2015-16 Representation Review Guide for …€¦ · Web viewTherefore, the three-ward model does...

BENALLA RURAL CITY COUNCILApril 2019

© State of Victoria (Victorian Electoral Commission) 3 April 2019

Version 1

This work, Local Council Representation Review Preliminary Report – Benalla Rural City Council, is licensed under a Creative Commons Attribution 4.0 licence [http://creativecommons.org/licenses/by/4.0/]. You are free to share this work under that licence, on

April 2019

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Local Council Representation Review – Preliminary Report Benalla Rural City Council 2019

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ContentsEXECUTIVE SUMMARY..............................................................................1

BACKGROUND.........................................................................................3

Legislative basis..........................................................................................................................3

Public engagement......................................................................................................................3

The VEC’s principles...................................................................................................................4

Developing recommendations.....................................................................................................5

PUBLIC SUBMISSIONS (PRELIMINARY)......................................................7

THE VEC’S FINDINGS AND OPTIONS..........................................................9

Preliminary report findings...........................................................................................................9

Options......................................................................................................................................15

NEXT STEPS..........................................................................................16

Response submissions.............................................................................................................16

Public hearing............................................................................................................................16

Final report................................................................................................................................17

APPENDIX 1: OPTION MAP......................................................................18

APPENDIX 2: LIST OF PRELIMINARY SUBMISSIONS...................................20

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Executive summaryThe Local Government Act 1989 (the Act) requires the Victorian Electoral Commission (VEC) to

conduct an electoral representation review of each local council in Victoria at least before every

third council general election.

The purpose of a representation review is to recommend an electoral structure that provides fair

and equitable representation for the persons who are entitled to vote at a general election of the

council. The matters considered by a review are:

the number of councillors

the electoral structure of the council (whether the council should be unsubdivided or

divided into wards and, if subdivided, the details of the wards).

The VEC conducts all reviews based on three main principles:

1. taking a consistent, State-wide approach to the total number of councillors

2. if subdivided, ensuring the number of voters represented by each councillor is within plus-

or-minus 10% of the average number of voters per councillor for that local council

3. ensuring communities of interest are as fairly represented as possible.

2019 electoral representation reviewThe current representation review for Benalla Rural City Council commenced on Wednesday

6 February 2019.

Current electoral structureBenalla Rural City Council currently comprises seven councillors elected from an unsubdivided

electoral structure. Prior to the last representation review in 2007, Benalla Rural City Council was

comprised of seven councillors elected from seven single-councillor wards.

Visit the VEC website at vec.vic.gov.au to access a copy of the 2007 review final report.

Preliminary submissionsAt the close of submissions at 5.00 pm on Wednesday 6 March 2019, the VEC had received four

submissions for the representation review of Benalla Rural City Council. These submissions can

be viewed on the VEC website at vec.vic.gov.au and a list of those people or organisations that

made a submission is available at Appendix 2.

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http://www.vec.vic.gov.au/



VEC optionThe following option is being considered by the VEC:

Option A (preferred option)

Benalla Rural City Council consist of seven councillors elected from an unsubdivided electoral structure.

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BackgroundLegislative basisThe Act requires the VEC to conduct a representation review of each local council in Victoria

before every third general council election, or earlier if gazetted by the Minister for Local

Government.

The Act specifies that the purpose of a representation review is to recommend the number of

councillors and the electoral structure that provides ‘fair and equitable representation for the

persons who are entitled to vote at a general election of the Council.’1

The Act requires the VEC to consider:

the number of councillors in a local council

whether a local council should be unsubdivided or subdivided.

If a local council should be subdivided, the VEC must ensure that the number of voters

represented by each councillor is within plus-or-minus 10% of the average number of voters per

councillor for that local council.1 On this basis, the review must consider the:

number of wards

ward boundaries

number of councillors that should be elected for each ward.

Public engagement

Public information program The VEC conducts a public information program to inform the community of the representation

review, including:

public notices printed in local and state-wide papers

a public information session to outline the review process and respond to questions from

the community

a media release announcing the commencement of the review

coverage through the local council’s media

advertising on the VEC’s social media

contact with community groups and networks

ongoing information updates and publication of submissions on the VEC website

1 Section 219D of the Local Government Act 1989.

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a submission guide to explain the review process and provide background information on

the scope of the review.

