The idea that the United States and Canada should merge is not new. In recent years, too, Mexico has often been added to the concept to create a fully North American union. Most of these proposals emphasize economic advantages and cultural affinities, and they all have some merit. Less discussed is a more institutional and political approach, which recognizes that, if Canada needs a merger for long-term economic, demographic, and security reasons, the United States needs a merger even more to remediate its dysfunctional political system.
This used to be a very tough argument to make, because most Americans were unwontedly proud of their political system. They didn’t think they needed help from anyone. That was going to change eventually, and now it has: Most Americans know something is wrong, and at least some suspect the problem is structural. The result has been to flip the skepticism from “Why does the United States need Canada?” to “Why on earth does Canada need the United States?”
Alas, as an example, my latest book, Merger of the Century: Why Canada and America Should Become One Country, first saw light of day during the U.S. government shutdown in October 2013. The timing could not have been worse, because the ongoing budget debacle highlighted Washington’s dysfunction. One American interviewer asked me, “Who would want to join our mess?” Indeed. My rejoinder was that if Canadians agreed to join the U.S. political system they would vote overwhelmingly for the Democrats, ensuring control of the White House and Congress for at least a few election cycles and thus cleaning up the mess. I spoke too quickly, however; one-party dominance does not guarantee political efficacy. President Obama experienced plenty of difficulty during his first two years in office with a Congress controlled by Democrats, as did Jimmy Carter. The reality is that America’s system is flawed at a more fundamental level. Gridlock has caused U.S. government operations to be shuttered 17 times since the 1970s. The real contribution that Canada could offer the United States in this regard is the Westminster system of budget-making.
But dysfunction in the budgetary process is only one of America’s problems. Taken together, the breadth and depth of dysfunction lead one to conclude that, by any reasonable test of good governance—efficiency, accountability, transparency, alignment with the public interest—the U.S. system as it exists today fails. The Founding Fathers would have been better off adopting Britain’s system, minus the monarchy and House of Lords. Instead, they created an 18th-century prototype that lurches along in the 21st century, unable to make decisions, scarred with acrimony, and ripe with fiscal calamity. (Samuel Huntington likened this prototype to the 16th-century Tudor model, which emphasized “courts and parties” at the expense of a strong executive.) A merger with Canada’s political system would do the trick, minus the monarchy and its unelected Senate, which is a de facto House of Lords. Canada’s businesslike parliamentary governance template, along with its untapped resources and America’s economic strength, would establish an unbeatable superpower.
We should not, of course, underestimate the difficulties and complications. Would Canada’s provinces become states, with two Senators each and proportional inclusion in the House? How would the different health care systems be managed in a union? What about significant alternative legal approaches to various functional issues, not to speak of the U.S. Constitution itself? Obviously, a union would need to be sequenced into being over time, and a group of Wise Men (and Women) would need to be in operation for several years.
Even a de minimus approach to union is unachievable at present, to say the least. I know that. Neither country can even figure out how to fix its postal system, after all. Even so, a comparison of the two illustrates the efficacious elements, and the superiority, of a parliamentary system. So does the fact that most countries that have democratized in the past century have opted for its basic architecture. For these reasons and others, Americans would be well advised to understand the advantages that parliamentary institutions deliver as a template to revise their democracy, merger or no merger.
Nearly 1,000 years ago the British King began to formally consult with an advisory board consisting of nobles and bishops, the forerunner of the House of Lords. Eventually, knights and mayors of towns were invited too, the forerunner of the House of Commons. In 1401, the King, facing a threat to his throne, gave the Commons authority to control taxation in return for its loyalty.
In 1867, Canada adopted the Westminster system (named for the Palace of Westminster in London where Parliament sits) after Britain began loosening the reins on its remaining North American colonies. There would be a House of Commons, a Senate (a version of the House of Lords, comprised of rich or influential appointees) and a Governor-General, who would act on behalf of the British Monarch as Canada’s head of state.
The defining difference between Canada’s political history and that of the United States is that parliaments fuse together their executive and legislative branches in an effective fashion. A Prime Minister is like a CEO working in concert with executive and management teams. The Canadian Prime Minister is not elected separately, like a President, but is a Member of Parliament who holds a seat and also leads the political party with the most seats in the House of Commons. Originally, monarchs appointed those who demonstrated they had the “confidence” of parliament, or majority support, and could obtain “supply” of money from the public. In other words, they wanted people who could execute their wishes.
