This article summarizes recent developments relating to accountability.
It examines institutional characteristics that diminish Parliament's ability
to hold Ministers and Officials to account and looks at prospects for improved
accountability in the future.
The Gomery Commission was given two mandates: to inquire and report on
who was responsible for the sponsorship scandal; and, then, in a second
report, to make recommendations to address shortcomings in the governance
and accountability regime. The establishment of the commission of inquiry
and the selection of a judge to be sole commissioner acknowledged the perceived
limits of the parliamentary processes of holding ministers and officials
to account, and thus the requirement of an independent commissioner,
preferably someone seconded from the judicial branch of government.
The commission did what was expected of it. It named many who were responsible
in some manner; it blamed a smaller crowd; and, it shamed a few. There
is no need to repeat the verdicts. However, it is worth noting that Gomery,
in Volume 1, concluded that: Three main factors
caused or contributed
to the problems. They were:
the unprecedented decision [by the Prime Minister] to direct the Sponsorship
Program from the PMO, bypassing the departmental procedures and controls
which the Deputy Minister of Public Works and Government Services Canada
would normally have been expected to apply and enforce;
the failure of the Deputy Minister of PWGSC to provide oversight and administrative
safeguards against the misuse of public funds;
the deliberate lack of transparency on how the Program was initiated, financed
Significant here is the juxtaposition of political management the role
of the PMO and the failures of the professional public service the
signaling out of the DMs responsibilities leading to deliberate secrecy
in government operations. The maladministration, in short, could occur
only because the public service was willing to go along with what ministers
and their political staff wanted.
People were named, blamed and shamed. But, equally important, the structure
of power was questioned. At issue was how ministers, let alone their political
staff, could think it proper to run roughshod over the established authority
structures for managing the financial and human resources deployed in the
provision of public services. Gomery was as shocked and dismayed as the
Auditor General had been when she saw the results of her offices audit.
The Liberal Government tried to preempt Gomery by focusing change on strengthening
public sector management. Implicitly, public servants, rather than ministers,
were blamed for the maladministration, even if only a few rogue bureaucrats
were blamed for corruption. There followed a huge volume of new command
and control rules and regulations as well as promises of a new internal
auditing regime. Overkill was the most common adjective applied to the
initiative. At the same time, the Government refused to make any changes
to the official doctrine of ministerial responsibility or public service
By the time Gomerys second volume was released, everything had changed.
The Conservative Party had made an Accountability Act the centerpiece of
its 2005-2006 election-campaign platform and then proceeded to win the
The Conservatives exhibited an appreciation of the fundamentals of government
accountability when they crafted the proposed Federal Accountability Act.
It is not surprising that they would be sensitive to the need for improved
checks and balances in the system, given that, with very few exceptions,
their leadership and support staff were experienced only in opposition.
They knew the limitations of Parliament in holding ministers and officials
One could almost say that MPs have agreed to contract-out to Parliamentary
agents the duty of Parliament to hold ministers and officials to account.
Further, these proposals were crafted not only when they were the Official
Opposition in a minority government situation but also at a time when public
opinion polls did not suggest that they would be in a different position
after the election. The proposals in the FAA, as they become a government
bill, were fundamentally opposition-inspired improvements to government
accountability. As one official put it, this is the value of an outside
view, that is, outside the Government-public service arena.
The Conservatives proposals acknowledged that Government accountability
in the parliamentary system of responsible government has to be secured
by Parliament having the capacity to hold the Government to account. Indeed,
the campaign proposals made no mention at all of the considerable efforts
that have been made by successive Canadian governments to improve government
accountability by way of improved performance or results-based reporting,
that is, by an improved rendering of account by ministers and their departments.
For the Canadian Conservative Party in opposition, the proposed way to
improve the capacity of Parliament to hold government to account was primarily
to strengthen the capacities of parliamentary agents, the press, and the
to scrutinize and review the behaviour of ministers and officials,
to audit public administration,
to assess government information,
to obtain government information, and,
to protect (and reward) public servants willing to blow the whistle on
government or administrative wrongdoings.
