Questions of Transparency and Comprehensiveness in a Policy Process
As a professor who teaches and researches transport policy, my duty is to open an urgent question of the policy process behind the potential changes in the organizational structure for rail-based urban transport in the Capital Region of Finland (CRF).
The policy process for organizational change of HKL from currently a municipal enterprise and part of the City of Helsinki into something else, falls short in two critical aspects for any policy process:
- The ongoing policy process does not have an adequate level of transparency for such an important decision and,
- The ongoing policy process does not show an adequate level of comprehensiveness for such an important decision.
Why is this decision very important?
Let us first understand the importance of this decision for the long-term future. To begin, we have to recognize that CRF has one of the best public transport service levels in the world, which is a result of wise decisions made over several past decades. This service level is based on a high coverage and high frequency public transport network that relies on a resilient combination of metro, heavy rail, tram, and bus lines – and is always in the process of adaptation to change [Ref 1.].
With this logic of adapting to the changing environment in the future, there are solid plans for CRF to continue investing in rail-based public transport infrastructure, resulting in public transport lines that cross municipal boundaries. Such developments, following the everyday moving patterns of people, aim to continue with the high level of service as the population grows in the region and for achieving climate targets. With this in mind, the decision to change the organizational form of HKL now will have repercussions for decades to come, for over a million people living in the region, and will affect how millions of euros are spent.
Put in a perspective of several decades, we see that a question of infrastructure management is related to the question of its operation and financing, which is also related to the question of organizing large numbers of people across city boundaries. So, given the fact that rail-based infrastructure is supposed to cross municipal boundaries, the central question seems to be – how to organize planning, operations and finances of rail-based public transport on a regional level (not including commuter rail)? At the surface, this might seem a simple bureaucratic question. However, once we start to think a bit longer, we understand that the question has in fact quite a heavy weight and the answer should come out from a high quality policy process – with transparency and comprehensiveness.
Challenge of process transparency
Having in mind the significance of such a regional decision, there is a surprising dearth of publicly available information on the policy process so far. An example of available material is [Ref 2.] which provides a quite narrow analysis. Otherwise, there are no publicly available details on how this process has gone over several years and what kinds of steps have been taken to ensure its legitimacy. Hand in hand, an open public debate is largely missing from the media, besides from a couple of news articles and comments [Ref 3., Ref 4.], while the evidence of any open forum debates is missing. Moreover, even the HKL employees themselves claim that they are not fully on board with what has been going on in the process. However, out of this process with limited transparency, the decision on the change of organization has to be made now! HKL board of trustees [Ref] and Helsinki City Council [Ref] are expected to make a decision by the end of 2021 so that the new company could start already in 2022. Now imagine any other similar European city, such as Munich, Stockholm, or Vienna making such a significant decision with this low level of public transparency? Even if one would try to defend this lacking transparency due to reasons of not providing competitive advantage, such an argument would not be sufficient to correspond with the necessary legitimacy of this significant decision.
Challenge of process comprehensiveness
Besides lacking transparency, from the publicly available information, it seems that the main proposed alternative to the current HKL existence is its transformation into a Limited Company (i.e., Ltd, LLC, GmbH, Oy, Ab). There is also another alternative mentioned, which is that every municipality should have their own company. This second alternative is largely dismissed, under the (probably justified) reasoning that it will lead to inefficient sub-optimization in regional public transport operations. No other alternatives are mentioned, while the main alternative also lacks elaboration. Recognizing that there could be ideas for other alternatives, perhaps by introducing new legislation, is not mentioned in the publicly available information.
On top of the lack of elaboration on alternatives, the list of criteria and their relations does not seem to be comprehensive. From what is available publicly, we can infer that the most important criteria seems to be revolving around the assumed complexity of financial accounting and legal agreements. The assumption is that the main alternative, enabling for example City of Vantaa or City of Espoo to buy shares in the new company, would thus reduce complexity and increase coordination in processes of organizing financing for procuring new rolling stock and other equipment. Despite the aspiration that municipalities should be collaborating, descriptions of the process complexity issues or cooperation problems between municipalities within the current model are not sufficiently elaborated. Moreover, the expected reduction in process complexity is supposed to bring about a faster pace of administrative processes, increase in process transparency, reduction of errors in projects, and improve employer image. Although these are great aspects to consider, the assumptions presented do not seem to have a thorough backing up for claiming these kinds of cause-effect relations.