Public consultationPublic input is accepted by the VEC in:

preliminary submissions at the start of the review

response submissions to the preliminary report

a public hearing that provides an opportunity for people who have made a response

submission to expand on this submission.

Public submissions are an important part of the process but are not the only consideration during

a review. The VEC ensures its recommendations are in compliance with the Act and are formed

through careful consideration of public submissions, independent research, and analysis of all

relevant factors.

The VEC’s principlesThree main principles underlie all the VEC’s work on representation reviews:

1. Taking a consistent, State-wide approach to the total number of councillors.

The VEC is guided by its comparisons of local councils of a similar size and category to

the council under review. The VEC also considers any special circumstances that may

warrant the local council having more or fewer councillors than similar local councils.

2. If subdivided, ensuring the number of voters represented by each councillor is within plus-or-minus 10% of the average number of voters per councillor for that local council.

This is the principle of ‘one vote, one value’, which is enshrined in the Act. This means

that every person’s vote counts equally.

3. Ensuring communities of interest are as fairly represented as possible.

Each local council contains a number of communities of interest. Where practicable, the

electoral structure should be designed to ensure they are fairly represented, and that

geographic communities of interest are not split by ward boundaries. This allows elected

councillors to be more effective representatives of the people and interests in their

particular local council or ward.

Developing recommendationsThe VEC bases its recommendations for particular electoral structures on the following

information:

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internal research specifically relating to the local council under review, including

Australian Bureau of Statistics and .id data2; voter statistics from the Victorian electoral

roll; and other State and local government data sets

the VEC’s experience conducting previous electoral representation reviews of local

councils and similar reviews for State elections

the VEC’s expertise in mapping, demography and local government

careful consideration of all input from the public in written submissions received during

the review

advice from consultants with extensive experience in local government.

Deciding on the number of councillorsThe Act allows for a local council to have between 5 and 12 councillors but does not specify how

to decide the appropriate number.3 In considering the number of councillors for a local council,

the VEC is guided by the Victorian Parliament’s intention for fairness and equity in the local

representation of voters under the Act.

The starting point in deciding the appropriate number of councillors for a local council is

comparing the local council under review to other local councils of a similar size and type

(Principle 1). Generally, those local councils that have a larger number of voters will have a

higher number of councillors. Often large populations are more likely to be diverse, both in the

nature and number of their communities of interest and the issues of representation.

However, the VEC also considers the particular circumstances of each local council which could

be cause for more or less councillors, such as:

the nature and complexity of services provided by the Council

geographic size and topography

population growth or decline

the social diversity of the local council.

Deciding the electoral structureThe Act allows for a local council ward structure to be unsubdivided—with all councillors elected

‘at-large’ by all voters or subdivided into a number of wards.

If the local council is to be subdivided into wards, there are three options available:

1. single-councillor wards

2 .id is a consulting company specialising in population and demographic analysis and prediction information products in most jurisdictions in Australia and New Zealand.3 Section 5B(1) of the Local Government Act 1989.

Page 5 of 20


2. multi-councillor wards or

3. a combination of single-councillor and multi-councillor wards.

A subdivided electoral structure must involve internal ward boundaries that provide for a fair and

equitable division of the local council.

The Act allows for wards with different numbers of councillors, as long as the number of voters

represented by each councillor is within plus-or-minus 10% of the average number of voters per

councillor for that local council (Principle 2). For example, a local council may have one three-

councillor ward with 15,000 voters and two single-councillor wards each with 5,000 voters. In this

case, the average number of voters per councillor would be 5,000.

Over time, population changes can lead to some wards in subdivided local councils having larger

or smaller numbers of voters. As part of the review, the VEC corrects any imbalances and takes

into account likely population changes to ensure ward boundaries provide equitable

representation for as long as possible.

In considering which electoral structure is most appropriate, the VEC considers the following

matters:

the VEC’s recommendation at the previous representation review and the reasons for

that recommendation

the longevity of the structure, with the aim of keeping voter numbers per councillor within

the 10% tolerance for as long as possible (Principle 2)

communities of interest, consisting of people who share a range of common concerns,

such as geographic, economic or cultural associations (Principle 3)

the number of candidates in previous elections, as outcomes from previous elections

indicate that large numbers of candidates can lead to an increase in the number of

informal (invalid) votes

geographic factors, such as size and topography

clear ward boundaries.