What is noteworthy here is that the capacity of Parliament to hold ministers
and officials to account is considered almost exclusively in terms of Parliaments
agents and not MPs themselves. And, in the Canadian tradition a tradition
that is not shared fully by other Westminster systems these agents or
officers of Parliament are deemed to be independent, that is, not subject
to direction or control by MPs. Within their statutory mandate, they perform
their oversight functions of audit, investigation and review as they see
fit. It is not surprising, accordingly, that the Conservatives would propose
reforms to improve government accountability that draw their inspiration
from the model of the Auditor General the preeminent independent officer
The Canadian Accountability Regime
This focus of the Conservative Party on independent oversight should come
as no surprise to anyone. It is widely acknowledged, including by MPs themselves,
that the Canadian Parliament is not as effective as it might be in holding
ministers or officials to account.
In comparative perspective, the Canadian system of accountability has some
real strengths. For instance, for all its alleged and obvious shortcomings
in practice, there is an effectively designed Question Period. The Auditor
General has a broad mandate, at least in respect to government departments
and agencies, and is very well funded. The resources available to MPs and
parliamentary committees are generous by international standards. And,
whatever its deficiencies, there has been an access to government information
regime in place for two decades.
Yet, the Canadian Parliament has at least three major institutional characteristics
that diminish the effectiveness of Parliament in holding ministers and
officials to account.
First, the Senate does not have the legitimacy to hold the Government to
account, even though its committees are often said to be more competent
at scrutiny and review than are House of Commons committees. An elected
Senate, especially one designed to minimize the likelihood that it would
be controlled by the Government by virtue of the electoral system, would
overcome this shortcoming. A Senate controlled by the Government is hardly
a prescription for better democracy through checks and balances, even if
it did shift the regional balance of power in Canada.
Second, the House of Commons has usually been controlled by the Government.
And in this case, except for the Union Government in the First World War,
the Government has always been formed by a single party with its MPs constituting
a House majority. In this circumstance, holding the government to account
is something that precious few, if any, Government MPs have been willing
to do. Indeed, every Government has preferred to have its MPs help to thwart
Opposition MPs from being effective in holding the Government to account.
On the relatively few occasions when Canada has been governed by a minority
government, the Government has usually had some difficulty in getting its
agenda passed in the House without compromise. But no major innovations
have emerged from these situations for holding the government to account
more effectively. In the 1950s, 60s and 70s, and again in the 2000s, these
minority-government situations were generally regarded as temporary, or
transitional, that is, awaiting a return to the preferred normalcy of
single-party majority government. This describes the current the state
of affairs. The prime minister, for instance, following the rejection of
his nominee for chair of the proposed Public Appointment Commission by
a House of Commons committee, suggested that reform on this front will
have to wait for the power of majority government, that is, where the prime
minister can expect Government MPs to support Government initiatives without
Canada, in other words, has yet to benefit from the change in the balance
of power between the Government and Parliament that can come with minority
government, or coalition majority government, if that outcome is regarded
as normal, that is, not merely temporary or transitional. This is in contrast
to New Zealand, for example, where minority or coalition majority governments
are now expected as normal. This is the result of New Zealands adoption
of an electoral system of proportional representation a decade ago, a change
that ended a tradition of executive-dominated parliamentary government
arguably more extreme than the Canadian tradition.
The third major characteristic of the Canadian Parliament is the size of
the House of Commons. With 308 MPs, once ministers and parliamentary secretaries
are removed from the Government caucus, the number of remaining Government
MPs who are willing to play a significant role in holding the Government
to account has always been miniscule (even when the governing party has
a large caucus, as occurred in 1968 and again in 1984). Since so few Government
MPs have been willing to act independently of the Government and its whips,
even only occasionally, the capacity of Commons committees to do much in
the way of serious scrutiny and review has been severely compromised.
In contrast, the British House of Commons has over twice the Canadian number
of MPs, and there has long been a tradition of taking seriously the work
of holding the government to account, including by MPs from the Government
side. The difference between the British and Canadian experiences on this
score should not be exaggerated, as it sometime is, but it is still important.
While only some British MPs take this work seriously, and perhaps it is
a diminishing number, this number, including Government MPs, has tended
to be sufficient to make British committees reasonably effective.
