Talkin' 'bout term limits

It appears that a legislative term limits measure will be on the ballot this fall. Members of the Oregon House would be limited to three 2-year terms, members of the Oregon Senate to two 4-year terms. Overall, legislators would be limited to a total of 12 years.

Recent articles on the measure have appeared in the Corvallis Gazette-Times and the CFM Insider.

Who wins under term limits? From the G-T:

“If you want to turn over the keys to the State Capitol to the state bureacracies and lobbyists, then put in term limits,’’ says Democratic state Sen. Alan Bates, a physician who runs a family practice in Ashland when he’s not working as a legislator in Salem.

Of course, Oregon had term limits for a decade - from 1992 to 2002 - so this isn't just a theoretical conversation. What happened? Among the effects noted by the CFM Insider:

* Term limit backers believed legislators would be freed from fears of re-election and focus on the tough issues of the day. Instead, lawmakers quickly realized they barely had time to learn where the bathroom was, let alone make a dent on big issues, so they avoided them and concentrated on topics that had a short-term payoff. It was during this period of time that school funding problems worsened, while lawmakers gave voters the chance to lock the personal and corporate income tax kickers into the state Constitution.

* Instead of pushing political considerations aside, politics became more paramount. For example, Speaker Snodgrass maneuvered much of her third and final House term for a run for Secretary of State. Many House members plunged into Senate races instead of seeking re-election to extend their legislative careers. Political time horizons, like public policy time horizons, shrunk. It was during this period that majority and minority caucuses in the House and Senate became more dominant, producing a more partisan legislature. The gridlock evident in the legislature today has its roots in legislative term limits, when leaders of both parties worried more about how their caucus would fare than individual members who were destined to come and go.

But will anyone organize a campaign against it? Again, the G-T:

Business, labor and political groups already are talking about forming a coalition to mount a major campaign to try to persuade voters to reject a new term limits law. Salem lobbyist Mark Nelson, who’s involved in the effort, says term limits drained the Legislature of veteran leadership and institutional memory and led to excessive partisanship among lawmakers. “I’ve heard from a lot of different organizations and individuals who say, ‘We just can’t let this happen again,’ “ Nelson said. “We are just now recovering from the hangover from term limits.’’

Read the rest at the Corvallis Gazette-Times and the CFM Insider. Discuss.

  • KISS (unverified)
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    I can see why term limits would irk the lobbyists. Their candidates would be a new crop to buy each session, instead of the " Bought and Paid Group" of old. Once bought always bought was the motto and now with term limits a new expensive game plan will have to be reworked. If,and a big if, were that voters weren't lazy and would read up on their elected officials..just maybe we would not need term limits. Nah, that ain't never gonna happen..viva Term Limits.

  • Anne (unverified)
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    The Medford Mail Tribune also has an excellent editorial on the subject here: http://www.mailtribune.com/archive/2006/0725/edit/edit.htm

  • Sponge (unverified)
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    Term limits don't "irk the lobbyists," KISS; just the opposite. The lobbyists (and state bureaucrats) become the keepers of institutional knowledge at the capitol. With term limits, the seasoned legislative veterans are those with two terms under their belts, while many of the lobbyists have been around for decades. The above quotes from the CFM Insider are dead-on accurate in their analysis of the failure of term limits.

  • Patrick Allen (unverified)
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    Term Limits: Stop me before I vote again!

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    Term limits is definitely a two edged sword for lobbyists. On balance, lobbyists do not like limits.

    Lobbying is a relationship business. Yes, institutional memory is important, but the influence lobbyists or lobbying groups have is more directly related to the depth and strength of their relationships with key legislators - the committee chairs and leadership.

    When those jobs turn over quickly, lobbyists have the uncertainty of whether they can develop equally strong relationships with the new people. That takes time, money and effort.

    That said, it cuts both ways. Term limits also gets rid of committee chairs and leaders that some lobbyists might not have good relationships with, and therefore it helps them.

    But - I think this is safe to say: the most influential lobbyists and groups in Salem (on both sides) have far more to lose from term limits than to gain.

    I think that is why you will see most of them oppose this measure.

    Does that make this measure good? Not necessarily. On the question of "institutional memory," I think term limits shift relative power to agency bureaucrats more than it does to lobbyists. It is hard for even experienced legislators to cut through the agencies' constant game of "hide the salami," so the new ones basically have no shot. That is a problem.

