The comparison of the US President and the British Prime Minister appears from the onset, to provide some interesting differences since the President holds the position of Head of State as well as Head of Government. The Prime Minister, it would appear, has more influence in domestic, able to dominate his part, legislature and to an extent, executive branch. The US President, on the other hand, appears to have the position of supremacy in domestic politics, known as the chief legislator and dominates his executive, though part control is limited. He does not hold the same position of power in domestic affairs as the Prime Minister, but his position of strength appears to be in the realm of foreign and international matters, in which he faces little challenge from Congress. Much of this prominence is derived from his status as the ‘Nation’s Leader’ and the unifying force in a dispersed political system. It would appear that both offices hold different powers, all of which will be taken into account when deciding which is more powerful.
The power, which the holder of each office exercises over their respective party in the legislature is of great significance in determining which office, confers the most power. The British Prime Minister, as shown by past examples, usually holds substantial power over the party machine from which their power originates, and position depends on. The absence of a clear separation of powers in the British system gives the British Prime Minister the position of, head of the majority party in parliament. Due to such a strong link between the Prime Minister and his party he can often expect loyalty as a matter of course when forwarding legislation. The President can not though, expect such favorable treatment from his party, as no direct link exists between he and his party colleagues in Congress, a situation created by the ‘separation of powers’, a primary intention of the Founding Fathers when writing the Constitution to prevent executive dominance. The British Prime Minister also has, at his disposal, a powerful Whip system to maintain party loyalty. British MPs are faced with the threat of losing career prospects within government, temporary suspension, the enmity of their colleagues, failure to be selected by their constituency party, and the ultimate sanction of expulsion from the party. Such weapons make the Whips a vital tool to the Prime Minister in maintaining party loyalty. It may be true that both Senators and Representatives of the same party as the President face similar threats when voting on Presidential legislation, but they also face numerous other pressures which they take into account when voting, most notably, their own personal convictions, lobbyist and financial backer’s views, and pressure from constituents upon whom they rely for reelection. This is particularly true of Representatives who stand for election every two years and are thus ‘fighting a permanent election battle’. For such reasons, members of Congress, especially Representatives, are usually more independent when it comes to voting. Despite the success of presidents such as FDR in maintaining strong party loyalty in Congress, the example of Presidents such as Carter show that party loyalty is not often guaranteed or even expected in the US system. This explains the reliance on ‘logrolling’ by the US President when attempting to gain support for legislation, rather than the reliance on party loyalty, which dominates British politics. The example of Reagan, a Republican, in gaining control over the federal budget through the cultivation of good relations with Tip O’Neill, a Democrat House Speaker, showed clearly how the support of the opposing party is often required to pass legislation within the US system. It has been noted though that control over party, for both the President and British Prime Minister depend much on the varying political climate at that time. In Britain, the example of the Conservative rebellions over Europe throughout the life of the Major government which served to decrease the government majority and eventually render it non-existent, showed how party support could be lost and extremely weaken a Prime Minister’s power. By contrast, many political observers have noted the growth of a more cohesive party system, especially after the ‘Contract With America’ produced by the Republican Party in 1994 after a sweeping victory in the elections for both Houses of Congress. If the Congressional composition remains as it is after the elections in November and Bush wins the Presidential election, it will be interesting to see how the relationship between he and Congress will develop and if such party unity does in fact exist. Undoubtedly, the prime minister appears to hold a considerable advantage in controlling his party, much more so than the president, who is faced with a disunited party system and the lack of a working authority with his party colleagues.