The job description remains, but Prime Ministers and their parties are now elected by voters, not appointed by the Crown, and serve at the pleasure of the public as long as they maintain control. If they lose their majority, they must form a coalition with one or more other parties to control at least 51 percent of the seats. If that is not possible, Prime Ministers who lose the “confidence” of Parliament to get “supply” must resign. An election is held within weeks, one ancillary or “accidental” benefit of which is to constrain the electoral season so that plutocrats cannot plan months and even years ahead to suborn the electoral process with their money. And the Westminster system, because it seals the budgetary process off from most forms of horizontal penetration, also makes it more difficult to buy or rent politicians after they are elected.
The threat of being tossed out of office, and the requirement to retain the “confidence” of the House, is why parliamentarians tend to seek consensus and compromise rather than confrontation. In 2010, for instance, Britain’s David Cameron obtained only 32.4 percent of the vote and could not become Prime Minister unless he joined forces with another party. He chose the party in third place, the Liberal Democrats, which had garnered 22 percent, for a total of 54.4 percent. Members of both parties hold positions in his cabinet. As long as this coalition holds, Cameron can govern for up to five years before the next election.
Paradoxically, the fact that parliamentary governments can be dissolved at any time is not usually destabilizing. The opposite tends to be true, at least in systems with a small and relatively stable number of parties, because parties will go to great lengths to find common ground in order to stay in office. This makes parliaments more productive, disciplined, and capable of resolving disputes than two-party presidential systems. (Presidential systems naturally tend to two major parties because it takes 51 percent to elect a President, which is why coalition-building must happen before elections. In parliamentary systems it can also take place after elections.) The founding mission statement of Canada’s Founding Fathers was to provide “peace, order and good government”, and thus far the mission has been pretty well accomplished.
The American system, by contrast, followed a bloody revolution against the King of England and his puppet parliament. The Founding Fathers had to devise a process to avoid tyranny that their scrappy, mostly uneducated, and rebellious electorate could understand and trust. They replaced the King with an elected President, indirectly chosen by an Electoral College to avoid the “tyranny of the majority.” To keep him in line, they created two separate legislative branches that could veto whatever he initiated; to keep legislators in line, they gave the President a veto. And to keep both in line they created a Supreme Court that is the least democratic of the three branches of American government.
The separation of powers was supposed to keep everyone honest, but American federalism was also an adversarial system that pitted everyone against one another. If America were a corporation, its bylaws would partition the CEO from his executive and management teams and place them permanently at odds. This structure institutionalizes a bad marriage by tolerating drawn-out battles and blockages within the Legislative Branch and between it and the Executive Branch. There is no punishment for obstructionism, except a drop in public opinion, and no arbiter who can demand decisiveness.
Over the years, however, Federal courts have managed to fill the crevasses of public policy deficits (especially since the passage of the 17th Amendment in 1913), but the Founders never intended the courts for this purpose. The flaws in the original structure have led to a creeping judicialization of American politics that makes it less democratic in many respects than most European parliamentary systems. The result is that America’s transformative idea two centuries ago has become a serious competitive disadvantage today, what Francis Fukuyama has called a vetocracy.1 This is not a new insight. In 1885, Woodrow Wilson, then of Princeton University, wrote Congressional Government, about the dysfunction of the American system and the benefits of a parliamentary one:
As at present constituted, the federal government lacks strength because its powers are divided, lacks promptness because its authorities are multiplied, lacks wieldiness [sic] because its processes are roundabout, lacks efficiency because its responsibility is indistinct and its action is without competent direction.
Think what you will about Wilson as President, but this he got dead to rights.
Budgets are more than just accounting exercises. They are critical tools for organizations to plan and manage operations. Government budgets inform the public about taxes, forecasts, and the cost of policy initiatives. They reveal the state of the nation and provide critical guidance to voters and markets. They are, therefore, important political documents in a democratic governance system.
Parliamentary and presidential systems require approval of a budget every year. But a Prime Minister who fails to gain approval for a budget is removed from office while a President and Congress that fail can simply kick the can down the road by approving stopgap measures to keep operations going. Unfortunately, this perpetuates disagreements and accepts indecisiveness. It is why the last budget approved in Washington dates back to fiscal year 2010.
