The Overseas Experience with Political Management
in Local Government
Professor Robin Hambleton, Special Adviser to the
Committee and Director of the Centre for Local Democracy at the
University of the West of England, Bristol
This paper responds to a request from the Committee
for more information on the political management models found
in local government abroad. It does not offer a comprehensive
review, rather it aims to provide evidence to illuminate some
of the key issues the Committee has been examining in recent weeks.
Two points should be made at the outset. Firstly,
it is clear that comparing local government systems in different
countries can be extremely rewarding. It can stimulate fresh thinking
and offer valuable insights into the way particular models of
local political management work in practice. Secondly,
it is also the case that democratic traditions and legal systems
in different countries vary a great deal. It follows that it is
misguided to scan foreign local democracy in the hope of finding
easy answers to local political challenges. Successful cross-national
policy transfer requires an ability to interpret foreign
experience and adapt it to meet local political and managerial
2) The separation of powers
The Government has stated that the quality of local
democracy will be enhanced by the introduction of a separation
of powers between 'the executive and backbench roles of councillors'
(1). This terminology has created some confusion and continues
to bedevil debate. 'Backbench' is a Westminster term and, as explained
below, the meaning of 'executive' needs to be unpacked. However,
the separation of powers between a political executive and a political
assembly is extremely common in local government abroad. Supporters
of this model argue that it has three main benefits: 1) the executive
has the legitimacy to exercise bold outgoing political leadership,
2) it is clear where power lies, and 3) it enhances accountability
as those exercising power can be held to account. In her evidence
to the Committee the Minister said that she is persuaded by these
arguments. The indications are, then, that all local authorities
will be required to introduce a separation of powers as they draw
up a 'new constitution' for local governance in their area as
envisaged in the recent White Paper (2).
Overseas experience will be invaluable to local councils
as they embark on this task. In many countries the local authorities
are well used to developing and revising their constitutions within
frameworks provided by higher levels of government. For example,
in many states within the USA local authorities, either of their
own volition or as a result of citizen pressure, can be seen bringing
forward proposals for constitutional change. This is known as
charter revision and, in any given year, perhaps 1% or 2% of localities
might be expected to modify their constitutions. For example,
on 8 June 1999 the citizens of Los Angeles were invited to vote
on the separation of powers within their system of local governance
and decided, inter alia, to strengthen the power of the neighbourhoods,
to give more authority to the directly elected mayor, and to reduce
the power of the city council.
Two points about overseas experience with the separation
of powers should be emphasised. Firstly, there is enormous variation
within this model of governance. Recent research on foreign experience
with versions of the three models set out in the Government White
Paper has provided examples of situations where the political
executive has substantial formal authority (for example, the Mayor
of Baltimore, USA) and situations where the political executive
has virtually no formal authority but can, nevertheless, be very
effective by virtue of positional power (for example, the Mayor
of Christchurch, New Zealand) (3). There is, then, more scope
for diverse approaches within the three models than has been commonly
recognised. Secondly, local constitutions can be revised and developed
to suit changing circumstances. Clearly charter revision should
not be undertaken lightlyconstitutions ought to be fairly
lasting. But a strength of local government in many countries
is that citizens can and do initiate change to the governance
arrangements of their areas. This is bottom up governmental change
and differs fundamentally from the top down approach that has
been such a striking feature of local government reform in the
One area which the Committee may feel deserves further
examination concerns the definition of 'executive'. It is clearly
a myth to suggest that, in the modernised local government the
Government wants to encourage, the 'executive' will make all the
decisions in an area. This is impossiblethe executive could
not possibly cope with the work load. It is also highly undesirable
as it would involve an unhealthy over-concentration of power.
Work for the Society of Local Authority Chief Executives
(SOLACE) suggested that it might be helpful to invite local authorities
to make provision for three kinds of executive decision as they
draw up their new constitutions: 1) strategic executive decisions
(to be made by the central political executive), 2) local executive
decisions (which could be made by local councillors in area or
neighbourhood committees), and 3) operational executive decisions
(the many detailed decisions delegated to officers) (4).
