in North America and Australia as "pork barrelling"), while ignoring safe seats which will reliably fall to the same party every time; this is especially true in cases where the safe seat is held by the minority party. In countries that do not apply the first past the post system, many of which equally operate a geographic division-based system, selected or party sub-nominated candidates can be allocated a safer or more tenuous list position. If a party is strong enough nationwide to gather representations in all subdivisions, the top candidate(s) on each list tend to be very safely elected to parliament. This is seen in the extremely proportional election systems of the Nordic countries, for example. Safe seats and candidates can be avoided altogether by a purposefully marginal-preference allocation of all divisions, ensuring all divisions are near-identically demographically diverse which may be achieved by pairing non-adjoining areas. Australia The Australian Electoral Commission defines seat margins as follows: In his election analysis, psephologist Antony Green puts the cutoff between "safe" and "very safe" at 12%. In Australia's federal system, most rural seats are safe seats for either the National Party or Liberal Party. Conversely, inner-city and poorer suburban seats are typically safe Australian Labor Party seats, and a few of the most affluent inner-middle urban seats are held by the Liberal Party. Marginals are generally concentrated in the middle-class outer-suburban areas of Australia's larger state capitals, which therefore decide most Australian federal elections. At the 2007 federal election, the governing Australian Labor Party's safest seat was the seat of Division of Batman in Melbourne's inner-northern suburbs, with a two-party-preferred margin of 26.0%. The safest seat for the opposition Liberal Party was the rural Victorian electorate of Murray, with a margin of 18.3%. The Liberal Party's junior coalition partner, the National Party's safest seat was the division of Mallee, also located in rural Victoria, with a margin of 21.3%. Canada Examples include: Beauséjour, a riding in southeastern New Brunswick, which is considered a safe seat for the Liberal Party. In 1990, when Jean Chrétien needed an open seat to become Leader of the Opposition, he chose Beauséjour in a by-election and won. Bow River, located in southern Alberta, is considered a safe seat for the Conservatives. In the 2015 federal election, the Conservative candidate won by 77% of the vote. Central Nova, located in east-central Nova Scotia, which has previously been called