If the United States were a publicly listed corporation, with the CEO, management and executives at war over budgets, it would have long since been de-listed from stock exchanges. But governments don’t get de-listed; their creditworthiness get downgraded. So in 2011 Washington’s internecine warfare caused a rating drop from AAA to AA+, and Standard & Poor’s issued the following statement: “The downgrade reflects our view that the effectiveness, stability and predictability of American policymaking and political institutions have weakened at a time of ongoing fiscal and economic challenges.”
Now, parliamentary systems do not guarantee better judgment, nor do their politicians faithfully ascribe to fiscal rectitude. But they can expeditiously respond to crises or public groundswells. In 1992, Canada’s debt rating was downgraded from AAA to AA+ after a downturn and years of profligacy. Markets, business, the public, and media criticized the government publicly and privately. The Liberal government immediately reversed course for its February budget and announced cost-cutting measures, downsizing government departments and raising taxes to fix the fiscal challenges. They retained majority control and were able to impose austerity measures for several years until budgets were balanced. By 2002, the credit rating was restored to AAA.
The budget process is sacrosanct in Westminster parliaments. In Canada, the Minister of Finance publicly announces his budget in February or March, and the budget is usually approved within days. In Canada, there have been only three “no confidence” votes in parliament leading to resignations and snap elections in fifty years, and there has never been a government shutdown. Under Canada’s constitution, the Governor-General allocates funds to keep the lights on during election periods when no budget is in place. This removes from the political fray a decision that could jeopardize the nation’s fiscal health or survival.
By contrast, the American budget process is impracticable. The President submits his budget in February, and then House and Senate Budget Committees hold separate hearings. Their determinations and revisions are tabled in their respective houses and, if approved, are sent to a House-Senate Conference that attempts to reconcile and resolve disagreements. All this is to be completed within weeks but, needless to say, never has been.
The latest hostilities erupted after Republicans gained control of the House of Representatives in the 2010 midterm elections. Since then, they have fought the Democrat-controlled Senate and the President over the budget page by page and paragraph by paragraph. They have attempted to tie unrelated issues to their approvals, such as defunding the Affordable Health Care Act, shutting down the government, or even threatening to let the Treasury default by refusing to raise the debt ceiling, notwithstanding the fact that since 1983 the ceiling has been routinely raised 15 times. By December, the public had run out of patience and public opinion polls plummeted to a historic low of a 12 percent approval rating of Congress. This led lawmakers in January to sign another allocation deal, but a comprehensive budget deal still eluded them, and another debt-ceiling ultimatum loomed.
It’s instructive in this light to imagine America’s political landscape in a parliamentary context. Some may argue that gridlock is unavoidable in the United States due to the nature of America’s polarized and complex society. Not so: Polarization is not the cause, but the result, of a political process that amplifies and extenuates conflicts. Canada is nearly as diverse and polarized as the United States, but its parliament delivers businesslike efficiency and democratic accountability. For decades, five political parties have held seats in Canada’s House of Commons, along with a handful of independents. These currently include parties ranging from center-right to center-left, socialist, Quebec separatist and Green. Britain’s Parliament has nine sitting parties and Germany has five.
As already suggested in passing, multiple parties are a characteristic of parliamentary governments and bestow several benefits. America has never been able to support a viable national third party, although several candidates have surfaced over the years. Only two garnered significant support: Teddy Roosevelt won 27.5 percent in 1912 for his Progressive or Bull Moose Party, and Ross Perot won 18.9 percent in 1992 for his fiscally prudent Reform Party. Again, this is because a presidential system requires an outright majority of Electoral College votes to elect a President, and so naturally tends toward a two-party system.
Yet the appearance of new leaders and ideas is healthy for a democracy. As Perot’s former campaign manager Clay Mulford told New York Magazine in 2006, under a two-party system the nation lost “the ability for things to bubble up from the body politic and give voice to things that aren’t being voiced by the major parties.” Multiple parties help voters identify ideologies, alliances, and allegiances by party affiliation. A ballot in Canada or Germany offers a choice of local candidates, but voters select the candidate whose party and leader they respect. Americans, by comparison, often vote for individuals irrespective of their parties.