    On the other hand, a very real result under the current system is that veteren legislators are very often co-opted by the agencies they are supposed to oversee. Happens all the time. So even when they do learn enough to be effective watchdogs, all-too-often the agency's access and constant feeding of one-sided (mis)information results in the veteran legislator being "captured" by the agency.

    So, in sum, the whole thing is a mixed bag. Last time I voted for term limits, because I thought that it just might be a "bad idea whose time has come."

    This time I am still undecided.

  • PRK (unverified)
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    Here, here, KISS! You know, since voters can't be trusted to make decisions for themselves, we should really just let the Politburo decide the candidates and run the elections. I for one feel great relief when others just tell me who I can and can't vote for. It takes away the stress in my life brought on by self-determination.

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    Hey Portlanders- if you want to discuss this stuff in person, and meet some progressive legislators and candidates, tonight's Bus Project Presents forum is for you.

    Tonight, 7-9pm, at Acme (SE 8th and Main.) Free, all ages.

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    Rob... I'm pretty sure you meant "hide the ball". The phrase "hide the salami" means something else altogether.

    In any case, I think your analysis is basically right, but I'd take it a step further. When the legislators are always new, don't have any information, and don't necessarily have the understanding it takes to withstand the lobbyists' influence, we get less democracy - not more.

    With experience, legislators can develop their own expertise -- and the confidence and power to withstand the entreaties of lobbyists and special interests.

    Term limits are a disaster.

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    And the long comment I had worked on to lead off the "comments" section was bounced because Typepad thought I was Spam?

    As chief petitioner of two of the previous TL initiatives I have responded to some of the anti-TL hyperbole over on my blog.

    However suffice it to say that the lead story above is wrong on a few counts.

    First of all it is deceptive to say that we had TL's for a decade. It was actually just shy of a decade and they had actually just begun to take effect. In fact the previous law never really was given a chance as many TL violating legislators never were term limited (Westlund, Hannon etc...).

    Secondly to blame gridlock on TLs is... well... I thought we had gridlock now? Isn't that why we needed the silly non-partisan ballot initiative? Because partisan gridlock was killing the legislature? NEWS FlASH: This has happened WITHOUT term limits being in place.

    Another part of the story was that somehow Lyn Snodgrass was unusual to use her speakership as a stepping stone to a higher office. Oh now that is certainly a new side effect from TLs.

    Kinda like Sen. Smith using his state senate leadership position to jump to higher office. Before TLs.

    Kinda like Bradbury using his senate leadership position to angle for higher office. Before TLs.

    Kinda like Kevin Mannix using his elected position to jump to higher office.

    Another news flash. Politicians use their current positions to jump to higher office. With or without TLs.

  • Jesse O (unverified)
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    I find it ironic that people who make their living off of initiatives (somehow trusting the voters to be smart enough to figure out complex policy decisions) are often the same people who want to limit the voters' ability to choose who can represent them (by passing term limits).

    What? What's that you say? Incumbents can out-raise challengers? Money confuses voters? Oh, and initiative wars aren't about money buying confusing messages to voters?

    If the problem is corrupt powerful politicians, vote them out of office. Don't throw the baby out with the bathwater (and the salami).

    Term limits limit voter choice. By definition.

  • Baloo (unverified)
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    I'm not sure how much of a difference, if any, state term limits will make until term limits are in place for all US legislators and not just Oregon's US legislators. What good does local term limits do if the feds are determined to undermine us?

  • Baloo (unverified)
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    And is there a compelling reason BlueOregon uses TypePad instead of something a little less bogus like slashcode, which offers greater ease of use for users and threaded replies?

  • Sponge (unverified)
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    Try to keep up, Baloo. Oregon's US legislators are not term-limited, nor does the current initiative propose such a thing.

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    (Let's not go off into meta-land, but to answer your question, Baloo: We use Typepad because at the time we launched Blue, it was the best of the hosted blog systems. We're continually looking at ways to improve things, including hosting it on our own server, but this is where we are for the foreseeable future.)

  • Levon (unverified)
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    Why not term limits for voters? If we don't want legislators with experience and institutional memory, why allow them for voters?

    Nothing like a fresh set of eyes to analyze the ballot and make decisions about who to put in office.