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Public submissions (preliminary)The VEC received four preliminary submissions by the deadline for submissions at 5.00 pm on

Wednesday 6 March 2019. These submissions can be viewed on the VEC website at

vec.vic.gov.au and a list of those people or organisations that made a submission is available at

Appendix 2.

Number of councillors Three preliminary submissions supported leaving the number of councillors at seven. These

submissions reasoned that seven councillors is appropriate for Benalla Rural City Council as this

is consistent with other Regional Centre local councils with a similar size and number of voters,

and that there were no special circumstances to justify an increased number of councillors. Of

these three submissions, one also supported reducing the number of councillors to five if there

was strong justification and community support for such a change.

The fourth preliminary submission did not clearly indicate a preferred number of councillors.

There were no calls for increasing the number of councillors in any of the preliminary

submissions received.

Electoral structure Three preliminary submissions supported keeping the current unsubdivided electoral structure in

Benalla Rural City Council.

Submitters Margaret Connors and Wendy Mullet argued that the current electoral structure was

an improvement on the subdivided electoral structure previously in place in Benalla Rural City

Council. Ms Connors and Ms Mullet also argued that the unsubdivided electoral structure

encouraged councillors to take a ‘whole-of-shire’ approach to representation, and that this had

resulted in fairer representation and improved strategic development and planning for the entire

local council area.

The Proportional Representation Society of Australia (Victorian-Tasmania) Inc. (PRSA) also

supported keeping the current unsubdivided electoral structure, arguing that the proportional

representation system, which is used in unsubdivided and multi-councillor electorates, was the

fairest system because it maximises the number of effective votes. The PRSA also argued that

the unsubdivided electoral structure:

maximises the choice of candidates for voters

encourages councillors to be equally informed about the entire local council area

facilitates representation for non-geographic communities of interest

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removes confusion about the location of ward boundaries and

removes the need to make periodic re-adjustments to ward boundaries to cater for

changes in enrolment numbers.

The fourth preliminary submission did not clearly indicate a preferred electoral structure.

A move to a subdivided electoral structure for Benalla Rural City Council was not supported by

any preliminary submissions.

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The VEC’s findings and optionsPreliminary report findings

Number of councillors The VEC considers that seven is the most appropriate number of councillors for Benalla Rural

City Council.

Benalla Rural City Council is in the Regional Centre category of local councils. The local council

covers an area of 2,375 square kilometres and currently has 12,131 voters. Compared to other

local councils in this category, Benalla Rural City Council is well within the seven-councillor

grouping, sitting between Horsham Rural City (with 16,454 voters) and Ararat Rural City (with

9,311 voters). Among Regional Centre local councils, Benalla Rural City Council has the second

smallest voter population after Ararat Rural City Council.

In some cases, special circumstances may exist in a local council area that support a

recommendation for fewer or more councillors. While Benalla Rural City Council has its own

characteristics and challenges, the VEC’s analysis and information provided in preliminary

submissions did not identify any special circumstances that would support a recommendation to

change the number of councillors.

Benalla Rural City Council has a stable population and is not projected to experience significant

population growth or decline over the mid- and long-term outlook4. The population within the local

council is largely socially and linguistically similar, and rural areas have below average levels of

disadvantage compared to other local councils in regional Victoria5. On the other hand, the

population is ageing6 and the Benalla urban area is experiencing higher than average levels of

disadvantage7, however these factors are not sufficient to warrant consideration of increasing the

number of councillors.

For these reasons, the VEC has concentrated its modelling for this representation review on

seven-councillor options for consultation.

4 Department of Environment, Land, Water and Planning, ‘Victoria in Future 2016’, 2016, https://www.planning.vic.gov.au/__data/assets/pdf_file/0030/97608/Victoria-in-Future-2016-FINAL-web.pdf.5 .id, ‘Benalla Rural City: SEIFA by profile area’, https://profile.id.com.au/benalla/seifa-disadvantage-small-area, accessed 20 March 2019.6 Department of Environment, Land, Water and Planning, loc. cit..7 .id, loc. cit..