In this sense, parliamentary democracy is a team sport, not an individual endeavor. And, clearly, it takes a team to pass a budget or run a government. “It could be Donald Duck on the ballot and Canadians will vote for the party and leader that can get the job done”, John Manley told me in 2014. He is the former Deputy Prime Minister of Canada, Finance Minister, and seasoned parliamentarian who was a Member of Parliament between 1988 and 2004.
Reliance on strong political parties and leaders reduces the excessive influence peddling and lobbying that co-opts and corrupts America’s Congress. This is because Members of Parliament are the political equivalent of legs on a centipede and must vote the party line or be expelled from the caucus. Only Prime Ministers can be effectively lobbied to change policies or direction. But this power is also held in check, as Manley explained:
In parliamentary systems, the leaders cannot be dictators. They need the support of their caucus, their confidence. You could lose confidence if a majority or key members of your own caucus threaten to defect unless you change course. Every caucus Member of Parliament thinks of his own re-election chances. They go home every weekend and don’t need opinion polls to smell trouble. If their Prime Minister is unpopular, they know it and they thrash this out in caucus.
Such backlashes can unseat the most entrenched leaders between elections or party conventions. For instance, Britain’s longest-serving Prime Minister in the 20th century, Margaret Thatcher, was forced to resign after 15 years. In 1940, Neville Chamberlain was pressured to leave, by his own caucus, for making concessions to Hitler. All of Britain’s parties supported Winston Churchill to replace him as wartime Prime Minister. In Canada in 2003, Jean Chrétien resigned after three terms following a mutiny against him led by his ambitious Finance Minister. What went on in Australia’s Labor Party in recent years between Kevin Rudd and Julia Gillard furnishes material suitable for a Shakespearean comedy (or tragedy, depending on one’s tastes in entertainment).
Again, these observations are not new. In The English Constitution, Walter Bagehot decried America’s “presidentialism” in the 19th century because power could not be transferred in an emergency:
The American government calls itself a government of the supreme people; but at a quick crisis, the time when a sovereign power is most needed, you cannot find the supreme people. You have got a congress elected for one fixed period, going out perhaps by fixed installments, which cannot be accelerated or retarded—you have a president chosen for a fixed period, and immovable during that period.
Woodrow Wilson, influenced by Bagehot, waded in by comparing a Prime Minister and President in terms of duties, pointing out that a do-nothing President would be impossible to remove. There would be no grounds to do so: “A Prime Minister must keep himself in favor with the majority, a President need only keep alive.”
In parliaments, party discipline is not always rigid and is occasionally relaxed so members can cast “free votes” or “conscience votes” rather than follow the official line set down by their party. These involve religious, moral, or ethical issues. In 2013, for example, Prime Minister Cameron failed to get support from opposition parties, and from a dozen of his own Conservatives, to authorize military strikes in Syria. Technically, he could have authorized military strikes without parliamentary approval and without triggering an election, but during Question Period he said, “It is clear to me that the British Parliament, reflecting the views of the British people, does not want to see British military action. I get that, and the government will act accordingly.”
By comparison, America’s parties herd cats all the time. This is because they are not parties in the parliamentary sense, but coalitions of convenience for entrepreneurial politicians who seek party branding in order to get on ballots or get financing. Once elected, they often end up representing competing or extremist agendas, regional interests, ideologies, and goals that vary from party platforms or from their congressional leaders’ recommendations. This, in turn, opens up many fronts of political warfare: the Senate versus the House, the President versus one or both, and dozens of partisans against one another. It also spawns an “American Idol” political culture in which sabotage or posturing by rogue politicians, like Paul Ryan or Ted Cruz or Michele Bachmann, vaults their profiles and prospects beyond that of party loyalists or even leaders.
To illustrate the differences, here is what Washington would look like in a Westminster scenario. The House of Representatives would be in charge of taxation and spending. The Senate would provide second consent on laws, and could make recommendations about budgets, but not veto them. The President would be head of state, elected by the Electoral College, and would be given important “reserve powers” designed to guarantee political stability. Each party member would have to vote the party line, and toe the line. “Parties emerged early in the parliamentary system because the key is the government must have the confidence of the House and a leader must find a way to assemble that”, explained Manley. “The whips tell each member you are entitled to express your opinion in caucus, you can give a speech, but you cannot vote against the party because that may hurt us and that will hurt you because you need our party.”