The effect of partisanship in diminishing the capacity of Canadian MPs
to hold the government to account has long been acknowledged. For some
time now, the principal recommendation for reducing its alleged perverse
effect on good governance has been to adopt a system of so-called free
votes for all but explicit votes of Government confidence. The Conservative
Party, in its 2006 platform, in a section called A Better Democracy,
promised to make all votes in Parliament, except the budget and main estimates,
free votes for ordinary Members of Parliament.1 This has long been a
central part of the democratic reform repertoire of the Reform wing of
the Conservative party. The promise was essentially gutted by the new Conservative
Government on assuming office when it added votes on priority items in
the governments agenda to votes on the budget and estimates as votes
subject to Conservative party discipline.2
The state of affairs following
this decision returns the role of party discipline at least back to where
it was when the Martin Liberal Government adopted the so-called three-line
Prospects for Improved Accountability
Although Senate reform may eventually serve to provide a balance to Government
control of the House, there appears little likelihood of an increased number
of MPs in the House, a change to the electoral system for the House of
Commons, or increased willingness of Government MPs to hold the Government
The prospects for improved government accountability, nonetheless, are
good. Leaving aside the fact that one or more provisions in the Federal
Accountability Act, as Bill C-2, such as the changes to the Canada Elections
Act respecting campaign contributions, have little or nothing to do with
government accountability per se, the capacity of Parliament, as an institutional
complex encompassing independent officers of Parliament, will be enhanced.
Taken as a package, the prospect is for greater openness, increased transparency,
and more oversight. Indeed, the latter by itself will enhance openness
and transparency given the powers and resources of the various oversight
At the same time, the bar of what constitutes effective government accountability
has been raised, if only because public expectations have been raised.
Politically, therefore, the question is whether the numerous devils in
the details of the provisions now in the bill are perceived as constituting
backtracking or reversals, as some have claimed in regard to the access
to information provisions for example. Given the explicit promises and
the level of rhetoric associated with the campaign proposals, the Government
runs the substantial risk of fueling public cynicism if it is seen to be
reneging on its commitments.
The Conservatives have named, blamed, and shamed the Liberals for the sponsorship
scandal, among other debacles. They have been advised to continue to do
so through to the next election. Insofar as they blame the Liberals, however,
the focus is shifted away from the structures of power, which the Conservatives
also proclaim that they want to alter in order that that they can transform
the way the federal government works. Their prescription seeks to improve
the checks and balances in the system by improving transparency, openness
and independent oversight. But these changes by themselves will not be
transformative. Most of the provisions to be adopted are in place elsewhere,
and nowhere have they transformed the practice of government accountability,
even though individually and collectively they constitute improvement.4
The change that promises the greatest effect is the proposal to have deputy
ministers designated as accounting officers, and who will be personally
responsible and accountable before Parliamentary committees for their personal
performance in exercising their specific management authorities. This innovation
is significant because it should serve to enhance the degree to which MPs,
among others, are able to distinguish between the respective authorities
and responsibilities of ministers and deputy ministers. In short, it should
help in the tasks of naming, blaming and shaming specific individuals,
as deemed necessary, in holding ministers and/or officials to account.
It will not eliminate every instance where ministers or officials seek
to shift responsibility and blame to one another. But it will help provide
much needed clarification by virtue of its statutory specification of the
responsibilities of deputy ministers.
This is the important provision in the accounting officer scheme. The so-called
disagreement resolution provision, in my view, is secondary. Although deputy
ministers have long appeared before Parliamentary committees, the important
change is the recognition that deputy ministers are accountable in their
own person before these Parliamentary committees. In practice, what this
will mean is that if a Parliamentary committee does not hold the deputy
minister responsible it follows that the minister must be deemed to be
responsible and accountable.
The New Public Governance
This provision is also important precisely because it puts the spotlight
on the new power structures of public governance and accountability. Everywhere
in the Western liberal democracies there are major challenges to effectively
holding government to account because of the consolidation of what I have
referred to elsewhere as the New Public Governance.5 This entails the following
the concentration of power under the prime minister and her or his court
of a handful of a few select ministers, political aides, and public servants;
the enhanced number, roles and influence of political staff;
the increased personal attention by the prime minister to the appointment
of senior public servants where the prime minister has the power to appoint;
the increased pressure on the public service to provide a pro-government
spin on government communications; and,
the increased expectation that public servants demonstrate enthusiasm for
the governments agenda.
