FEDERAL-STATE RELATIONS COMMITTEE
Report on
FEDERALISM AND THE ROLE OF THE STATES:
COMPARISONS AND RECOMMENDATIONS
Appendix 2: Comparative tablesTable 1: Features and powers1
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United Kingdom (1707)2 |
United States (1789) |
Canada (1867) |
Australia (1901) |
Germany (1949) |
Belgium (1831) |
European Union (1957) |
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FEATURES Where does residual power lie? Are state powers enumerated? No. of component units Population |
Central No 4 59,008,600 |
State No 55 271,709,700 |
Federal Yes 13 30,300,400 |
State No 8 18,500,000 |
State No 16 82,570,400 |
Federal Yes 53 10,170,000 |
State No 15 374,564,000 |
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SCOPE OF POWERS Finance and Fiscal Relations Taxation: Customs Excise Corporate Personal Income Sales Other Equalisation Debt and Borrowing: Public Debt (of fed.) Foreign Borrowing Domestic Borrowing |
Central Central Central Central & S Central - None
Central Central Central |
Federal Joint Joint Joint Joint - None
Federal Federal & State Federal & State |
Federal Federal Federal & State Federal & State Federal & State - Federal
Federal Federal & State Federal & State |
Federal Federal Joint Federal Federal - Federal
Federal Federal & State Federal & State |
Federal State Joint* Joint* Joint* - Federal & State
Federal Federal & State Federal & State |
Joint Joint Joint Federal & State Joint State Federal
Federal All levels All levels |
Federal Federal State State State - Federal
Federal Federal & State Federal & State |
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United Kingdom (1707) |
United States (1789) |
Canada (1867) |
Australia (1901) |
Germany (1949) |
Belgium (1993) |
European Union (1993) |
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International Relations Defence Treaty implementation Citizenship Immigration (into federation) Immigration (between states) |
- Central Central Central Central Central |
- Federal & State Federal Federal Joint - |
- Federal Federal4 Federal Joint - |
- Federal Federal Federal Federal - |
Federal Federal Federal & State Federal & State* Joint* Joint* |
Federal Federal All levels Federal Federal - |
Federal & State State Federal & State Federal & State Federal & State Federal |
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Economic Union Trade & Commerce External trade Inter-state trade Intra-state trade Currency Banking Bankruptcy Insurance |
Central Central Central Central Central Central Central Central |
Federal Federal Federal State Federal Joint Federal & State Federal & State |
Federal Federal Federal State Federal Federal & State5 Federal Federal & State |
Federal Joint Joint State Federal Joint Federal Joint |
Joint* - - - Federal Joint* - - |
State & Community Federal & State - - Federal Federal - Federal |
Federal & State Federal Federal Federal & State Federal State State State |
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Transport & Communication Roads & Bridges Railways Air Telecommunications Postal Services Broadcasting |
- Central, S & W Central, S & W Central & S Central Central Central |
- Federal & State Federal & State Federal Federal & State Federal Federal |
- State Federal & State Federal Federal & State Federal Federal |
- Federal & State Federal & State Federal & State Federal Federal Federal |
Federal & State* Joint* Federal & State* Federal Federal Federal Federal & State |
- State & Community Federal Federal & State Federal Federal State & Community |
Federal & State Federal & State State State State State State |
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United Kingdom (1707) |
United States (1789) |
Canada (1867) |
Australia (1901) |
Germany (1949) |
Belgium (1831) |
European Union (1957) |
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Agriculture & Resources Agriculture Fisheries Mineral Resources Nuclear Energy |
S & W S & W S & W Central |
State State State Federal & State |
Joint Federal & State Federal & State Federal |
Joint Federal & State State Joint |
Joint* Joint* Joint Joint |
State State Federal |
Federal Federal State Federal & State |
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Social Affairs Education & Research: Primary & Secondary Post-secondary Research & Dev. Health Services: Hospitals Public Health Labour & Social Services: Unemployment Ins. Income Security Social Services Pensions |
S & W S & W Central & S
Central S & W
Central Central S & W Central |
State Federal & State Federal & State
Federal State
Federal & State - Federal Joint |
State State
Federal State
Federal Federal & State Federal Joint |
State Federal & State Federal & State
Federal & State State
Joint Joint Joint Joint |
State Joint* Joint*
Joint* Joint Joint* Joint* Joint* - - |
State & Community State & Community All levels
State & Community State & Community
Federal Federal State & Community - |
State Federal & State Federal & State
State State
State State Federal & State State |
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Law & Society Civil Law Criminal Law Organisation of Courts Police Prisons |
Central & S Central & S Central & S Central & S Central & S |
State State Federal & State Federal & State Federal & State |
State Federal Federal & State Federal & State Federal & State |
Federal & State State Federal & State Federal & State State |
Joint* Joint* Joint* State - |
Federal - - Federal - |
Federal & State State Federal & State Federal & State State |