    In fact, why not demand it for every profession/position? Doctors? 10 years of practice and you're out. Dentists? 8 years. Lawyers? 2 years.

    Married to that special someone? (yes, you're straight). You've got 5 years to enjoy your matrimony and then it's time to move on.

  • djk (unverified)
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    I really don't see the benefit of depriving my district of an honest, capable, hard-working representative because she's been around three terms. Term limits are idiotic; they bar us from keeping good people in office. The legislature needs reform, but that reform needs to occur at the level of House and Senate rules. You want to get rid of your crappy legislator, vote him out. But let us keep our good one.

    Whatever case there might be for terms limits vanishes completely in Oregon, with an underpaid, part-time citizen legislature meeting six to eight months out of every two years. Amateur legislators with no experience in the political process, no respect for the institution, and a lot of ignorant ideology can be tempered by seasoned veterans who have grown past all of that. With terms limits, we get permanent amateur hour. We replace a third or more of the legislature every year.

    This also is an invitation to irresponsible budgeting. Why not drain the reserves, pass an irresponsible tax cut, or a bill that will mandate a crapload of spending three years down the line? You won't be around to deal with it.

    And hey ... that third term, when you can't run again anyway? Who the hell cares what the voters think? You don't answer to them anymore ... unless, of course, you're using your final term to campaign for your next office on the taxpayers' nickel. (Now, as for the interests of that company that could be really, really good to you when you leave office...)

    Personally, the only term limit I want to see is a one-consecutive-term limit on committee chairs in both Houses.

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    I was asked to allow myself to be nominated as the non-partisan fifth member of the commission designated to write the ballot language, and I had to decline, even though I'm as good as anyone (I'd like to think) at poking holes in arguments made by proponents and opponents.

    Why? Because pointy headed academic types have studied the impact of term limits for a decade now, and the consensus finding is clear: term limits are bad public policy.

    Term limits hurt legislative productivity. Term limits remove our most experienced legislators ("workhorses") from office. Term limits do little to reduce government spending, increase government responsiveness, or any of the other various claims that are made for them. Term limits empower the executive branch, bureaucrats, and interest groups over the legislative branch.

    Look, legislative turnover is a GOOD THING from a little d democratic perspective. Legislative turnover increases responsiveness, improves representation, and helps bring new elites into the system.

    But this is a misdirected sledgehammer approach. To increase turnover, you can:

    • Publicly finance elections (or at least challengers)
    • Help challengers via free media time
    • Improve the quality of challengers by making sure we have vital political parties and other activist organizations

    • And my personal favorite: Create a non-partisan redistricting process so that we don't draw safe seats

  • Rep. Peter Buckley (unverified)
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    I'm with Paul on this one.

    We held a town hall meeting a few months back, and the issue of term limits came up, and there was some good banter back and forth along the lines of "sure, you are opposed now that you're elected." But I've got to say that I think the limits are absurd. There is such a huge learning curve to this job--I defy anyone to get a handle on the Department of Human Services budget in two years or even four--that to shut someone off from serving in the House after three terms simply cements a lack of quality into place.

    After just about two years in this job, I am finally feeling confident of who to call on what issue, and what pressure to put on where to help a constituent or get traction on an issue. I have no idea of how long I can last as a legislator, given what the impact is on my family, but I know I will be a better representative in 2007 than I was in 2005, and better than that in 2009, etc.

    Paul's approach to a healthy turnover is one I back 100%.

  • LT (unverified)
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    Peter, Paul, Jesse O, djk all have the right idea. TERM LIMITS HAS BEEN TRIED! There are people who consider it an abject failure--what was promised by the sponsors was not what happened.

    The most glaring example would be Speaker Simmons getting that lobbying job before his term as Speaker was over. Just how many terms had Mark Simmons served in the legislature? Under term limits, was he out the door of the legislature after the session he was Speaker and was that why he was looking for a lobbyist job?

    Closer to home, the district just to the south of us (now 19, previously 30) was a mainly rural district. For years there was a wonderful state rep. in tune with his rural constituents. Larry Wells was a very strong leader in water quality (fishing would be ruined if water was polluted) and was one of those rare legislators who met with ordinary constituents incl. those not yet old enough to vote. I took some high school students to his office one time and we were treated as very important visitors. Not only that, but his office was the model of polite, friendly treatment of all who came to visit.