The power, which each office holds over the passage of legislation, is of great significance in determining which office holds the most power as a whole. The British Parliament, according to McNaughton, may be sovereign but when considered thoroughly, this is only a theory. “In effect, the sovereignty of Parliament becomes the sovereignty of the Government” (McNaughton). This view tends to show that the British Prime Minister, who usually maintains the support of a parliamentary majority, holds a position of dominance over the passage of legislation. The American system though, due to the ‘Separation of Powers’ between the Executive and legislative branches, in theory provides a limit to Presidential power over the passage of legislation. The ‘checks and balances’ which exist within this system, according to McNaughton, both limit and enhance the independence of Congress in dealing with legislation, with the constitution acting as the guarantee of such a position. The majority, which the Prime Minister can usually rely on, both because of the election system and the use of the Whips is in effect a guarantee of legislative success, especially true with the current Blair government which holds a massive majority in parliament, so much so that even legislation which faces much opposition from within can pass with ease. The passage of the Bill on the privatization of Air Traffic Control in May, despite a massive revolt, shows clearly how the British Prime Minister can push through legislation, which has little support. Contradictions though, most notably from the Major administration, show that other factors also play a significant role in this, such as the size of the majority, leadership skills and party unity. The President though, due to the relative lack of party loyalty and the election system, which often results in ‘split-ticket voting’, cannot hope to have such control. The President is aware that members of Congress often have their own interests as regards legislation, and therefore compromise is often the key to Presidential success. The individual wishes of Congressmen, it would therefore appear, are influential in the passing of legislation. In Britain, the failure of Private Member’s Bills is common, with success limited to about five Bills per year. This due to the lack of support given by the government, those with support are the only ones with a real chance of success. The parliamentary timetable is dominated by Government Bills, which find their roots with the Prime Minister, and have a relatively minute chance of failure. The British Prime Minister, it would appear has more legislative power than the President since he has much control over the workings of the standing committees which consider and amend legislation. The governing party’s majority, the existence of whipped voting and the application of the guillotine allows the Prime Minister to effectively control the work of such committees. Only amendments, which he favors, will be moved to a vote so that the government Bill usually emerges unaltered. The standing committees of Congress, in stark contrast, are not under the control of the President and have a much wider range of powers when considering legislation, and are themselves key policy initiative areas, acting as an alternative to Executive dominance of the legislative program. Besides, Presidential Bills have to negotiate further hurdles in their passage through Congress, from the Rules and Majority Policy Committees, which hold great influence on the likelihood of success for the Bills proposed by the President, as they determine when they will be debated. It would appear therefore that the only effective formal power, which the President possesses, is that of veto. This, though subject to overturn by the 2/3 majority of both Houses, is a very effective power in legislating. Clinton, for example, used 17 vetoes between 1993 and 97 with great success, having none overturned. Bush too, had great success in using the veto, defeated only once from 1988 to 1993. The power of the pocket veto has also become an effective weapon of the president in controlling legislation, since it can not be overturned and needs not be explained, and moreover, can be used a bargaining counter with Congress to ensure success for Presidential legislation. It would appear that the constitution has limited the power of the President and strengthened Congressional power, but when looked at more closely, the President has become known as the ‘Chief Legislator’, according to Johnson, for his extensive use of the State of the Union address to forward his proposals for legislation and make it known to Congress, his intentions for the year, and the fact that he passes more legislation than Congress. We may also consider the use of Executive Powers by the President as a further way in which he can bypass Congress, and exert his law-making powers. The extensive use of such powers in Foreign Affairs have been a significant element of the Presidency in recent years, as Executive Agreements have been used instead of Treaties so that Senate’s approval is not required. They have also been used to send troops abroad, an example being the Grenada and Panama situations of the 1980’s, when the War Powers Resolution of 1973 and the Constitution were successfully sidestepped. The British Prime Minister cannot expect to hold so much foreign influence, as the question of foreign policy appears to spark the interest of Parliament, shown by the quality of debates on foreign issues. The Prime Minister does not have the ability to use Executive powers in this area either, and he does not hold the position of Head of State. It would appear therefore that both the President and Prime Minister have extensive powers in legislating, both having the most control within their respective systems. The Prime Minister though, appears to have the most influence over legislation, when compared to the President, as his dominance over the legislature is much more secure and faces less opposition. The president though, through his use of executive powers, appears to have almost unlimited powers in foreign affairs, whereas Congress are more concerned with domestic issues.