A further theme that foreign experience can illuminate
relates to the processes of: 1) electing (or appointing) the political
executive, 2) holding them to account during their period of office,
and 3) removing them should they be failing disastrously. As implied
by the earlier discussion there is wide variation on all three
points. I now consider each in turn.
In many countries citizens directly elect the political
executive. Where this happens there is usually a single executive
known as the mayor. However, in some countries citizens directly
elect a cabinet to run the local authority. This approach, known
as the commission form in the USA, is uncommon but is used even
in some fairly big citiesfor example, Portland, Oregon.
An alternative to direct election is appointment of the executive
by the council. This is common practice on the continent and is
the approach being adopted now by innovative UK councils working
within existing legislation.
The arrangements for holding the political executive
to account are inextricably linked with the design of the separation
of powers within a local authority. Again there are choices. In
Oslo, Norway, members appointed to the cabinet resign their seat
on the council. At the other extreme the cabinet (or mayor) may
continue to also be 'normal' members of the council. Councils
should be encouraged to develop their own proposals.
It is very important to have in place arrangements
for removing a thoroughly incompetent political executive. However,
great care is needed. Once a political executive is elected or
appointed they need to be able to exercise leadership without
too much interference. It is argued that many existing political
leaders in UK local government often have to spend too much time
dealing with the internal politics of the town or county hall.
If the new arrangements do not grant leaders more space to lead
local democracy will not be enhanced.
We do, however, need to guard against the opposite
extreme. In some countries the local political executive has,
over a period of years, been able to build up an unchallengeable
position. In some cases this has led to corruption, more commonly
it results in incompetent leadership. Term limitation can form
part of the solution and is commonplace in local government abroad
that is the political executive can be required to vacate their
office after, say, two four-year terms (as with the President
of the USA). In addition the council needs to have a power of
recall during the term of office of a given political executive.
This could be along the lines of a vote of confidence by, say,
60% of the council. This kind of arrangement is often found in
local government charters abroad.
3) Six models of local political management
This section outlines six models of political management
found in local democracies around the world. There are other models
but the six summarised here provide a reasonable picture of the
options which are most relevant to current policy debates in the
UK. A fuller discussion of these models is found in a report prepared
for the Commission on Local Government and the Scottish Parliament
i) The typical UK local authority
The Local Government Association (LGA) in its evidence
to the Committee rightly pointed out that many local authorities
have modified the traditional committee system to meet changing
needs. There is, then, probably no such thing as a 'typical UK
local authority'. However, it is still the case that the majority
of UK local authorities continue to manage their decision making
through a number of separate committees usually related to local
authority functionssee Figure 1. Councillors, elected
on a ward basis, usually serve on several committees as well as
on the council as a whole. Most councillors belong to a political
party and many important policy decisions are made in party groups,
rather than in the committees. However, it should be noted that
not all councils are party political. It should also be noted
- many councils have developed area committees
so that local decisions are taken closer to the people most directly
- many councils have developed robust arrangements
for listening to the voices of people who are often excluded (for
example, disabled people, young people, ethnic minorities).
In the existing UK model there is no separation of
powers. To citizens at large it is often not at all clear who
is responsible for which decisions.
ii) The mayor-council structure (strong-mayor)
Figure 2 illustrates the
strong-mayor form of government in which the mayor has substantial
executive powers as compared to those of the council. The mayor
serves as the directly elected chief executive and is highly visible.
The mayor prepares the budget, controls the city administration
and has the power to appoint chief officers and to veto legislation
passed by the council. The council can be responsible for developing
policy, authorising the budget, reviewing the performance of the
mayor and can retain executive responsibility in specified areas.
The council can insist on regular reports from the mayor and can
have a system of committees to examine issues and scrutinise decisions.