Imagine, then, that in 2008 Barack Obama was elected Prime Minister as leader of the Democrats with more than 50 percent of the seats; John McCain was opposition leader of the Republicans with 40 percent; Ron Paul led the Libertarians with 7 percent; and Al Gore led the Green Party with 3 percent. Despite these divisions, budgets passed every year, and no debt downgrade came in 2011. Imagine that in 2012 sentiment shifted somewhat against the Democrats and the Tea Party split from the Republicans. Prime Minister Obama slid to 47 percent of seats; Mitt Romney’s Republicans to 35 percent; the newly formed Tea Party headed by Sarah Palin won 10 percent; the Libertarians led by Rand Paul 4 percent; and the Green Party headed by Al Gore 4 percent. By falling to 47 percent, Prime Minister Obama would be naturally inclined to ally himself with the Green Party or else lose “confidence” to an alliance of Republicans, the Tea Party, and Libertarians. If his support decreased to 45 percent, he would have to consider a “grand coalition” with the Republicans to stay in power by making dramatic budget concessions and offering important cabinet positions. If his support dropped further, a coalition of the other three could form or, if deemed destabilizing or unworkable by the President, an election would be called to let voters decide who should govern.
This thought experiment underscores how a parliamentary structure better reflects voter choices and necessitates compromise. An American parliament would also be more transparent and accountable, and relatively free from moneyed interests. As happens now in Canada, every day that parliament were in session, Question Period would be televised for 45 minutes from the chamber of the House of Commons. The Prime Minister and his cabinet would answer questions from leaders or designated members of the other parties, a ritual designed to hold the government accountable. Parliamentary privilege allows members to speak freely without fear of legal action for slander, contempt of court, or for contravening laws that protect state secrets. Since the mid-19th century, this immunity has protected parliamentarians from intimidation, violence, or interference by former monarchs and their henchmen. Today, immunity allows delicate and controversial matters to be brought to the public’s attention on a timely basis. Question Period exchanges in parliament become headlines and broadcasts, thus enhancing the media’s role.
An American Parliament would also have twenty standing committees, not the 200 now in Washington, to review and make suggestions concerning bills and budgets. These committees would also hold proceedings in public, and transcripts would be available to the press and the public. An interested citizen can reasonably follow twenty discussions and debates, not 200.
Woodrow Wilson blamed the congressional committee system for corruption and for being undemocratic. As constituted then and now, committees are run by chairs who are selected strictly on the basis of seniority, often conduct meetings in private, and generally are unaccountable. In 1885 there were 47 committees, which Wilson described as being
divided up, as it were, into forty-seven seignories, in each of which a Standing Committee is the court-baron and its chairman lord-proprietor. These petty barons, some of them not a little powerful, but none of them within reach [of] the full powers of rule, may at will exercise an almost despotic sway within their own shires, and may sometimes threaten to convulse even the realm itself.
Governance models have always been designed to meet specific and unique social and political objectives. The result has been many forms of government capable of good government, and many forms of democratic government capable of democracy. The Americans aimed to eliminate monarchy from their lives and keep government prerogatives in check at all times. The British objective was to keep a watchful eye on taxation and royal spending. The Swiss wrote a constitution in 1848 that smoothed over their religious divisions following a brief civil war between Protestants and Catholics; the result is a highly non-transparent but collegial system. The Germans bolstered their system following the hijacking of the Weimar Republic by the Nazis; in it, coalitions are built for four-year tenures, there can be no snap elections, and the President’s powers are weak. All these systems of democracy are distinct, and they all work reasonably well.
It is tempting to want to pick the best of each type and combine them. To my way of thinking, the optimal model would consist of a unicameral Parliament that would incorporate the discipline and efficiency of the Westminster system and the stability of Germany’s government. The President would be a figurehead, selected from a blue-ribbon list of candidates, capable of representing the nation with dignity and intelligence, and empowered to protect the constitution in times of crisis. But different societies evolved different systems for good reasons, and a weak President may not suit a country like the United States that has long had an unusual international security role as guardian of the global security commons. So hybrids may be attractive in theory, but impractical in reality.