Both offices are faced with the scrutiny of committees within the legislatures of the respective systems. The British Prime Minister, in theory, is held to account and scrutinized widely by the Select Committees of the commons and the in House debates and Question Time. Select Committees have the right to ‘persons, papers and records’ and may commission damning reports which are of great use in scrutinizing the Prime Minister, a view backed by Adonis, ‘they have enhanced the profile of the House’. In practice though, Prime Ministers, as shown by Thatcher in particular, can greatly limit their effectiveness in scrutinizing, by withholding vital evidence and witnesses, as was the case in the 1996 investigation into the ‘Arms to Iran’ affair. Such committees, according to Norton have numerous other setbacks which limit their scrutinizing powers, such as time restrictions and the lack of an independent inquiry into their reports (this is left to the government to act upon). The President faces much more intense scrutiny from both Standing and Select Committees since they have a wider remit to evidence due to their extensive finance and freedom of information laws, added to this is the apparent lack of government secrecy on a scale such as that displayed in Britain. The investigations carried out by such bodies often gain public attention and mass media coverage, prominent examples being the Watergate Committee of 1974 which had mass following and demonstrated the power of such committees, by subpoenaing vital evidence which led to the resignation of Richard Nixon. Due to the direct link between the Prime Minister and the legislature, it may appear that he would face much more intense scrutiny than the President, as he has to face the Commons in debates and at Question Time. This may be true in theory, and has support from Adonis, but in practice debates have little influence on government policy, usually made to a sparsely attended chamber and only having real influence when the government is in a small majority, as shown during the time of Major when the debate over coal mines in 1992 led to Major’s back down over shutting them down. Adonis argues that debates on international issues are of great value as they force the Prime Minister to defend his actions and help in the area of sound policy making, a recent example being the debate on Kosovo and the subsequent decision to send in British troops. Question Time too has come under attack for its ritualistic nature and often, ‘rowdy’ nature in which it becomes a mere point scoring match, a situation which appears to have continued despite Blair’s reforms in 1997. Such politics has led to, according to many analysts, the apathy towards politics felt by many in Britain today. It would appear that the President is more extensively scrutinized than the Prime Minister, and thus his power is greatly limited in order to provide accountable government for the United States. The lesser degree of government secrecy and the ‘separation of powers’ provide, it would appear, a more adequate form of scrutiny.
The power of each office can also be measured by the degree of control they exercise over their cabinet and executive. In theory, the British Prime Minister is merely regarded as the ‘first among equals’ within the cabinet, and is usually expected to meet with cabinet, which is a formal unit. The President though, is not obliged to meet with his cabinet or consult them on policy, as cabinet is not a formal unit contained within the constitution. There is no doctrine of collective decision making, and the President holds the power of supreme decision maker when consulting cabinet and may ignore the views of his cabinet, a policy favored by Presidents such as Kennedy and Bush, who formalized meetings and paid little attention to the views of their cabinets. In Britain there exists the doctrine of collective decision making, which is supposed to help in stable government and collective decision making, but has been manipulated by many prime Ministers to silence dissent as those who refuse to do so are forced into resignation. The American President may, if he so wishes, use alternative sources of information apart from his cabinet, namely EXOP or the Independent Executive Agencies, which are contained within the Bureaucracy. This, it would appear, gives the President a vital alternative source which can only help increase his power as it provides vital information and analysis. The British Prime Minister, according to Dunleavy, has also taken on such a policy, pre-cooking policy and using alternative sources of information when deciding policy. Thatcher, in particular, greatly increased her power within the executive by increasing the power of the Prime Minister’s Office and successfully using the Cabinet Secretariat as a further means of centralizing power. Blair too, as he streamlined the two, has followed up on such a policy to adapt both executive branches to his advantage, to keep his cabinet in check, and to use it successfully in media relations. Dunleavy and Rhodes claim that the power within the British executive though, cannot be said to be merely central to the Prime Minister as it is more complex than it appears, rather that power within the British executive is spread in different places at different times, depending on the political landscape. It would seem therefore, that the president has more control over his executive than the prime minister, as McNaughton points out, since he can easily centralize power around himself whereas the prime Minister must refer to his cabinet.
The comparison of the US President and the British Prime Minister appears from the onset, to provide some interesting differences since the President holds the position of Head of State as well as Head of Government. The Prime Minister, by comparison, is merely Head of Government, but as we have seen from the above, is able to exert considerable influence to merit a comparison with the President. The Prime Minister, it would appear, has more influence in domestic politics and is able to successfully dominate the legislature due to a lack of ‘separation’ between the executive and legislature, avoid the intense scrutiny of Parliament, and keep a firm grip over his party which the president cannot. The US President, on the other hand, appears to have the position of supremacy in domestic politics, although not to the degree of the Prime Minister, but his position of strength appears to be in the realm of foreign and international matters, in which he faces little challenge from Congress. Much of this prominence is derived from his status as the ‘Nation’s Leader’ and the unifying force in a dispersed political system. It is therefore difficult to assess which office is more powerful, but it would appear that the President is more powerful in foreign affairs and the Prime Minister, more dominant in domestic politics. However, the Prime Minister must also maintain the support of the legislature, whereas the president can govern without support here.