Chief officers are clear that, if the mayor loses
an election, they could well lose their jobs. Some department
heads may, however, be covered by civil service employment conditions
or may, once appointed, not be removable by the mayor unless it
can be demonstrated that they are failing to perform their duties.
In any event, the lines of authority for all or most departments
of local government lead to the mayor's officehence the
bold line around the mayor.
The Government's proposals for a 'directly elected
mayor with a cabinet' can be viewed as a modification of this
model in two main ways. Firstly, the Government envisages the
mayor appointing a cabinet. In some countriesnotably Francethe
directly elected mayor will have several 'deputies' (6). However,
in many countries the mayor acts alone. Secondly, the Government
anticipates the mayor and the council appointing a chief executive.
Again this top officer role does exist in other countries but,
in the strong-mayor model, the most senior officer is often called
the Chief Administrative Officer (CAO). This officer, as the name
implies, is usually less powerful than a UK chief executive. Remember
in the strong-mayor model it is the mayor, not the officer, who
is the chief executive. It is clear, therefore, that the strong-mayor
model can be expected to alter the roles of the chief executive
and other chief officers. The Committee will wish to ensure that
there are adequate protections for the Head of Paid Service and,
possibly, the other statutory officer roles which now exist in
UK local government.
Because the Greater London Authority (GLA) is a strategic
authority the Government's proposals for London are distinctive.
Nevertheless, it is useful to note the separation of powers that
will be introduced in Greater London next year (7). The Government's
proposals indicate that the mayor will have five key roles:
- To devise strategies and actions
- To propose a budget
- To co-ordinate action to implement the agreed
- To act as a voice for London
- To make appointments
The assembly, which will have 25 members, is to have
- To assist in policy development
- To approve or amend the mayor's budget
- To examine London issues
- To examine the mayor's strategies and performance
- To participate in the appointments procedure
- To serve as members of the police and fire authorities
These proposals give the mayor substantial authority.
In constitutional terms the balance of power in the GLA can be
described as strong-mayor rather than strong-council.
iii) The mayor-council structure (strong-council)
Figure 3 illustrates the
strong-council form of government. The mayor is still directly
elected but power is dispersed between the mayor and the council
and, in some cases, other elected officials. The council is usually
the formal centre of power. In particular, it is normally the
council that appoints chief officers. There is, however, no sharp
line between the strong-mayor and strong-council optionsrather
there is a continuum. Generally speaking, the strong-council form
The government's proposals for a 'directly elected
mayor with a cabinet' could be built around a version of Figure
3, just as they could stem from a version of Figure 2.
As before the key differences are that the Government envisages
the mayor appointing a cabinet and that the mayor and council
will appoint a chief executive.
Much of the UK debate about elected mayors has tended
to assume that the mayor-council form is a 'big city' model of
government. Famous examples lend support to this viewsuch
as New York City and Chicago. But the assumption is quite wrong.
The mayor-council form of government is extremely popular in rural
areas and small towns.
iv) The council/manager structure (with a
In the council-manager form of government, as illustrated
in Figure 4, there is no separation of powers between a
political executive and a legislative body. The elected council
appoints a top manager who, in turn, is directly in charge of
departmental chief officers and supervises their performance.
This officer is often referred to as the 'city' manager but in
a county he or she would be the county manager and in some cases
the term used is council manager. In this paper I use the term
'top' manager to make it clear that it is a form of management
which can be used in both rural and urban areas. On the whole
top managers have rather more authority than a typical UK local
authority chief executive. For example, they may be able to appoint
all officers with little or no reference to the politicians. These
managers are, however, usually on five year contracts so if they
are not politically aware they will not last long.
In some ways the top manager resembles the managing
director of a private company. Indeed, analogies with business
organisations almost always provided the principal supporting
arguments for moving to the council-manager plan in the USA in
the early part of this century. Figure 4 suggests that,
in contrast to Figure 2, power is concentrated in the hands
of an officer: hence the bold line around the top manager. Whether
too much power is concentrated in the hands of one officer is
a matter of disputemuch depends on the details.
