Thank you again for your hard work on this difficult issue. I just want to make a few final points as the consultation period closes.
1. As stated in my previous submission, I do not believe that there will be a parliamentary majority for the Final Proposals (and those of your fellow Commissioners in England, Scotland and Wales) when push comes to shove. It is probable that all of the opposition parties will oppose changes which generally benefit the Conservative Party, and sufficient government MPs will rebel because the proposed changes do not benefit the Conservatives enough. The position of the DUP, who have always been hostile to the abolition of Northern Ireland’s 18th seat, will then be irrelevant. However, the show must go on.
2. The Commission’s decisions to minimise disruption to existing constituencies and to invoke Rule 7 without hesitation have produced a much better map than the Provisional Proposals. Your remit has been made more difficult by the arbitrary decisions of the government before last in regard to how the process is conducted. The limitation to 5% variation has proven very difficult to implement in practice. On a process point, the previous system, which allowed local Assistant Commissioners to produce their own recommendations, was much superior.
3. It is regrettable that the political rhetoric around the Commission’s work has been inflated by a party which failed to respond substantially to the Provisional Proposals (a marked contrast to the mid-1990s, when they successfully mobilised to prevent a previous proposal to reduce Belfast to three seats). It is ridiculous that the process is being presented by some as a gerrymander in favour of the DUP, who are the only party that (according to my calculations) will actually lose Westminster representation as a result of these proposals.
4. Having said that, I do think that Dungiven is poorly served by the Revised Proposals. This is not the Commission’s fault – you were not responsible for the drawing of the ward boundaries of Dungiven, Altahullion and Feeny, which intersect so confusingly in the streets of the town; and you were also not responsible for the rigid 5% limits of the legislation.
5. However, the Commission’s duty is to take into account as of equal weight the current ward boundaries (which after all are of relatively recent vintage, and themselves reflect an attempt to fit numbers to maps) and the strength of local ties that might be broken by the new boundaries. (Rule 5 (1) (b) and Rule 5 (1) (d).)
6. A reasonable interpretation would be to take the wards as a starting point, but not hesitate to split them where necessary, as a previous Commission did for the Derriaghy ward in the mid-2000s and as your colleagues across the water have done in this review cycle.
7. Dungiven is a clear case where too rigid an adherence to ward boundaries violates local ties. The boundary between Dungiven ward and Feeny ward, which is also the boundary between the proposed constituencies of Mid Ulster and West Tyrone, runs along Main Street. Main Street is not actually central to the town, most of which lies to its north and east; but it is reasonable to feel that both sides of the road should be in the same parliamentary constituency.
8. To solve this problem, Feeny ward (and probably also Altahullion ward) should be divided between constituencies. The map below illustrates my proposal, the blue lines indicating my proposed new boundaries between Mid Ulster and respectively West Tyrone (to the southwest of the map) and Causeway (to the north).
9. The very small part of Feeny ward to the east of the Owenreagh River, and the Roe River north of its confluence with the Owenreagh River, should be included in the Mid Ulster constituency, and the rest of Feeny ward should remain in the proposed West Tyrone constituency. The whole of Dungiven town lies east of the Owenreagh and the Roe.
10. The Commission’s proposed West Tyrone has an electorate of 70,498, which is almost 800 more than the lower Rule 7 limit of 69,701. The number of voters in the part of Feeny ward east of the Roe and the Owenreagh may be close to 797, but I would be surprised if it is actually more. Mid Ulster, at 73,902 voters, can comfortably absorb a few hundred (or indeed a few thousand).
11. To the north, the boundary between Mid Ulster and Causeway could be made tidier by including the townland of Derryware in Mid Ulster rather than Causeway. The number of voters involved looks to be only a handful. Both Causeway and (as stated above) Mid Ulster are comfortably in the middle of the permitted range of variation of electorate, so this proposed change should not pose any further problem.
12. My other substantial remark relates to the two seats of South Down and Mid Down, as proposed by the Commission. This is a case where adhering to existing boundaries may actually be detrimental to local links. I am rather attracted by the proposal made by Pete Whitehead on the Vote UK Forum on 31 January:
13. Mr Whitehead’s proposal moves the four Banbridge wards, as well as Quilly and Dromore, from Mid Down to South Down, and in return moves Drumaness, Ballydugan, Crossgar and Killyleagh, Quoile, Cathedral, Knocknashinne, Lecale and Strangford wards from South Down to Mid Down (or East Down, as the seat might then be better described).