None of these elements is entirely new, of course. But the consolidation
of these several elements has increased the intensity of political pressures
on the public service to the point where the so-called bargain that ought
to govern the relationship between a democratically elected government
and its professional and non-partisan public service is called into question,
challenged, placed under severe stress, or even broken.6
In my view, the political leadership cannot escape the pressures that bring
about the New Public Governance. They are part of the environment that
Governments do not control at all or cannot control very well, however
much they may try. These pressures emanate from, among other things:
the transparency resulting from the contemporary electronic communications
the greater assertiveness and aggressiveness of the mass media resulting
from greater competition;
the demand for openness that come with the advent of a recognition of the
publics right of access to government information;
the creation or expansion of a host of independent audit and review agencies
in recognition of the need for expert oversight;
- the public exposure of ministers and public servants before parliamentary
committees as well as public consultation or engagement exercises; and,
- a less deferential citizenry that demands greater public accountability.
The New Public Governance is clearly not a phenomenon unique to Canada,
or to recent Liberal governments, as should now be patently obvious to
everyone given the governance practices of the new Conservative government.
It is an international phenomenon and it cuts across governments of different
partisan stripes. In Britain, for example, many observers would conclude
that the Blair Labour Government has succumbed to these pressures even
more so than did the Thatcher and Major Conservative Governments. Not all
governments are affected exactly the same way, of course, since they have
different institutional arrangements and political practices, even in the
family of Westminster systems.
The Federal Accountability Act will help address the challenge of the New
Public Governance in some ways. As noted, the Accounting Officer scheme
will help to clarify the respective responsibilities and thus accountabilities
of ministers and deputy ministers. Political staffers are to lose their
special access to public service positions, thus reducing the degree to
which there exists an opportunity for unacknowledged politicization of
public service staffing.7 And, the better regulation of lobbying, government
advertising and public opinion polling should also help, given that each
is integral to the pressures that produce the New Public Governance. For
the greater part, nonetheless, the power structure stays the same.
Addressing the Imbalance of Power
Judge Gomery departed from the approach taken by the Conservative Party
and Government, and, for that matter, the former Liberal Government. He
saw the problem of the sponsorship scandal as the result of an imbalance
in power between the Government and Parliament and the Government and the
public service and, thus, by extension, between Parliament and the public
service. He thus stressed the need to enhance the capacity of the Public
Accounts Committee to do its work in holding deputy ministers to account
for the performance of their statutory and delegated authorities and responsibilities.
In Gomerys Volume 1 analysis, a great deal hinged on the relationships
of the Deputy Minister of Public Works and Government Services and departmental
officials, the Minister, the Ministers political staff, the Prime Minister
and his political staff, the Clerk of the Privy Council and other senior
officials in the Privy Council Office. Indeed, the entire story of the
maladministration of the program can be told from the vantage point of
the deputy minister of PWGS. The corruption part of the story may have
defeated the Liberal Government but, in some important respects, it was
merely an unfortunate byproduct of the maladministration. While the corruption
was undoubtedly an aberration, the maladministration was further evidence
of systemic shortcomings in the system arising from the failure of the
public service to draw the line between responsiveness to ministers and
advancing partisan interests, and the sponsorship scandal is by no means
the sole piece of evidence in this script.
Gomerys key recommendations thus sought to alter the balance of power
between the Government and Parliament and Government and the public service,
including those government agencies at arms length. He proposed radical
changes to the regimes for staffing the deputy minister cadre and for appointing
the boards and chief executive officers of Crown corporations.
Gomery sought to radically curb, in some cases to eliminate, the discretionary
appointment powers of the Prime Minister.
These proposals did not get incorporated into the Conservative Governments
Federal Accountability Act. The Conservative campaign platform was silent
on the staffing of the deputy minister cadre. It did state that the adoption
of the Accounting Officer scheme would address the blurring of lines between
ministers and non-partisan public servants that, in their view, took place
under the Liberals by re-establishing clear lines of accountability.8 Presumably
this was thought sufficient to secure the necessary non-partisan independence
for deputy ministers and thus for the public service they direct. I think
that it will help, and that it is a necessary condition to securing a better
balance of power. But, more is required in my view.