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Other Matters Language Culture Indigenous Affairs Environment Municipal Affairs |
S & W S & W - S & W S & W |
- - Federal Federal & State State |
Federal & State Federal & State Federal Federal & State State |
- - Joint Federal & State State |
- State - Joint* State |
All levels All levels - State All levels |
Federal & State Federal & State - Federal & State State |
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Source : Ronald Watts, Comparing Federal Systems in the 1990s, Institute of Intergovernmental Relations, Queen’s University, Kingston, 1996, Appendix A (for United States, Canada, Australia, Germany, Belgium).1Note on terms:the term “Joint” refers to a policy area where both Federal and State Governments act. Where a policy area is described as “Federal & State”, there is division of competence within the policy area. A dash indicates that the matter is not explicitly referred to in the constitution, or is left to the residual authority. 2For the United Kingdom only: Central = Government of Great Britain; S = powers held by the Scottish Parliament; W = powers held by the Welsh Assembly. 3Overlapping Regions and Communities. 4Consent of the Provincial Governments is required. 5Banking is exclusively federal; savings and credit unions are provincial. *Federal legislation is administered by the Länder. Table 2: Upper houses: selection, composition and powers6
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United Kingdom7 |
United States of America |
Canada |
Australia |
Germany |
Belgium |
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Title |
House of Lords |
Senate |
Senate |
Senate |
Bundesrat |
Senate |
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Selection |
Appointed by the Government, either as a life or hereditary peerage. The former do not pass their position on to a successor. |
Elected by voters of each State, according to first-past-the-post system. |
Appointed by the Federal Government. |
Elected by voters of each State, according to proportional representation system. |
Members of State Governments, appointed by their Government. |
Direct election and appointment. |
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Length of term |
Life. |
6 years (one third of the Senate is elected every 2 years). |
Senators sit until age 75 (for life, if appointed prior to 1965). |
6 years (one half of the Senators are elected every 3 years). 3 years for Territory Senators. |
Composition changes according to change of government in each Land. |
All periods of election or appointment are for 4 years. |
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Composition |
Archbishops and bishops: 26 Peers by succession: 751 Hereditary peers of first creation: 8 Life peers: 509 Total number of members: 1,294 |
2 Senators for every State. Total number of members: 100. |
Equal representation for 4 regional divisions, + 8 additional Senators for Newfoundland, Northwest Territory, Nunavat and Yukon. Total number of members: 104. |
12 Senators for each State; 2 for each Territory. Total number of members: 76. |
Multiple members for each state, apportioned according to population. Total number of members: 69. |
Forty Senators directly elected from Community electorates; 21 appointed from the Community Councils; 10 appointed by other Senators. Children of the monarch (currently 2) sit as of right. Total number of members: 73. |
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Voting pattern |
Along party lines; many peers sit on the crossbenches. |
Mixed voting: according to party lines or State issues. |
Along party lines. |
Along party lines. |
Votes are cast in state blocks. |
Mixed voting: according to party or Community affiliation. |
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Federal government representation |
Yes. |
No. |
Yes. |
Yes. |
No, although members of the Federal Government have a right to be heard. |
No. Ministers may be selected from the Senate, but must have a replacement for so long as they remain in the Ministry. |
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Powers |
Has no veto or amendment powers. Money bills may only be delayed for one month. All other legislation may come into force regardless of the opinion of the House of Lords, if House of Commons votes for it in 2 sessions, with 1 year between sessions. Also acts as final Court of Appeal. |
Equal to the House of Representatives. Money bills must originate in the House of Representatives, but may be amended or rejected by the Senate. |
Equal to the House of Representatives. Money bills must originate in the House of Representatives, but may be amended or rejected by the Senate. |
Equal to the House of Representatives. Money bills must originate in the House of Representatives, but may be amended or rejected by the Senate. |
Suspensive veto on federal exclusive powers which may be overridden by the Bundestag; absolute veto on concurrent powers and amendments to Basic Law. Mediation Committee in case of deadlock. |
Equal to Chamber of Deputies on some matters, but on others the Chamber has overriding powers. It has the power to mediate conflicts of interest between parliaments at the federal or Community level. |
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6The European Union has been excluded from this table since it does not possess an upper house. 7The House of Lords currently is subject to a Royal Commission on changes to its selection, composition and functions. |
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