The Association for Due Process and the Constitution's submission to the Boundaries Commission contains no surprises.

The lobby group continues to maintain that the constitution should not be changed without a constitutional conference.

And it repeats its argument that the Boundaries Commission should have minutes of its deliberations open to the public, as well as make available all relevant materials.

In its 115 page submission, it argues that the number of MPs should remain at 40 unless 'better reasoning' is provided to change it - in which case it should be an odd number.

The report also states that parishes should be preserved in redrawing the boundaries and constituencies size deviations of up to ten percent should be considered acceptable.

While supporting the abolition of the dual seat electoral system, the Association says that the Boundaries Commission should give an opinion on the matter in its report and should also recommend that the public be given an opportunity to formally consent to its recommendations.

And the Commission should mention in its final report other proposals for reforming the electoral system such as adopting proportional representation, says the Association.

The Association's submission argues that a first past the post system is a non-proportional system - meaning that it produces a disparity between the share of votes and share of seats in the House of Assembly and favours the winning party.

"If the size of Parliament is reduced then we can expect the electoral system to become less proportional and accordingly less equitable."

In a final section of the submission proper, the Association leaves open the possibility of going to the courts for a review of the process.

Among its grounds for such action are the claims that the Commission interpreted its remit too narrowly and gave inadequate information for the public to properly express its views.

The Association is also concerned that the Commission did not appear to take formal records of the public meetings.

"It is therefore difficult to see how the views of the public can conscientiously be taken into account by the Commission in accordance with the right of the public to a fair hearing."

The Commission should also make its report available to the public before forwarding it to the Governor, the Association says.

The submission contains nine pages of annexes, totalling 50 pages, including its correspondence with the Boundaries Commission, an analysis of electoral bias in Bermuda's elections since 1968, and results of polls commissioned by the Association.

It also contains seven different possible scenarios for allocating seats within Parishes, and their implications and a report on electoral reform in Guernsey.