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https://profile.id.com.au/benalla/seifa-disadvantage-small-area

https://profile.id.com.au/benalla/seifa-disadvantage-small-area

https://www.planning.vic.gov.au/__data/assets/pdf_file/0030/97608/Victoria-in-Future-2016-FINAL-web.pdf

https://www.planning.vic.gov.au/__data/assets/pdf_file/0030/97608/Victoria-in-Future-2016-FINAL-web.pdf


Comparable Regional Centre local councils to Benalla Rural City Council

Local Council Area (km2)

Population (2016

Census)

Number of voters at

last review

Current estimate of

votersNumber of councillors

Number of voters per councillor

Mildura Rural City 22,330 53,878 39,443 41,305 9 4,589

Mitchell Shire* 2,864 40,918 29,817 33,781 9 3,753

Wodonga City 433 39,351 29,002 32,230 7 4,604

Warrnambool City 120 33,655 26,116 27,497 7 3,928

Wangaratta Rural City 3,639 28,310 22,094 23,168 7 3,309

Horsham Rural City 4,249 19,642 16,048 16,454 7 2,350

Benalla Rural City* 2,375 13,861 10,934 12,131 7 1,733Ararat Rural City* 4,230 11,600 9,141 9,311 7 1,330

* The local council is undergoing an electoral representation review by the VEC during 2019–20

Electoral structureIn 2007, the VEC recommended that Benalla Rural City Council change to an unsubdivided

electoral structure. The reasons for making this change were that an unsubdivided electoral

structure:

recognised the shared interests and interdependence between the rural and urban areas

of the local council

supported a whole-of-shire perspective for voters and councillors

reduced the likelihood of uncontested elections, which occurred during the 2003 and

2005 general council elections.

The VEC also considered that the subdivided electoral structure that was in place at the time of

the 2007 representation review did not meaningfully represent communities of interest in the

local council.

The current unsubdivided electoral structure has been in place for three general elections of the

Council (in 2008, 2012 and, most recently, 2016).

Of the 14 candidates in the 2008 general election, the majority were from the Benalla urban area

(nine), while four candidates were from the rural south and one candidate from the rural north of

Benalla Rural City. This election returned five councillors from the urban area and two councillors

from the rural south (Moorngag and Warrenbayne).

At the 2012 election there were nine candidates for Benalla Rural City Council, again with the

majority from the Benalla urban area (eight) and one from the rural south (Moorngag). This

election returned six councillors from the urban area and one councillor from Moorngag.

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The most recent general election in 2016 included a much larger field of candidates for Benalla

Rural City Council (20). The majority of candidates were, again, from the Benalla urban area

(17), two candidates were from Tatong in the rural south, and one candidate was from

Glenrowan West, east of Benalla itself. The 2016 election returned six councillors from the urban

area and one councillor from the rural township of Tatong.

Overall, in each election there have been few candidates standing from outside of the Benalla

urban area, and rural candidates have largely been drawn from the southern portion of the local

council area. However, despite the smaller number of candidates standing from rural areas

(compared to the number of candidates from urban Benalla), every election has returned at least

one rural councillor. It could be concluded that, when rural candidates have stood for election

under the current unsubdivided electoral structure, they have often been successful. This may

indicate that although most of the Benalla Rural City Council population resides in Benalla itself,

there is sufficient support for rural candidates to be elected when they do stand.

The proportion of councillors from the Benalla urban area versus those from rural areas broadly

echoes the overall population distribution in the local council: approximately 75% of the Benalla

Rural City population resides in urban Benalla, and 70-85% of councillors elected during the

2008-2016 general elections have resided in urban Benalla.

It is also worth noting that during the 2016 general election there was a higher level of informal

voting by Benalla Rural City Council voters. In 2016, 7.56% of votes were informal, compared to

3.80% for 2012 and 2.92% for 2008. While it is not certain what caused this increase in informal

votes in 2016, the VEC has generally observed informal voting rates tend to increase as more

candidates are listed on the ballot paper8. This is one of the drawbacks of an unsubdivided

electoral structure, which can encourage larger fields of candidates at elections and lengthier

ballot papers. Longer ballot papers can be confusing for voters, leading to higher levels of

informal voting through voter error.

The general arguments in support of an unsubdivided electoral structure outlined in the 2007

representation review still apply for Benalla Rural City Council. However, given the larger field of

candidates and higher rate of informal voting observed at the 2016 general election, the VEC

considered that both unsubdivided and subdivided electoral structures should be examined

during this representation review.