I also think that a more independent process for staffing and managing
the deputy minister cadre will come at some time in the not-too-distant
future in any event. The New Zealand model, adopted in the 1980s, is the
obvious option to emulate,9 even if the regime in one system must always
be adapted to fit the circumstances of another. The course of reform in
Canada over the past century has witnessed a progressive diminution of
the executive discretion of prime minister and government over matters
of management. Given that the deputy minister cadre in Canada has always
been regarded as the leadership of the professional, non-partisan public
service, the idea of a change in its staffing regime would hardly constitute
a deviation from Canadian public service values. Indeed, it would represent
a far better acknowledgement of these values. According to these values,
a deputy minister cadre so appointed would be no less responsive to ministers
as is now the stated norm. At the same time, however, deputy ministers
would be in a better position to resist those explicit or implicit marching
orders, as a former deputy minister put it, that require them to ignore
or overlook their statutory duties, their professional obligations as leaders
of the non-partisan public service, or Canadian public service values.
With respect to appointments to the boards and CEOs of Crown corporations
the proposal for a Public Appointments Commission, now incorporated into
the Accountability Act, is an important first step, but only a first step.
The operative assumption here is that a transparent process is needed to
ensure that those appointed by Government are deemed to be qualified by
someone other than the Prime Minister. The appointment is merit-based in
this sense, but only in this sense. No claim can be made that partisanship
in appointments is thereby eliminated, as amply demonstrated by the prime
ministers nomination of the commissions first chair.
Moreover, it needs to be stressed that in terms of what transpired throughout
the sponsorship scandal, the question of partisanship looms much larger
than the question of merit. Very few, if any, of those who have been identified
as the responsible persons in connection with these instances have been
characterized as not qualified or incompetent to fill the positions they
held. Rather, in almost every case, the charge has been addressed to the
consequences or effects of partisan appointments. If anything, the maladministration
or corruption took time to be discovered precisely because those involved
were competent. They were competent partisan cronies! In Britain where
a public appointment commission has been in operation for some time, there
are criticisms, including from commissioners themselves, of the inappropriate
involvement of ministers in the appointment process. Some of those so appointed
by the Blair Government through this new process are referred to, as one
should have expected, as Tonys cronies
A Lesson from Australia
Government accountability in the Australian system of parliamentary government
suffered a major blow last year when the Government secured control of
the Senate. For over thirty years there had been a steady increase in the
extent to which ministers and public servants are exposed to public accountability.
And, for roughly the same period of time, the Government, whether under
Labor or Coalition (Liberal-National), had to cope with a Senate in which
they did not have majority control. Beginning in July, 2005, the Coalition
government had control. Since Senate committees, of the Estimates and special
inquiry variety, have been among the most important instruments of government
accountability in the Australian parliamentary system, the capacity of
the Government to curtail scrutiny, investigation and review of government
by Senate committees constitutes a significant decrease in government accountability.
The possibility of this was realized almost on day one of the new balance
of power when a proposed Senate committee inquiry was voted down.
This Australian development is important for two reasons. First, Australia
has been a leader internationally in improving government accountability,
especially in the family of Westminster systems. Australia has been a leader
because of the degree to which the Australian Senate over the past three
decades has been able to scrutinize, investigate, and review the performance
of ministers and public servants. The Senate has been able to do so primarily
because it has not been controlled by the Government. The Opposition, collectively,
has held a majority in the elected Senate. This result is partly due to
the different electoral system used to elect Senators as compared to the
system to elect members of Parliament in the House of Representatives.
The Australian Senate, in Canadian terms, has been a model Triple E Senate:
elected, and therefore legitimate; equal, in terms of the representation
of the Australian states; and, effective, in countering the Governments
control of the House of Representatives. It has been especially effective
in holding ministers and public servants to account. Its capacity to do
this demonstrates that effective government accountability is enhanced
to the degree that there exists an Opposition with the power to hold ministers
and officials to account. There has been, in other words, a balance of
power that has made the intended checks and balances effective. That essential
condition was diminished significantly when the Government secured majority
control in July 2005. Australia now looks more like Canada.
Second, this development demonstrates that the holding to account part
of the accountability process is the most important part of the two-sided
process of accountability. The other part the rendering an account
part is the less important. If ministers and officials are held to account,
they will be forced to render an account. On the other hand, if ministers
and officials merely render an account, the accountability process invariably
is reduced to either a public relations exercise in self-congratulation
on self-reported results or a case where ministers accept responsibility
for an instance of maladministration or even wrongdoing but with no admission
of personal culpability and therefore no acceptance of the need to suffer
any personal consequence. An effective system of government accountability,
in other words, requires more than a forum or process for ministers and
official to report. There must be institutions and processes to actually
hold ministers and officials to account. There must be a balance of power
for accountability to be effective.
