The final boundaries - The EBC's considerations and decisions

The EBC's considerations and decisions

  1. Sections 10B(1) and 11 of the Act require the EBC to consider all suggestions and objections lodged with the EBC in response to the proposed boundaries. The redivision is a consultative process, and the EBC values the information and perspectives provided in feedback from the public. The paragraphs below focus on the suggestions and objections which disagreed with the proposed boundaries, and explain the EBC’s considerations of the issues raised. The report first discusses three general matters, and then deals with particular areas.

Enrolment projections

  1. The small-area population analysis and forecasting company, .id (informed decisions), lodged a submission querying the enrolment projections used by the EBC, and providing alternative projections. The EBC appreciates .id’s expertise, and took the company’s projections into account, but has relied primarily on the projections provided by DPCD for the sake of consistency.

Interpretation of legislation

  1. The Nationals argued that the EBC had erred in its interpretation of the Act in forming the view that the numbers criterion is the only fixed one in the Act, and that all other factors in the Act are subordinate to this one.

    “The Nationals vigorously contend that the phrase ‘Subject to and in accordance with the provisions of this Act’ at the commencement of section 5 very much qualifies the primacy of the ‘numbers’ criterion set out in that section and make it abundantly clear that Parliament intended the factors specified in section 9 to be very significant indeed. It is apparent that the Commission’s undue emphasis on the ‘numbers criterion’ has subjugated the other factors the Commission is required to duly consider, resulting in a number of proposed electoral borders that do not appropriately unite communities of interest or facilitate fair electoral representation due to factors of geography and distance.” 27

  2. The Electoral Boundaries Commission considers that the words “Subject to and in accordance with the provisions of this Act” do not alter in any way the clear intention of the Act. Section 5(1) provides that the function of the Commission is to divide Victoria into electoral regions and districts with the object of establishing and maintaining electoral regions and districts of approximately equal enrolment and to determine their boundaries. Section 9(2) provides that for the purposes of the Act the Commission may take electoral regions or districts to be of approximately equal enrolment where the enrolment for each electorate does not vary by more than 10 per cent from the State average – that is, enrolments may vary by up to 10 per cent from the average and still comply with the requirement for approximate equality. Section 9(1) provides that the Commissioners shall give due consideration to area and physical feature of terrain; means of travel, traffic arteries, and communications and any special difficulties in connection therewith; community or diversity of interests; and the likelihood of changes in the number of electors in the various localities. The factors in section 9(1) are very important, and there is scope for legitimate differences of opinion on how those factors should be applied in particular cases, but the EBC remains firmly of the view that the factors must be considered within the context of the primacy of the numbers criterion, which requires enrolments for all electorates to be within 10 per cent of the State average.

Representation of rural and regional Victorians

  1. The Nationals criticised the proposed boundaries for under-representing rural and regional Victorians and over-representing metropolitan electors. The Nationals pointed to the large cluster of districts on the eastern side of Melbourne whose enrolments are projected to be below average by 2018, contrasting them with rural districts that are expected to be above average. According to the party’s submission:

    The Commission’s proposal will deliver 56% of districts in metropolitan Melbourne that are under-average enrolment compared to 39% in regional Victoria. And when projected population is taken into account the percentage of districts under average enrolment in Melbourne actually increases to 60% versus 48% of regional seats. On projected figures 21% of rural and regional seats will be more than five per cent above quota in 2018 versus 13% in metropolitan Melbourne28.

    The Nationals contended that this balance is counterintuitive, that the greater proportion of districts below average enrolment should be in regional Victoria to offset the size of the electorates and the associated challenges in representing their electors.
  2. The Act does not distinguish rural and metropolitan electorates. The EBC believes that the intention of the Act is that all electors should be treated on an equal basis, that that there should be no systematic imbalance favouring either regional or metropolitan electorates. The Nationals’ argument that the proposed boundaries do create such an imbalance needs to be considered carefully.
  3. In statements about rural and regional representation, the extent of rural and regional Victoria tends to shift according to the point being made. To regard the three non-metropolitan Upper House regions as synonymous with rural Victoria is unsatisfactory, because these regions include peri-urban districts that are often considered to have more in common with Melbourne than with country Victoria. For the purpose of analysis, the EBC proposes that there are 25 core rural and regional districts, with eight peri-urban districts (Melton, Yan Yean, Evelyn, Monbulk, Gembrook, Hastings, Mornington and Nepean) grouped with the metropolitan ones. On this basis, metropolitan and regional enrolments vary as follows:

Variable (Districts)







Number below average

34 (53%)

37 (59%)

9 (36%)

12 (48%)

Number > 5% above average

9 (14%)

13 (21%)

6 (24%)

3 (12%)

Median deviation from average





  1. On current enrolments, there are fewer rural and regional districts below average than their metropolitan counterparts, and, in percentage terms, more districts that are well above average. However, by 2018 there are projected to be very few regional districts that are more than 5 per cent above average, and the number below average will have increased. The median deviation of rural and regional districts will be very close to the average. The statistics indicate that there has been no systematic under-representation of rural and regional Victorians. Instead, enrolments for some districts have been set at above average to allow for projected relative population decline, which will have taken effect by 2018.
  2. The number of metropolitan districts more than 5 per cent above average is projected to increase by 2018, reflecting rapid population growth in outer suburban areas. However, the number of districts with below average enrolments is large and projected to rise, and their median deviation from the average is expected to reach -2.95 per cent. These figures are a consequence of the relatively sluggish growth of the middle suburbs on the eastern side of the metropolitan area. Although the EBC has abolished one district in this area (Doncaster) and adjusted boundaries to allow for rapid growth on the outer fringe and inner Melbourne, this still leaves a large area of districts with below-average projected enrolment.
  3. A possible reaction to this situation would be to abolish another metropolitan district. However, the EBC considers that this would be an over-reaction to a limited problem. First, it should be noted that the problem exists only in one part of the metropolitan area; there is no sign of districts in the northern and western and inner suburbs being generally smaller than average. Secondly, a large number of districts in the eastern and south-eastern suburbs are below average to a comparatively small degree, while a smaller number of outer suburban districts are expected to grow well beyond the average. This pattern means that the median score possibly overstates the degree of metropolitan districts’ deviation below the average. More importantly, it would be difficult to abolish another district; the average size of districts in the three eastern side metropolitan regions (Eastern, South-Eastern and Southern) would increase from 41,436 (just below the State average) to 42,421, and these electors would then arguably be under-represented. The abolition would have major consequential effects across the metropolitan area and into regional Victoria. None of the proposed districts on the eastern side of Melbourne is projected to deviate more than 10 per cent below the average. In light of the facts that country electorates are not disadvantaged, and that the issue of below-average metropolitan districts is geographically limited, the EBC considers that the abolition of an additional metropolitan electorate would create more problems than it would solve.

Back to index


The Nationals – Victoria, Submission, pp. 2-3.



The Nationals – Victoria, Submission, p. 4.

Please rate this page from 1 to 5 where 1 is unhelpful and 5 is very helpful