Modelling of electoral structures was undertaken to:

test the viability of potential structures

capture geographic communities of interest identified through research

8 Victorian Electoral Commission, 2016 Local Government Elections Report, 2017, Figure 9, pp. 26, https://www.vec.vic.gov.au/files/Report%20on%20the%20conduct%20of%20the%202016%20Local%20Government%20Elections.pdf

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https://www.vec.vic.gov.au/files/Report%20on%20the%20conduct%20of%20the%202016%20Local%20Government%20Elections.pdf

https://www.vec.vic.gov.au/files/Report%20on%20the%20conduct%20of%20the%202016%20Local%20Government%20Elections.pdf


determine whether these structures would adequately represent the communities within

the local council, while complying with legislative requirements.

Due to the uneven distribution of voters across Benalla Rural City, possible options for

subdivided electoral structures are limited. The following sections outline the models explored

during the development of the preliminary option for Benalla Rural City Council.

Single-councillor ward structures

The VEC considered single-councillor ward structures. Due to the population concentration in the

Benalla urban area and the need to set and maintain voter-to-councillor ratios within the

acceptable legislated tolerance, any single-councillor ward model would need to split Benalla into

at least three very small wards with arbitrary ward boundaries that divide the locality. The

community within the Benalla urban area clearly shares a strong interest, and any subdivided

electoral structure ought to incorporate the entire Benalla urban area within one ward. A single-

councillor ward structure also poses challenges for widespread or non-geographic communities

of interest to be represented in the local council. Therefore, electoral structures based purely on

single-councillor wards were found to be inappropriate for Benalla Rural City Council.

Three-ward structure

The VEC modelled a mixed electoral structure with three wards, which was based on the first

alternative option from the VEC’s last representation review of Benalla Rural City Council in

2007.

This model consisted of a five-councillor ward for the Benalla urban area and its immediate

surrounds, and two single-councillor wards for the remaining northern and southern areas of the

local council. Ward boundaries were modified from the 2007 model to account for changes in the

distribution of the population across the local council since 2007. This model included Glenrowan

West (located south of the Hume Freeway) in the northern ward.

The benefits of this model are that the three distinct regions of the local council area (rural north,

rural south and urban Benalla) are recognised, voter-to-councillor ratios are balanced across

wards, and this structure may help reduce the likelihood of high numbers of informal votes at

future elections.

However, there are a number of concerns that prevented the VEC from putting this model

forward as an option for this review.

Firstly, the three general regions of the local council area are not cleanly represented. Although

the Hume Freeway is a logical boundary between the northern and southern rural areas of the

local council, the Hume Freeway could not be used as a ward boundary to separate north and

south wards in the eastern part of the local council. Glenrowan West is located south of the

Hume Freeway, but had to be included in the northern ward to balance voter-to-councillor ratios

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across all three wards. Also, some rural areas surrounding the Benalla urban area had to be

included in the urban ward, also to balance voter numbers across wards. Therefore, the three-

ward model does not cleanly represent the areas either side of the Hume Freeway, or cleanly

divide urban and rural areas of the local council.

Also, this model divides the Benalla Rural City community, separating the urban and rural areas

of the local council. During the 2007 representation review, the VEC recognised that, because

Benalla is the major service centre in the local council and is centrally located within the local

council area, there is a substantial degree of interdependence between the urban and rural parts

of the local council. Therefore, the entire council area could potentially be considered a

community of interest.

There is also a risk of uncontested elections with this subdivided model. Benalla Rural City

Council had a history of uncontested elections under the subdivided electoral structure in place

prior to 2007 (seven single-councillor wards). Since the introduction of the unsubdivided electoral

structure at the 2008 general election, there have also been few candidates standing from rural

parts of the local council area, particularly from areas north of the Hume Freeway. Since 2007,

only one candidate from north of the Hume Freeway has stood for election. This indicates a risk

of uncontested elections for any subdivided electoral structure, especially for a rural north ward.

Uncontested elections are not desirable in the goal to achieve fair and equitable representation

as, by definition, voters are not given the opportunity to elect a representative of their choice.

Due to the distribution of voters throughout the local council area, the urban ward would always

have the majority of councillors. This subdivided electoral structure would guarantee two rural

councillors (one from north of the Hume Freeway and one from the south) but would also limit

the number of councillors that could be elected for rural areas9.

Finally, there was little public support expressed for this option during the 2007 representation

review, and no support expressed in preliminary submissions for the current review.

For these reasons, the three-ward model was not considered appropriate for Benalla Rural City

Council.