    Term limits ended Wells' political career. Was he replaced by someone equally concerned about the residents of the district, someone equally friendly and honest? No, he was replaced by Dan Doyle (who left office and was convicted of campaign violations and jailed--is he out on probation now?).

    If the term limits advocates can cite an example in reverse (cocky legislator replaced by someone who really cared about the ordinary citizens in the district), let them post that example here. I am not sure that example exists.

    If the entire term limits campaign (from idea to money to all the other parts of the campaign) had come from Oregon with no help from any other state, that would be one thing. But my guess is that the folks in US TERM LIMITS never heard of Dan Doyle. But they want us to vote for their ballot measure because they know what is best for people in a state where they don't live?

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    Paul -- Given that you're an expert on the issue (er, pointy-headed academic type) why didn't you seek the 5th seat on the measure-description cmte?

    I don't understand. Aren't you exactly the sort of person we should want on that committee? (As opposed to a well-meaning but uninformed person...)

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    There is such a huge learning curve to this job--I defy anyone to get a handle on the Department of Human Services budget in two years or even four--that to shut someone off from serving in the House after three terms simply cements a lack of quality into place.

    ...especially since we're talking about citizen legislators, many of whom have day-jobs. You simply can't become an expert on the intricacies of policy, run for office, deal with constituents, and oh yeah - hold down a day job.

    I might (maybe!) be OK with term limits (but 12 years total, not the 6/8 split) if we had a full-time legislature. But not this part-time legislature.

  • Ooooo (unverified)
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    Married to that special someone? (yes, you're straight). You've got 5 years to enjoy your matrimony and then it's time to move on.

    Oooo, now there's an idea. How many signatures do we need?

  • Don Smith (unverified)
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    The appealing thing to me about the whole term limits argument, though I don't know whether I'll vote for it or not, is that if you have citizen-states(wo)men, rather than "workhorse politicians", you would hope that people become drawn to serve as a service to their state and go home, like the original intention of our government was.

    We have too many, IMO, people coming to Salem to become a fixture, whether in the legislature or down the road as a lobbyist. You all probably don't recognize the name Mark Sanford, but he was a South Carolina rep. He said he'd serve four two-year terms and get out. He parlayed that into a US House seat, said he'd serve two terms and get out. He did. He's now the governor.

    Now, you may look at that and say, he's just a politician trading up, and he was. But he kept his word (shocker), and left each of the posts when he said he would. The citizens rewarded him. He's now been an elected official for over 14 years. I don't know where he's going after the guv-ship, but I imagine he'll be able to do whatever he wanted. Point is, he's the kind of person we need more of. I don't know if term limits are the way to get there, but if the notion that once you get to Salem, it can be a forever-type appointment gets turned into, I'm going to Salem to serve my district for a few terms and get back to real life, I think that's a good thing. Unfortunately, I can't see that attitude coming about any way other than term limits, but I'd be open to it if there were.

    Term limits impose a limit on choice, but our current system fosters the wrong spirit in my opinion. The notion that I don't want to get rid of my good legislator is the wrong mindset, in my opinion. It just sets us up for more turf wars, more partisanship, and more gridlock.

    Politicians who are in it for the wrong reason will use their power in whatever ways are made available to them. Those in it for the right reasons are more likely to serve their districts and move on anyway, sometimes back to private life, sometimes up to higher office. Propose a better solution to our current problem, and I'll gather sigs for you. Otherwise, I think I'm prolly voting yes.

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    The appealing thing to me about the whole term limits argument, though I don't know whether I'll vote for it or not, is that if you have citizen-states(wo)men, rather than "workhorse politicians", you would hope that people become drawn to serve as a service to their state and go home, like the original intention of our government was.

    If you want people to do the work and go home, you'd be better off picking a legislature at random from the phone book.

    Of course, we might get much more progressive policy choices out of those folks. How many poor people do we have in the legislature? How many rich people? Does it match the population? Nope.

  • Zak Johnson (unverified)
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    In applying term limits to the private sector, there aren't a lot of successful companies out there who'd hire a C.E.O. with only a couple years experience. But those will be the only ones around to lead in the legislature, let alone serve, if this initiative passes.

