasonably question whether the absence of third parties is on the whole an advantage.

[edit] Judicial system

The membership of the federal judicial branch in Canada is also closely controlled by the Prime Minister, who gives the final advice for the Queen in Council's appointment of Supreme Court judges. In the US, by contrast, all judicial appointments must be approved by the Senate. In an effort to democratize the Canadian system, borrowing from the US example, a process of convening a multi-party committee to publicly "review" Supreme Court appointments in Canada was established. However, the committee holds no veto power, unlike the US Senate.

Judicial activism has been a concern in both countries. However, prior to 1982, the Canadian judicial branch was far less powerful than the US one because Canada had nothing comparable to the US Bill of Rights. However, in 1982 under the urging of then-Prime Minister Pierre Trudeau, the Canadian Charter of Rights and Freedoms was added to the constitution giving the courts far more power. However, in Canada's charter there is a notwithstanding clause, which allows any government to protect a bill from certain areas of the charter for a period of five years. This has never been used by the federal government however, and the Supreme Court has also ruled that the Charter does not apply to the civil law.

[edit] Size of constituencies and campaign financing

The approximately 32 million Canadians are represented by 308 elected federal members of Parliament, or about 1 for every 100,000 Canadians of all ages. The number of seats in Parliament is readjusted every ten years, based on the results of the most recent census, and ensuring that the provinces do not fall below certain historical levels of seats. In contrast, the approximately 300 million Americans are represented by 535 elected federal legislators (435 members of the House of Representatives and 100 senators), or about 1 for every 500,000 people; seats in the House of Representatives are apportioned so that the total always remains at 435. In the current distribution of seats in the American House of Representatives, seven states currently have only one statewide representative. Conversely, no Canadian province has just one Member of Parliament representing the entire province — even Canada's smallest province, Prince Edward Island, is divided into four electoral constituencies.

The District of Columbia, Puerto Rico and the territories send delegates to the House who have a voice, and vote in committees, but have no vote on the final passage of legislation. The Canadian territories have just one territorial Member of Parliament and one Senator each, but these are full voting members of their respective legislative bodies.

Furthermore, American candidates for senator must campaign over an entire state, while candidates for president must campaign across the entire country. In Canada, however, each member of Parliament represents a local riding, most of which are compact (only in the far north does sparseness of population create large ridings). Urban ridings in Canada sometimes cover only 5 to 8 km². As well, Canadians do not directly vote for Prime Minister, but only for their local candidate, although in practice the party leaders do have to campaign nationally on behalf of their parties.

The effects of this difference on federal political financing are enormous. American candidates, campaigning over larger areas to a larger population, require much more money than Canadian candidates, and indeed more than candidates in any other industrialized democracy.

Canada, starting with the federal election of 2004, has strictly limited political donations by corporations and unions; in particular, corporations and unions may not make donations to registered political parties or to candidates for the leadership of a party, and their maximum contribution to a candidate for member of parliament is limited to $1,000. In addition, the political campaigns of all parties which obtain certain percentages of the vote receive public campaign funding, so the influence of corporate and union money is further diminished. In previous elections the influence of corporate and union donations was still less than in American elections, because of the much smaller cost of campaigning.

[edit] Multilateralism

Due to Canada's much smaller political and military size in relation to the United States, Canada has had little opportunity to act unilaterally and largely committed to the concept of multilateralism and collective security. After rejecting a major role in the League of Nations in 1935, it later became one of the strongest backers of the United Nations and the Commonwealth and supports most international initiatives, such as the International Criminal Court, and the International Ban on Land Mines. The United States pursues both unilateral and multilateral policies at different times. Many Americans distrust the United Nations as a corrupt institution interested in being a global challenger to the US and are unwilling to see their country's sovereignty impinged on. Both Canada and the United States are committed to international economic organizations such as the International Monetary Fund, the World Health Organization, the World Trade Organization and the World Bank.

[edit] See also

• Annexationist movements of Canada
• Canadian and American economies compared
• Politics of Canada
  • Federal Government of Canada
  • Political culture of Canada
  • Political history of Canada
• Politics of the United States
  • Federal Government of the United States
  • Political culture of the United States
  • Political history of the United States

[edit] Notes

1. ^ Warner (1960)

[edit] References

• Adams, Michael. 2003. Fire and Ice: The United States, Canada and the Myth of Converging Values. Toronto: Penguin. ISBN 0-14-301422-6. Reviewed by W.S. Neidhardt, Canadian Social Studies, V. 39, No. 2, Winter, 2005.[2]
• Christie, Nancy. "'In These Times of Democratic Rage and Delusion': Popular Religion and the Challenge to the Established Order, 1760-1815" in G. A. Rawlyk, ed .The Canadian Protestant Experience (1994)
• Clark; S.D.Movements of Political Protest in Canada, 1640-1840 University of Toronto Press. 1959.
• Errington, Jane The lion, the eagle, and Upper Canada: a developing colonial ideology McGill-Queen's University Press, 1987.
• Grabb, Edward , James Curtis and Douglas Baer; "Defining Moments and Recurring Myths: Comparing Canadians and Americans after the American Revolution" The Canadian Review of Sociology and Anthropology, Vol. 37, 2000
• Lipset, Seymour Martin. Continental Divide; The Values and Institutions of the United States and Canada (1990)
• Lower; Arthur R. M. Canadians in the Making: A Social History of Canada Toronto. 1958.
• McNairn, Jeffrey L. The capacity to judge: public opinion and deliberative democracy in Upper Canada 1791-1854 Toronto : University of Toronto Press, 2000.
• McNairn, Jeffrey L. "Publius of the North: Tory Republicanism and the American Constitution in Upper Canada, 1848-54." Canadian Historical Review 1996 77(4): 504-537. ISSN 0008-3755
• Moffett, Samuel E. The Americanization of Canada (1907)
• Schwartz, Mildred. Party Movements in the United States and Canada: Strategies of Persistence (2005)
• Smith; Allan. "Doing the Continental: Conceptualizations of the Canadian-American Relationship in the Long Twentieth Century" in Canadian-American Public Policy 2000. pp 2+
• Allan Smith, Canada—An American Nation? Essays on Continentalism, Identity, and the Canadian Frame of Mind (McGill-Queen's University Press, 1994)
• Goldwin Smith, Canada and the Canadian Question Toronto: 1891, numerous reprints
• Stewart, G. 1992. The American Response to Canada Since 1776 Michigan State University Press.
• Stewart, G. 1986. The Origins of Canadian Politics: A Comparative Approach
• Thompson, John Herd and Stephen J. Randall, Canada and the United States: Ambivalent Allies McGill-Queen's University Press, 1994
• Warner, Donald F. The Idea of Continental Union: Agitation for the Annexation of Canada to the United States, 1849–1893 (1960).