Besides the first criteria above, other criteria seem to be rather superficially evaluated for the proposed main alternative. In line with the original thinking behind this policy process, we certainly live in an uncertain world. This means that there are many aspects that have not been taken into account explicitly or thoroughly enough. They start from the questions of equity effects on public transport users, such as accessibility for those dependent on public transport for their everyday mobility. They continue to the relations with other targets in city strategy, such as responding to climate change, but also relate to emerging technologies and services (e.g., automation) and changing nature of work. Even more, tram drivers, as experts that have a lot of knowledge of customer relations and realities of service implementation, are dismissed aside, thus not adequately accounting for impacts on customer relations or employer image. Finally, if you are looking for a list of clear objectives ranked in the order of importance – which is a basis for high quality policy-making – you will not find them.
The need for actions
Following the state-of-the-art in transport policy, there are many objectives which need to be clarified and ranked, together with elaborating existing and potential alternatives and criteria used for their evaluation. Pursuit of adaptability in the changing operating environment is certainly an important objective just as is creating an integrated service delivery for the benefit of users, the environment, and cities involved. So, we have an important decision ahead, but it does not seem that we have dedicated it the attention it deserves. Many more questions start to pop up…
Do we have a case where a decision has been made based on quick analysis by a limited number of actors and the rest of the process has been arranged to support that pre-made decision? Do we have a case where there are expectations that decision-making should not be complicated in a complicated institutional setting and where the concept of policy packaging for acceptance and effectiveness is not put in practice? Do we have a case of missing adequate previous experience with such processes and a lack of (national-level) evaluation of existing limited liability companies in the sector (e.g., Länsimetro Oy)? Do we have a case of adverse consequences from turf wars among politicians in CFR municipalities and a failure of deliberation-based politics in Finland? Or have we forgotten to think outside of the infrastructure box, and to imagine alternative ways of adaptive governance in transport policy?
Fortunately, I alone cannot answer these questions. However, my duty is to ask them. And my duty is to point to the fact that this kind of decision deserves a more serious analysis on how to deal with an uncertain future. Such an analysis is certainly not going to be easy and would need to involve a higher degree of systems thinking.
At this moment, my duty is to call upon all the responsible and should-be responsible actors in the Finnish transport policy to:
- Pause the policy process and do not make a decision for reorganization at this point in time.
- Immediately initiate an evaluation of the policy process so far which should transparently present what kind of analysis has been completed.
- Establish a transparent process with public involvement starting after the end of point 2 above, but aim to more comprehensively assess the alternatives and criteria for change in the organization of regional public transport.
What I can promise from my side, is that I could contribute to this policy process with my own knowledge, pro bono, as well as invite other colleagues to contribute, all while providing a space for deliberation at Aalto University.
In the end, we have to remember that high quality policy processes are a cornerstone of modern democracy. Democratic institutions do not simply exist but they are re-created with every new process – which is why we need transparency and comprehensiveness. Ultimately, even if after the improved policy process we arrive at the same suggested alternative as the current one, this additional time invested in improving decision-making will help maintain trust in public institutions, increase policy acceptance, and ensure policy effectiveness – for the sake of all our future.
Miloš N. Mladenović
Spatial Planning and Transportation Engineering, Aalto University
References to Extra background info:
Ref 1. Helsinki City Transport (HKL) is an organization that is currently responsible for running the trams and the metro as well as construction and maintenance of track, stations and depots
Ref 2. Helsinki Region Transport (HSL) manages planning of operations, contracting and passenger relations.
Ref 3. CRF is a constellation of independent municipalities. The largest three are the City of Helsinki, the City of Espoo, and the City of Vantaa.
Ref 4. Länsimetro Oy, i.e., West Metro Ltd., is a limited liability company that is jointly owned by the cities of Espoo and Helsinki.