    What we really need is an initiative to raise the number of signatures needed to qualify these endless initiatives. Say, 15% of all registered voters based on the last census? Now THAT's something I'd sign in a heartbeat. That would put our representative democracy back in the legislature where give-and-take trading and deliberation can have a chance to look at the larger implications of the sound-bites we're asked to vote on each election.

    (Making it harder to qualify would even make Sizemore & friends' services worth more. Are you listening, Bill?)

  • Paul Farago (unverified)
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    To blueoregon.com readers:

    Thank you for creating and participating in this thread. With support for legislative term limits at or near 70%, there can be no doubt than MANY progressives support the idea. As spokesperson for the initiative / ballot measure (if certified), I accept the broad diversity of support for term limits. We recognize that different people will support term limits for different reasons, and have no quarrel with that. And of course, while we are enthusiastic about legislative term limits, we do not claim it to be a "panacea" - nothing is.

    Complete information and history of legislative term limits in Oregon is available for review at: www.oregontermlimits.org. This website has been up and current since ... 1995 ... and now includes a blog. We welcome a discussion based on the facts and history of term limits, especially in Oregon.

    The "negatives" are already emitting from TL opponents in full force. As usual, newspapers have begun to editorialize "NO" - even before the initiative is certified and in all cases (so far) without even consulting us. If/when they do, they will find that proponents have a positive vision of good government. However, negative-campaigners typically try to define the "YES" side before proponents even have a chance to put their view forward. So this is expected, and we are prepared to answer.

    The founders understood the important and delicate relationship between government power and individual freedom/liberty. Rotation in office was a voluntary fixture of American democracy before the "Americans for Unlimited Government" movement took over. In Oregon, constitutional term limits for Governor, for example, date to our state's founding.

    Perhaps Benajmin Franklin but our vision best: "In free governments, the rulers are the servants, and the people their superiors and sovereigns. For the former, therefore, to return among the latter [is] not to degrade but to promote them."

    Paul Farago Spokesperson, Committee to Restore Oregon's Term Limits

  • Becky (unverified)
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    As spokesperson for the initiative / ballot measure (if certified), I accept the broad diversity of support for term limits.

    Apparently, however, you do not accept divergent views about the duration of the limits. Lest conservatives believe this is a conservative measure, take note that anyone who doesn't march in lock-step with these people's position is targeted by deep pockets, even if it means funding Democrats who oppose term limits but won't live long enough to break a self-limiting terms pledge over Republicans who support term limits but won't sign the pledge.

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    Don Smith,

    At the end of the session, what counts is not how we feel about our legislators' motives, it's the legislation they've crafted and how they voted.

    You base your argument on your intuitions - when there's plenty of data available. It was asserted in the CFM article that term limits have a negative imact, by providing an incentive to make a short-term splash (at the expense of focusing on the long term.) Do you disagree? Why?

    You ask us to propose a "better solution" without defining the problem. Here's a simpler solution for you: how about just term-limiting Karen Minnis?

    My congressman as a kid was Barney Frank. He's been in the US House for as long as I can remember. He was involved in a gay prostitution scandal, but there was never any doubt he would remain in office. But his staying-power isn't the result of corruption or DeLay-style greed - he represents his people well, and the progressive causes they believe in. (If you want to claim otherwise, you might want to do so over here.)

    Paul Farago:

    I didn't get past your first paragraph. If you're going to cite a stat that flies in the face of common sense, the least you could do is tell us a little about the study that produced it. In this case, I'd think "how was the question phrased" is the big thing...but also, was it Oregon? US? What year? Who funded the study, and who conducted it? etc.

  • Ross Williams (unverified)
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    Under term limits, was (Simmons) out the door of the legislature after the session he was Speaker and was that why he was looking for a lobbyist job?

    I don't think Simmons was term-limited at all, hadn't they already been thrown out by the courts? But even if he was, does anyone think being a part time legislator at low pay would prevent someone from taking a permanent well-paid job?

    you'd be better off picking a legislature at random from the phone book.

    Isn't that how the Greeks did it? I am not sure that we wouldn't get far better representation from a random cross section of people than we do from the self-selected bunch who get elected. Juries actually work pretty well that way. Select a third of one house every two years to six year terms and see what happens. Assuming people did a good job, they could run for the election to the other house. That would create some accountability.

    I always vote against term limits on the basis that people should be free to elect their representatives. Serena Cruz Walsh on the Multnomah County Commission has shown one of the problems with term limited representatives. They can stop being responsive at all to the voters.

