Submission: Review of Ofcom’s list of larger parties for elections taking place on 5 May 2016

Question 1: Please provide your views on: a) the evidence of current support laid out in Annex 2 b) whether there is any other relevant evidence which you consider Ofcom should take into account for the purposes of the 2016 review of the list of larger parties and c) our analytical framework for assessing the available evidence laid out in paragraph 2.4.

We understand that colleagues from the UK Liberal Democrats have argued that assessing past electoral support for political parties should take into account party performances over the last two electoral cycles. We share this view. We believe that it is important to consider parties’ performances over a reasonable time period to ensure all parties have fair representation against a backdrop of a more volatile political landscape in the UK.

In terms of the data supporting these draft guidelines, while we do not question the accuracy of the results data cited in terms of electoral support, we consider that this provides a limited reflection of the current situation in many parts of . Judging electoral results purely in terms of seats does not reflect the overall balance of support across Scotland and the longer term picture.

The same applies for national opinion polls, which in many cases understate the position of the Liberal Democrats in regions across the country significantly. We note that the vast majority of polls failed to predict the result of the UK general election accurately, and the ongoing work amongst polling companies to examine their methodology in light of these failures. We would urge caution when judging what weight to offer the findings of national polls absent further explanation of these methodological shortcomings.

While the number of seats won by the Liberal Democrats in Scotland fell at the 2015 election, a detailed analysis of results show that in many seats we previously held, the number of votes received by Liberal Democrat candidates increased from 2010. In Edinburgh West, the number of votes the party received increased by 1484. In East Dunbartonshire, the number of votes we received increased by 1375. We observed similar patterns in seats like Caithness, Sutherland and Easter Ross, Argyll and Bute and Gordon. These voting patterns did not reflect national polls and are not detected by an analysis of electoral support which ignores detailed results in individual seats. Question 2: Do you agree with our assessment of the relevant evidence and our proposals for the larger parties to be included in the Ofcom list of larger parties as laid out in figure 6 above? Please provide reasons for your views.

We agree with the list of larger and smaller parties as set out in the draft guidelines.

With regard to the position of the Scottish Liberal Democrats, we note that at the 2011 Holyrood elections, the Scottish Liberal Democrats received 7.9% of constituency votes and 5.2% of votes on the regional list, with 5 Scottish Liberal Democrat MSPs returned to Holyrood. As a result, we are one of the four largest parties elected to the .

We are represented at meetings of the Parliamentary Business Bureau and party leader MSP has regular slots at First Minister’s Questions. Scottish Liberal Democrats have maintained a group presence at the Scottish Parliament since the legislature reconvened in 1999. We were in administration as part of a between 1999 and 2007.

Submission: Submission: Review of Ofcom’s list of larger parties for elections taking place on 5 May 2016

We have substantial presences on local authorities from the Borders to the Highlands and are currently in administration in a number of local authority areas.

At the 2015 UK general election, the Scottish Liberal Democrats received more than 219,000 votes across Scotland. By way of comparison, this was more than four times more than the number of votes secured by UKIP and five times more than the Scottish Green Party. We will stand candidates in every constituency seat across Scotland at the 2016 elections.

Since the election, we have seen an increase in party membership in Scotland of nearly one third. We have a clear record of past and current electoral support, and distinct policy positions in a number of devolved policy areas. For example, we were the only major Holyrood party to oppose the creation of a single Police force for Scotland. We have been successful in generating substantial public awareness and support for campaigns on topics ranging from cuts to college funding, to improved support for early years care and many other issues. This has led to the making a number of substantive policy changes.

In short, we have a distinctive position on a range of policy areas that will be debated in the course of the Scottish election campaign, and a record of support over time covering a number of electoral cycles. Given the above, Scottish Liberal Democrats should be given parity with the other larger parties.

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