14. This proposal clearly respects local links much better than the Commission’s Revised Proposals, or indeed than the existing boundaries. Banbridge would be linked with Newry, 15 miles away along a main road, rather than Newtownards, 35 miles away across the countryside. Downpatrick would be united with the rest of the Strangford Lough shoreline. Both constituencies would be much more compact and less extended.
15. The Commission may however feel that this proposal, untested by public consultation, goes too far for this stage of proceedings. If so, I have an alternative proposal that goes the other way.
Loughbrickland and Ballynahinch
16. The Commission’s Mid Down regrettably excludes Loughbrickland, thus detaching it from Banbridge, which is only three miles away and is the commercial focus of most economic activity in the village. Ballynahinch however is included in Mid Down, even though its closest neighbours, Carryduff and Downpatrick, are to be in different constituencies (South Belfast and South Down respectively).
17. The two wards have comparable electorates (Loughbrickland has 3790, Ballynahinch 2884, a difference of 906). A straight swap would therefore give South Down an electorate of 76,018 and Mid Down an electorate of 78,673. Unfortunately that would put Mid Down a shade above the 78,507 upper limit.
18. This can be fixed in two possible ways. First, the new Loughbrickland ward could be divided along the current boundary between Upper Bann (briefly Newry and Armagh) and South Down, the western part going to Mid Down and the eastern part remaining in South Down. The territory west of this line, but in the new Loughbrickland ward, contains the village of Annaclone, and certainly has more than 174 voters, though probably not many more.
19. Second, turning to Ballynahinch, the western edge of the Ballynahinch ward excludes the residents of Edengrove Park and Lime Trees from the rest of the town. If the Commission is minded to look at the Ballynahinch situation, it could divide the Kilmore ward and include those hundred or so electors in South Down along with the rest of Ballynahinch; that may well make division of the Loughbrickland ward unnecessary.
20. It should be noted that the Commission’s Revised Proposals divide voters living on The Brae and The Drumlins from the rest of Ballynahinch, as they live in the ward of Ballyward. If the Commission is not minded to take my proposal to transfer Ballynahinch and Loughbrickland, it could at least look at dividing Ballyward along the Edenavaddy Road and Grove Road, in order to include those voters who live on the southwestern fringe of Ballynahinch in the same constituency as their fellow townspeople. Again, the numbers involved will be a couple of hundred at most.
21. The two maps following illustrate these proposals. My proposed Mid Down is now even more extended than the Commisson’s Revised Proposals, but if the seat is conceived as the joining of Newtownards/Comber/Ballygowan/Saintfield and Banbridge/Dromore/Loughbrickland, it makes more sense.
22. Like Mr Whitehead’s suggested map, my proposals keep Loughbrickland with Banbridge, and make the more sensible link between Ballynahinch and Downpatrick given that it loses Carryduff as a constituency neighbour.
23. Some may feel that I have been rather unorthodox in proposing the division of wards. But the fact is that the rigidity of the 5% limit, even with Rule 7 flexibility, combined with a narrow interpretation of the rules regarding ward boundaries, has led the Commission to propose the disruption of local ties which could be retained with a very small amount of intervention, and invoking Rule 5 (1) (d) instead of Rule 5 (1) (b) where appropriate.
24. I have concentrated here on Dungiven, because of the amount of public commentary it has engendered, and Loughbrickland, because I happen to know the area. There may well be other cases: for instance, it strikes me that in the case of North Belfast / East Antrim, the Three Mile Water is a much more natural boundary than the artificial demarcation of Carnmoney Hill, Abbey and Monkstown wards to the south and Ballyduff, Jordanstown and Rostulla wards to the north. However I have no idea how to calibrate the number of voters in that case.
25. I wish the Commissioners well in their future work, and I am grateful for the positive interaction we have had over the course of this review cycle. As I said at the beginning, even if (as I expect) this particular review never sees legislative effect, it is practice for next time.