The council-manager form can, however, create a leadership
gap. Top managers, because they are not elected, cannot provide
political leadership. The original council-manager plan developed
in the USA at the turn of the century attempted to separate politics
from administration. Inevitably, however, top managers have been
required to act as visible leaders. But they do not have the legal
basis or political authority for performing such a role and this
factor has triggered improvements to the council-manager plan
in many American local authorities and elsewhere (see next model).
The Government does not envisage the council/manager
form of political management in the three models it has set out.
It does, however, see the possibility of introducing a strong
top manager into local government. At present, this role is linked
into a model which also incorporates a directly elected mayorit
is described as the 'directly elected mayor and council manager'
model. This model is discussed next. The Committee may, however,
feel that there is scope for recommending that councils should
be allowed to introduce a hybrid model combining a strong top
manager with a cabinet-plus-leader arrangement for members i.e.
an approach which combines features from two of the Government's
models. Given the commitment of the Government to a separation
of powers it can be assumed that the straightforward council-manager
modelas shown in Figure 4can be set aside
as it does not pass the separation of powers test.
v) The council-manager structure with a mayor
Many council-manager cities have modified their structures
along the lines shown in Figure 5. Here a directly elected
mayor is introduced to give a political lead to the work of the
top manager. This model has become increasingly popular in council-manager
cities in the USA. It is also the model of political management
introduced across New Zealand by the last Labour Government in
Council-manager mayors tend to act as facilitators
rather than executives. The possibilities of political leadership
for the facilitative mayor have been neglected in recent debates.
Kinds of leadership, beyond traditional ceremonial functions,
can be developed. One is a co-ordinating role in which the mayor
pulls together the different parts of the system of local governance
to improve their interaction.
A cross-national evaluation of political management
models carried out by the Carl Bertelsmann Foundation in 1993
gave joint first prize to two local authorities using the council-manager
structure with a mayorChristchurch, New Zealand and Phoenix,
USA (8). Whilst it would clearly be unwise to advocate any particular
model for UK local governmentsuch a stance would deny the
importance of local choicethe Committee may wish to suggest
that this is a model which deserves to be given more attention.
vi) The cabinet-council structure
In the cabinet/council structure there is a separation
of powers between a cabinet, which acts as the political executive,
and a council which develops and monitors policy and holds the
cabinet to accountsee Figure 6. The cabinet is usually
indirectly elected by the councillors and has the power to appoint
chief officershence the bold line round the cabinet. The
model, borrowed and adapted from central government, clearly identifies
the leading group of councillors responsible for running the authority.
Where there is a majority party the cabinet would, to some extent,
resemble a single party policy committee with a high degree of
executive power. The council delegates this executive power (which
could vary considerably) to the cabinet. Decisions taken by the
cabinet are decisions of the authority. As with the model in central
government individual members of the cabinet have delegated areas
of responsibility and the attendant decision taking powers, but
the broader strategy is decided by the cabinet.
The council can require regular reports from the
cabinet and can have a system of committees to examine issues
and scrutinise decisions. These committees have rights and might
have a political balance which favours minorities. As with the
mayor-council models described earlier the balance of power between
the executive (whether it is a mayor or a cabinet) and the council
can vary enormously. Just as it is possible to have strong-mayor
and strong-council forms in a mayor-council structure it is possible
to have strong-cabinet and strong-council forms within the cabinet-council
In 1986, the city of Oslo discarded a 'typical UK
local authority' form of governancesee Figure 1and
introduced a cabinet-council structure. The cabinet, elected by
majority vote of the council, comprises seven members. It is the
controlling body of the administration, it reports to the city
council and is responsible for implementing resolutions passed
by the city council. In effect, Oslo now has 'hands on' political
management in a form that resembles ministerial management of
An even more striking feature of the Oslo model is
the radical decentralisation of power to 25 neighbourhoods (with
populations ranging from 7,000 to 30,000). Close to 40% of the
massive £2000 million annual revenue budget of the city (the
local authority runs health as well as all the functions of a
UK unitary authority) is decided at neighbourhood level.
