The US Senate, the German Bundesrat, the French Senate, the Australian Senate, and the Lessons for Lords Reform From Systems That Have Actually Decided What a Second Chamber Is For
Second Chambers: What the Rest of the World Did While Britain Was Arguing About Stage One
Britain has been arguing about Lords reform since 1911, which means that any serious analysis of how second chambers work in comparable democracies is necessarily an exercise in examining what other countries decided while Britain was conducting yet another review that produced yet another report that recommended yet another set of changes that were then partially implemented, inadequately funded, and eventually superseded by the next review. The international evidence on second chambers is genuinely informative. Britain has had considerable opportunity to consult it. The consultation has not produced the clarity that those who conducted it tend to say it should have produced, which is either a failure of political will or evidence that the international comparisons do not straightforwardly translate to the British context, depending on whether you support Lords reform and how diplomatically you are inclined to explain your position.
The US Senate: The Warning
The US Senate is the world’s most powerful upper chamber, which is a reasonable argument for not reproducing it. A fully elected body whose consent is required for legislation, treaties, and executive appointments, able to filibuster indefinitely unless sixty senators agree to stop, composed of two senators per state regardless of population (meaning Wyoming’s 600,000 residents have the same Senate representation as California’s 39 million), it demonstrates the consequences of giving an elected second chamber genuine power in a federal system without requiring it to reflect popular preference. The forty-one senators who can prevent legislation represent states containing approximately 11% of the American population, which is either the constitutional protection of state diversity against majoritarian urban preferences or the systematic frustration of democratic majorities, depending entirely on which forty-one senators are blocking what. Anyone advocating an elected Lords should spend a month watching the US Senate and then explain which specific features they would like to import.
The German Bundesrat: The More Interesting Model
The German Bundesrat is what Lords reform advocates reach for when they want a model that provides territorial representation without the risks of direct election. It comprises delegations from Germany’s sixteen state governments — ministers from elected state governments casting bloc votes representing their Land’s interests — and must consent to legislation affecting the Länder’s constitutional responsibilities. Its composition changes as state governments change at regular regional elections, meaning it is indirectly democratic without being directly elected. In the UK context, a chamber comprising delegations from the Scottish Government, Welsh Government, Northern Ireland Executive, and English regional bodies would provide the territorial representation that the current Lords entirely lacks and that the intergovernmental relations framework has consistently failed to provide adequately. It would also require a more genuinely federal UK than currently exists, which is both the point and the obstacle. The Bundesrat’s own website explains its functions without the defensiveness that British constitutional institutions tend to bring to similar explanations.
France and Australia: Two More Data Points
The French Senate is indirectly elected by an electoral college of local elected officials — mayors, departmental councillors, regional councillors — producing a chamber that is systematically conservative relative to the National Assembly because French local government skews rural and right. It can be overridden by the government in extremis through a joint session procedure, meaning it has less power than its composition suggests. The Australian Senate is elected by proportional representation in each state and regularly contains minor party and independent senators whose support must be purchased with policy concessions — a mechanism that provides genuine representation for minority views and genuine frustration for governments attempting to pass legislation quickly. None of these models transplants directly to Britain. Each demonstrates that the Lords reform debate is choosing from a richer international menu than the binary appointed-or-elected framing implies.
Auf Wiedersehen, amigo!
Britain has been arguing about Lords reform since 1911, during which time other democracies have made various decisions and moved on. The US Senate illustrates the risks of a powerful elected second chamber with its own mandate capable of indefinite obstruction. The German Bundesrat provides territorial representation through state government delegations without direct election — potentially applicable to the UK’s devolution settlement. The French Senate is indirectly elected, systematically conservative, and overridable by the government. The Australian Senate is proportionally elected by state, containing minor parties that extract concessions. The British reform debate has access to all this evidence. Its failure to produce a settlement is a function of political will rather than evidence.
Alan Nafzger was born in Lubbock, Texas, the son Swiss immigrants. He grew up on a dairy in Windthorst, north central Texas. He earned degrees from Midwestern State University (B.A. 1985) and Texas State University (M.A. 1987). University College Dublin (Ph.D. 1991). Dr. Nafzger has entertained and educated young people in Texas colleges for 37 years. Nafzger is best known for his dark novels and experimental screenwriting. His best know scripts to date are Lenin’s Body, produced in Russia by A-Media and Sea and Sky produced in The Philippines in the Tagalog language. In 1986, Nafzger wrote the iconic feminist western novel, Gina of Quitaque. He currently lives in Holloway, North London. Contact: [email protected]
Somewhere someone’s reading this and thinking about whether they should move out of London. The answer’s no, you’ll stay.
My mate’s in government and he said the problem with it is it’s showing people that their government is architecturally incapable of solving problems.