The Electoral Commission is currently consulting on its performance standards for Returning Officers in Great Britain. Here’s my response (with the full consultation document embedded below).

Dear Ross Clayton,

Thank you for the opportunity to comment on the draft Returning Officer performance standards.

As you rightly identify (p.6), one of the key principles for each election should be participation: “it should be straightforward for people to participate in our elections, whether campaigning or voting”.

However, the campaigning aspect of this is only partially followed up in the standards themselves. Performance Standard 2c covers some aspects of this, and the inclusion of informal nomination checking is particularly welcome. However, it misses out the timely provision of electoral register and absent voter data to candidates and agents. A common problem at the moment, for example, is for the final additions to the absent voter list before polling day to be provided to agents only several days later, which then leaves very little time for agents and candidates to make use of such data. Prompt provision of electoral register data and absent voter data is essential for the principle of straightforward participation to be meaningful. This could be met by adding a requirement to have target response times for dealing with requests for such data and recording the proportion of requests which were met within the target time.

In addition, the people aspect of the participation principle is not followed through in Performance Standard 2a, Polling Station set-up. This, rightly, requires Returning Officers to consider accessibility issues when choosing polling station locations. However, it does not require Returning Officers to consider the impact on turnout of the distances people have to travel to vote. There is growing evidence that the further people have to travel to vote, the lower turnout is (particularly outside of general elections); for example see https://www.libdemvoice.org/what-do-the-academics-say-more-polling-stations-can-raise-turnout-25200.html.

Performance Standard 2a would therefore better meet the underlying principles for the standards if it required Returning Officers to review turnout data and consider whether to make any changes to polling station numbers and locations.

Finally, on a slightly different point and given that 100% checking of postal voting identifiers is sometimes a cause of controversy, I would like to add my support to your proposed inclusion of this in the performance standards.

Yours,

Mark Pack
Former member, Electoral Commission Political Parties Panel and co-author, “The General Election Agents’ Manual”

Electoral Commission: Consultation on Performance Standards for Returning Officers