Key points for the Committee to note are:
- The cabinet is not just a souped up policy committee.
It is a new model of political management with major implications
for members and senior officers.
- The Oslo experience suggests that the model strengthens
'hands on' political control of the organisation.
- The Oslo experience shows that it is possible
to combine a separation of powers with radical decentralisation
going well beyond even the most ambitious decentralisation schemes
currently operating in the UK.
This review has provided evidence of practical experience
with different forms of political management in other countries.
Given the task of the Committee four important points should be
1) Unpacking the executive
The separation of powers between a political executive
and a political assembly is common in local government abroad.
However, it is quite wrong to suggest that the political 'executive'
takes all the decisions in these other countries. The Committee
may wish to suggest that the requirements of effective and accountable
local government can be advanced by giving more attention to the
delegation of decision making power. Foreign experience suggests
that it is possible to make provision for at least three kinds
of executive decision: 1) strategic executive decisions (to be
made by the central political executive), 2) local executive decisions
(which could be made by local councillors and others in area or
neighbourhood committees), and 3) operational executive decisions
(the many detailed decisions delegated to officers). The enhancement
of 'local executive' decision making could make a major contribution
to strengthening the role of all councillors.
2) Local decision making involving local people
Devolution of decision making to local areas is commonplace
in local government in other countries. These arrangements have
been very successful in lifting citizen involvement in local affairs.
In the period between the July 1998 White Paper and the March
1999 Draft Bill the Government seems to have weakened its support
for area-based decision making.
Foreign experience suggests that this is a retrograde
step and that the reverse is needed. Citizens are often more concerned
about very local issues and the Bill should provide scope for
councils to have the option of devolving far more decision making
power to the local level.
3) Hybrid models
Foreign experience suggests that there is scope for
great variation in forms of political management whilst retaining
a separation of powers. It is clear that very different approaches
can be developed within each of the three models outlined by the
Government. There is, however, a case for clarifying whether or
not hybrid approaches combining features from different models
would be acceptable. Foreign experience suggests that there should
be as much flexibility as possible.
4) Flexibility and change
The Government argues that communities should decide
how they want their community governed and sets out proposals
for binding referendums. This bottom up approach to constitutional
change takes place in other countries. It is a welcome feature
of the Draft Bill as it will enable local councils and their citizens
to learn from experience.
1) Department of the Environment, Transport and
Regions (1998) Modern local government. In touch with the people,
Cm 4014, July, para 3.12
2) Department of the Environment, Transport and
Regions (1999) Local leadership, local choice, Cm 4298,
March, paras 3.5 and 3.6
3) Hambleton R. (1999) Modernising local political
management. Briefing Paper from the Centre for Local Democracy,
University of the West of England, Bristol. February
4) Hambleton R. (1999) Modernisation: developing
managerial leadership. Society of Local Authority Chief Executives
(SOLACE), January, paras 3.1 to 3.7
5) Hambleton R. (1998) Local government political
management arrangementsan international perspective.
The Scottish Office Central Research Unit, The Stationery Office,
6) Borraz O. (1994) Mayoral leadership in France
in Borraz O. et al Local leadership and decision making.
Joseph Rowntree Foundation. LGC Communications
7) Department of the Environment, Transport and
Regions (1998) A mayor and assembly for London. Cm 3897,
8) Pröhl M. (1993) Democracy and efficiency
in local government. Bertelsmann Foundation Publishers. The
author's own first hand research on Christchurch and Phoenix in
more recent years confirms that, in many respects, these are,
indeed, very well run cities
Figure 1: A typical UK local authority
Figure 2: The major-council structure (stong-mayor)
Figure 3: The mayor-council structure (strong-council)
Figure 4: The council-manager structure
Figure 5: The council-manager structure with
Figure 6: The cabinet-council structure