    On the other hand I don't grieve very much when they pass and throw out a bunch of entrenched incumbents. You will notice very few of the people thrown out by term limits have been returned to the legislature now that they are no longer subject to them. I think that may be an indication that they weren't as valuable as some people seem to think. It was incumbency, not ability that kept them there.

  • Don Smith (unverified)
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    Pete:

    You're right, my argument is based largely on my intuitions. In fact, it's not really an argument as much as a cry for help.

    That said, I'd like to know what impact term limits have had in places where it has become the institutional norm, rather than the temporary experiment. I would like to believe that where it has become the norm, a different type of representative emerges, one who has the long view in mind because he's got to live in his district after he quits the legislature. We will certainly remember the legislator who seeks the short-term splash, because that's so obviously the wrong thing to do. We don't remember the guy who takes the long view, does the unsexy, and goes home.

    Should Barney (or anyone) represent his district in perpetuity? I just think that creates an industry around maintaining that power. And I believe that (1) changing the hands of power on SOME relatively periodic basis, (2) bringing in fresh ideas and representation by those still living in the real world, and (3) attracting candidates with a mind to do their part for a brief period to serve their community as opposed to as a career move

    are all good things, and are all things that term limits encourage. Democratic seats will always have a democrat. So there's no worry that "my guy" will get tossed and replaced with someone philosophically repugnant to me.

    The argument that bureaucrats will take over once term limits are in place assumes that somehow the legislators have them under control now, which I think is somehow less than accurate. I think there's a lot of salami hidden in Salem. (Thanks for that, Rob, I think salami's going to be hiding throughout the rest of this thread LOL)

  • djk (unverified)
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    paul is right. We need a non-partisan redistricting process. The major reason incumbents, even bad ones, can stay year after year is they're in safe districts. A completely neutral, largely mechanical process of drawing districts would prevent that outcome.

    Yes, a few seats would wind up as safe seats, just from demographic happenstance. Oregon's congressional districts are a fairly good example: we have a reliably Republican 2nd (rural) district, a devotedly Democratic 3rd (heavily urban) district, and the 1st, 4th and 5th Districts are all swing districts where a solid challenger could knock out a bad incumbent, regardless of party.

    Get rid of partisan gerrymandering, and we could see fairly healthy turnover in the legislature without leaving our state in the hands of inexperienced first-term rookies and unaccountable second- and/or third-term lame ducks.

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    Kari, Thanks for the compliment. I think the positions are filled.

    --

    Paul D. I don't impugn your motives--although you are awfully quick to accuse the opponents to your initiative as "negative campaigners."

    I've reviewed your website, and the arguments fall flat.

    You blame every malady in Oregon over the past five years on "career" politicians. Well, if that is the case, are you willing to credit the gains that Oregon made in the previous 20 years to the lack of term limits?

    You say that term limits dispenses with seniority. Why? Look to California--it has term limits and they still use seniority.

    You claim that term limits will result in a lower budget, even though there is no evidence to support this claim.

    You constantly claim that term limits will result in a more responsive legislature even though, under term limits, one third of the legislature will be totally unaccountable to the public! (Folks this last point is HUGE. Under any term limit proposal, some proportion of the legislature are lame ducks--a recipe for complete disregard of the voters' desires.)

    ===

    Don,

    I understand the desire for citizen legislators (although, as Kari points out, that is essentially what we have in Oregon), but with all due respect, citing the historical example of a small, coastal country with a few million in population, very poor communications and trasportation, and essentially no federal government (most work was done by the states) is really not a very good analogy to today's modern, complex, highly bureaucratized government.

    The American public, via the ballot box, realized that the ideal of citizen legislators was naive as early at the 1840s, when they started returning members of Congress multiple times. By the 1870s, this pattern was solidly entrenched.

    I simply don't understand the argument that a highly complex bureaucratic apparatus can be managed by an amateur when you'd never apply the same criteria to any other sector of society.

    Finally, I didn't argue that the legislature controls the bureaucracy. I said that the bureaucracy--the permanent government--would become more empowered relative to where they are now. So if you think the legislature is too weak now, you should be supporting just the opposite of term limits--you should be supporting a permanent, well-paid, professionalized legislature.

  • Katy (unverified)
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    <h2>We already have term limits; it's called voting.</h2>
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