Even more important, the difficulty of bringing them about may be tied to the historical particularities of each nation. It so happens in the case under scrutiny—a U.S.-Canadian merger—that the amending formula of the U.S. Constitution makes minor revisions difficult and a complete rewrite impossible. Only three amendments have passed since 1913 that address the structure of the Federal government. The Canadian constitution is similarly impregnable. The 1982 Constitution Act was unsigned by Quebec, the 1987 Meech Lake Accord was unsigned, and the 1992 Charlottetown Accord failed to win approval in a national referendum. So even if an enthusiastic majority of Americans and Canadians came to see the wisdom of a merger, it’s not self-evident that existing legal structure provides a means for it to come about.
Creating a new entity, or a “newco”, to use business jargon, allows parties to formulate a structure that encompasses the best practices and elements of both in order to deliver the desired outcomes. The merging entities are then vended into the “newco”, an event that would only happen if Canada and the United States decide to fully merge or to create a binational entity similar to the European Union. That would take years or even decades, if it ever happens at all; but in the meantime, both countries certainly need to re-examine their governmental operations, and they would be wise to do so in a way that makes the merger option ultimately easier to achieve as time passes.
Canada’s parliamentary system works well, but its patronage-addled and superfluous Senate should simply be abolished. The United States should, at the very least, create a Commission of Operational Reforms to recommend how to simplify its budget process, forge a mechanism to induce compromises, gut the congressional committee system, and enhance transparency. In this regard, Wilson recommended what he called “cabinet government”, wherein a de facto fusion of Executive and Legislative branches could eliminate friction and warfare by requiring the President to appoint key legislators to sit in his cabinet. This would bring about blended policies as well as provide cabinet ministers who could command votes to get legislation and budgets passed in a timely fashion.
Wilson was unable to enact such a scheme while President from 1913 to 1921, but that doesn’t mean it can’t be done. Nor does it mean that other avenues to a similar destination cannot be imagined. Newt Gingrich, in his Contract with America, attacked the congressional committee status quo by suggesting that the number be cut in half or more; that staff budgets be decreased by one third; that term limits be placed on committee chairs; that proxy votes in committees be banned; and that all meetings be open to the public and press.
Even well short of such dramatic innovations, the U.S. budget process could be simplified and expedited by referring the President’s budget request directly, for sixty days, to a joint Congressional Super Committee of 12 legislators, similar to the Joint Select Committee on Deficit Reduction struck in August 2011. Membership would consist of six from the House and six from the Senate, with an equal representation of Democrats and Republicans. They would consult, review, and finalize a revised budget for a simple up-or-down vote, without amendment, in both Houses—just as the votes on BRAC and fast-track trade authority have worked in years past. If rejected, the previous year’s budget would remain effective. This process could be repeated until successful. While draconian, some mechanism is clearly needed to stop the destructive partisan gaming that has been going on now for far too long.
Most urgently, debt ceiling brinkmanship must cease. One way to stop it is to agree to index the ceiling to GDP growth and require approval only if debt levels exceeded growth. Without this, obstructionists can flirt with default, as happened in 2011. This procedure is equivalent to letting toddlers play with matches to the point of immolating the entire global economy. The inherent danger underscores the need for immediate debt ceiling reform in the national and global interest.
Indexation and other reforms, budget related and otherwise, would bring the U.S. political system incrementally closer to what works in Canada. A merger with Canada would do the trick tomorrow morning if it could be done, but such a radical maneuver would require the reincarnation of risk-taking and radical Founding Fathers on both sides of the current U.S.-Canadian border.
Clearly, those aptitudes are missing. The situation genuinely perplexes, given America’s aspiration, in every other endeavor, to be efficient, innovative, and best in its class. Yet when it comes to politics Washington historically cannot, short of a system-threatening domestic or national security crisis, deliver decisiveness, transparency, accountability, or alignment with the public interest. This is not because bad people operate within a good system; it is because the system itself is flawed, and those flaws stand out against the backdrop of the 21st century in ways that have never before been so apparent.
Options for change exist; Canada is there. But Americans will probably continue to select “none of the above” until they finally admit in majority numbers that the present U.S. Federal system is no way to run a nation, a corporation or even, for that matter, a self-respecting lemonade stand.
1Fukuyama, “The Decay of American Political Institutions”, The American Interest (January/February 2014).