A further letter asking for clarification following the Zac Goldsmith Case Review.
Dear Electoral Commission,
re. Case review concerning campaign expenditure return in respect of Zac Goldsmith MP
Further to my email yesterday there is another issue it would be useful to have guidance on.
Paragraph 3.16 of the review states:
"Mr Goldsmith‟s expenses return included an invoice for leaflets which cost £11,150.39. His return declared expenditure of £8,629.76, on the basis that not all of the leaflets had been used. The allegation suggested that in fact all material purchased should have been declared. However, the RPA2 defines election expenses as expenses incurred on materials used for the purposes of the candidate's election after the date when he becomes a candidate at the election. The guidance issued by the Commission states that candidates and agents must include the value of everything used in the regulated period, not what is purchased. We consider that Mr Goldsmith‟s reporting of the cost in relation to this item was consistent with the requirements of the RPA and the Commission‟s guidance in this area."
I was very surprised to raed this as the advice I have always been given is that you should declare the cost of everything you have bought for the purpose of the election, other than where you are sharing the cost with another campaign or going to use the material in the futre.
The problem with allowing campaigns to declare only part of a print run is that this allows them to benefit from economies of scale in printing costs and makes it very difficult to be certain what proportion of the run have actually been delivered.
For example if I want to produce a run of 10,000 leaflets it might cost me £500, whereas a run of 40,000 of the same leaflet might only cost £1000, due to the economies of scale involved in the printing process. If I get 40,000 printed and only use 10,000 (25% of the run) this ruling would allow me to declare only 25% of the bill, i.e. £250. In other words a campaign that has a lot of money to spend can artificially reduce the amount if has to declae on the election expenses.
Please can you therefore provide me with clear guidance on how this (new) rule works.
Is there any limit on how much a campaign can actually spend in order to reduce the aount it declares in the election expenses? (In either cash or percentage terms)
Is there any limit the number of different leaflets a campaign could claim to have not fully delivered?
How do you plan to be able to check what proportion of any given print run has been delivered?
Again, I would appreciate clear guidance on these points.