9 The VEC notes that a person enrolled for a local council general election may stand as a candidate in any ward for that council, regardless of which ward they are enrolled in.

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Option A: Seven councillors elected from an unsubdivided electoral structure (the current electoral structure)

The VEC recommended the current electoral structure following its last representation review of

Benalla Rural City Council in 2007. After investigating and modelling possible alternatives, the

VEC considers that the current unsubdivided electoral structure continues to be the best option

for providing fair and equitable representation for voters within Benalla Rural City Council.

Support for continuing with the current unsubdivided electoral structure was expressed through

preliminary submissions to this review. Also, under the current unsubdivided electoral structure

rural candidates appear to have had sufficient support to be elected, and preliminary

submissions did not indicate any support for a change to the existing electoral structure. When

considered together, these factors indicate that the current electoral structure is functioning well

for Benalla Rural City Council and change is not required.

The benefits of continuing with the current unsubdivided electoral structure include:

allows communities of interest to remain undivided

there is no risk of the voter-to-councillor ratio exceeding the plus-or-minus 10% tolerance

over the next 12 years, which would be a possibility with wards due to the uneven

population distribution across the local council area

supports a Shire-wide approach to representation and community identity

provides an opportunity for multiple councillors to be elected from any part of the local

council area

enables voters to select from a wider pool of candidates

provides an overall balance between the needs of various groups in the local council and

legislative requirements

reduces the likelihood of uncontested elections, which was an issue with the previous

single-councillor ward electoral structure

provides an opportunity for councillors to share responsibilities and workloads equitably

provides an opportunity for candidates to be elected from geographic and non-geographic

communities based on their proportion of support across the local council.

However, the VEC does acknowledge the possibility of longer ballot papers and higher levels of

informal voting under unsubdivided electoral structures.

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OptionsThe VEC is required by the Act to include a preferred option and may include one or more

alternative options for the electoral structure in the preliminary report. The VEC considers that

only the option outlined below offers fair and equitable representation for voters in the local

council. Please see Appendix 1 for a detailed map of this option.

Option A (preferred option)Benalla Rural City Council consist of seven councillors elected from an unsubdivided electoral structure.

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Next stepsResponse submissionsAny person or group, including the council, can make a submission to the VEC in response to

the options contained in this report. Response submissions to the preliminary report should

address the model proposed by the VEC within this report. Response submissions must be

received by the VEC by 5.00 pm on Wednesday 1 May 2019. Late submissions will not be

accepted.

Submissions must include the full name, address and contact telephone number of the submitter.

Submissions without this information cannot be accepted.

Submission methodsSubmissions can be made via:

The online submission form at vec.vic.gov.au

Email at [email protected]

Post toVictorian Electoral CommissionLevel 11, 530 Collins StreetMelbourne VIC 3000

Public access to submissionsTo ensure transparency in the electoral representation review process, all submissions will be

available for public inspection at:

the VEC website at vec.vic.gov.au

the VEC office at Level 11, 530 Collins Street, Melbourne.

The VEC will remove personal information such as address, phone number, and signature, if

applicable, from all public copies. However, the full name and locality of submitters will be

displayed.

Public hearingThere is an opportunity for people or organisations who have made a response submission to

speak about their submission at the public hearing. The public hearing is scheduled to be held at

6.00 pm on Tuesday 7 May 2019 at the Community Care Centre, Coster Street, Benalla. If you

wish to speak at the public hearing, you must indicate this on your response submission. If there

are no requests to speak at the hearing, it will not be held.

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mailto:[email protected]

http://vec.vic.gov.au/


Final reportFollowing the public hearing, the VEC considers all the evidence it has gathered and publishes a

final report for the Minister for Local Government containing a recommended electoral structure.

The report is scheduled to be published on Wednesday 29 May 2019. Any changes resulting

from the final report will apply at the October 2020 general election.

The final report will be available from the VEC by visiting vec.vic.gov.au or calling 131 832 and

for inspection at the offices of Benalla Rural City Council.

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Appendix 1: Option mapThe following map is included in this report:

Map Page

Option A (preferred option) 19

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Appendix 2: List of preliminary submissionsFour preliminary submissions were received in total. Submissions were made by:

Connors, Margaret

Marshall, Heidi

Mullett, Wendy

Proportional Representation Society of Australia (Victoria-Tasmania) Inc.

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