Summary: Comparative Public Administration

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• Lecture 1 & 2

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• Why would we focus on European systems?

  
  

  • Because the administrative and legal systems of most countries outside Europe were established by European colonial powers. 
    
    
  • When the colonies became independent, most of them retained the administrative and legal systems they had inherited. 
    
    
  • And most of them still have those elements of those systems up-to-today. 
    

• Which former colony is described here? Westminster political system (sovereignty of parliament) + common law + indirect rule (local power left to traditional elites) or self-government (in settler colonies). 

  Former British colony.

• Which former colony is described here? Centralization + strong executive (weak parliament) + civil law. 

  Former French colonies.

• How can we compare administrative systems?

  
  

  • Function of law: law serves to specify how policy should be implemented (Germany, France) vs. law should only offer general outlines of policy (UK, USA. 
    

  
  
  
  

  • Political systems: majority system (UK) vs. consensual systems (Benelux, Germanic countries, Scandinavia). 
    

  
  
  

  • Administrative culture: i.e. ideas about contact between public officials and citizens: based on formal rules (Germany), on cooperative contact (Sweden), or on bargaining (UK)?
    

  
  
  
  

  • Values: legality, equal treatment and neutrality (continental Europe) vs. flexible reconciliation of interests (UK, USA). 
    

• How to compare administrative systems? By means of the types of welfare state:

  
  

  1. Social democratic (universal benefits, large role for the state): Scandinavia. 
     
     
  2. Conservative: (room for status differences): Germany, Belgium, France, Italy. 
     
     
  3. Liberal: (less social security benefits, less redistribution of wealth): USA, UK,  Switzerland. 
     
     
  4. Rudimentary: (central role of family): Southern Europe. 
     
     
  5. Post-socialist: former communist countries of Central Europe. 

• There are in Europe 5 groups of countries to be distinguished by different models. Define those models:

  
  

  1. Napoleonic model. 
     
     
  2. Federal Germanic countries model. 
     
     
  3. Scandinavian model. 
     
     
  4. Anglo-Saxon model. 
     
     
  5. Central and Eastern Europe model. 

• Define the federal model of Germanic countries:

  
  

  • Germany, Austria, Switzerland. 
    
    
  • Characteristics:
    

  
  
  
  

  • Roman law. 
    
    
  • Strong position of sub-national governments (Swiss cantons, German Länder). 
    

• UK and most of its former colonies: USA, Ireland, Malta, Canada, Australia, New Zealand, India, Pakistan, Bangladesh, Myanmar, Malaysia, many African countries, Guyana, etc. etc. Define the Anglo-Saxon model: 

  
  

  • The state is not considered as a value in itself, but as just an instrument for society. 
    
    
  • No sharp distinction between private and public law. 
    
    
  • So easy transfer of ideas and concepts from private sector to public sector. 
    
    
  • Judge-made law rather than government-made law. 
    
    
  • Bureaucracy is controlled by parliament, not by administrative courts. 
    

• Define the model of eastern- and central Europe:

  
  

  • Communist model imposed after World War II by Stalin (ex- Soviet-Union). 
    
    
  • Found in all formerly or currently communist countries (former Soviet-Union, Central and Eastern Europe, China, Vietnam, Laos, Cambodia, Cuba, North Korea, Mongolia, Eritrea). 
    
    
  • Characteristics: 
    
    
  • State is subordinated to Communist party. 
    
    
  • No separation of powers. 
    
    
  • Local and regional governments are just agencies of the central government. 
    
    
  • After 1990, many countries in Central and Eastern Europe moved away from this model towards the Germanic one. 
    
    
  • But even there, the administrative heritage of communism is still heavily present. 
    

• Comparing local governments. There are three ways to do this. What are those three ways?

  1. Functional profile. > What can governments do? How much authority? 
     
     
  2. Territorial profile. > Big or small territory? 
     
     
  3. Political profile. > Is there local democracy? How is it organized? Who is holding power? The council (the local legislature) or the executive?  With which executive? Mayor? Vice-mayors? City manager?Are mayors appointed by central government? Or are they elected? Elected by whom? Directly elected by the citizens? Or elected by the council?