The two most significant sets of proposals to reform government accountability
in recent years the Gomery commission recommendations and the Conservatives
Federal Accountability Act share at least one common feature: they upset
the establishment. It is especially noteworthy that they agreed on the
need to have deputy ministers be publicly accountable before MPs for the
exercise of the significant powers that Parliament, and not merely ministers,
has conferred on these senior public servants. In so doing, they each raise
the issue of how the non-partisan, professional public service can be helped
to cope with the political pressures that Governments bring to bear on
them because they themselves are now subjected to unprecedented unrelenting
and intrusive pressures.
The Gomery commission was more radical in its recommendations, at least
insofar as relations between the Government, especially in the person of
the prime minister, and deputy ministers are concerned. Gomery recognized
that effective accountability requires that those who possess authority
and responsibility have the independence to discharge their duties and
obligations according to the law and the values that are meant to govern
their behaviour. In the case of public servants, this requires that ministers,
and their political staff, respect the obligations of non-partisan public
servants. In the real world of contemporary government, this demands major
change. The Liberal Government, and its political staff, may be history,
but the pressures of the New Public Governance did not depart with them.
Although the Conservatives Accountability Act will not transform the Canadian
system, at least not in significantly altering the balance of power, the
Conservatives have signaled an appreciation of what could be changed to
effect a significant transformation. Senate reform clearly is on this list,
given its longstanding place in the Reform reform program. An elected Senate
has been a critical part of Australias record of effective government
accountability. Fixed elections dates would also help, especially if the
scheme eliminated the right of a prime minister to dissolution of the House
of Commons, and thus an election, following the loss of a no confidence
vote. A convention or protocol that required the Governor General to consult
with the leader of the opposition following such a government defeat, to
see if a new government could be formed without an election, would also
remove the discretion from the Governor General. The process would be democratized
by requiring the party leaders in the House to publicly accept responsibility
for the formation and defeat of governments and the calling of elections
between fixed election dates.10 Finally, serious thought should be given
to some mechanism to give a minority of MPs, especially in committees,
the power to initiate committee inquiries and to summons witnesses in pursuit
of accountability work. The power of a parliamentary majority, in Parliament
or in committee, to curtail scrutiny, investigation and review does not
advance the fundamental obligation of MPs to hold the government and officials
1. Conservative Party of Canada, Stand Up for Canada: Conservative Party
of Canada Federal Election Platform 2006, 44.
2. See Canada, Accountable Government: A Guide for Ministers (Ottawa: Privy
Council Office, 2006),14.
3. Peter Aucoin and Lori Turnbull, The democratic deficit: Paul Martin
and parliamentary reform, Canadian Public Administration, Vol. 46, No.
4, Winter 2003, pp. 427-449.
4. Peter Aucoin and Mark Jarvis, Modernizing Government Accountability:
An Agenda for Reform (Ottawa: Canada School of Public Service, 2005).
5. Peter Aucoin, The New Public Governance and the Public Service Commission,
Optimum Online: The Journal of Public Sector Management, Vol. 36, Issue
1, March 2006, 12pp.; and, The Staffing and Evaluation of Canadian Deputy
Ministers in Comparative Westminster Perspective: A Proposal for Reform,
in Commission of Inquiry into the Sponsorship Program and Advertising Activities,
Restoring Accountability: Research Studies, Vol. 1, (Ottawa: Minister of
Public Works and Government services, 2006), pp.297-336.
6. See Donald J. Savoie, Breaking the Bargain: Public Servants, Ministers
and Parliament (Toronto: University of Toronto Press, 2003).
7. But they will be given the right to apply for internal competitions
for public service positions.
8. The Federal Accountability Act, November 5, 2004, Conservative Party
of Canada, p. 13.
9. Ironically, the New Zealand reform in the 1980s was adopted to give
a greater influence to ministers in the staffing of their equivalent of
deputy ministers, as compared to the insulated old-boys club that had full
powers to staff the senior executive cadre. See Aucoin, The Staffing and
Evaluation of Canadian Deputy Ministers in Comparative Westminster Perspective.
10. See Peter Aucoin and Lori Turnbull, Removing the Virtual Right of
First Ministers to Demand Dissolution, Canadian Parliamentary Review,
Vol. 27, No. 2, Summer 2004.