The Managerial System
The managerial system, which was invented in the U.S., has also been adopted (with local modifications) in countries such as Australia, the Netherlands, New Zealand, Honduras, Chile, and Brazil. A short description of its application in the U.S. is set out below.

The U.S.
As noted above, the Irish managerial system was initially inspired by the managerial system then being introduced in a number of U.S. cities. This “council-manager” system as it is known has gained in popularity and is now used in the majority of cities with populations over 12,000. Other U.S. cities have retained councils/mayors with executive authority (to differing degrees), while the town meeting system is still used in some smaller towns in New England.

While the operation of the council-manager system will vary from city to city (each city will have its own charter, perhaps based on a menu of options laid down by state law – see an example from Massachusetts below ) the system basically provides that the elected council is responsible for making policy, passing ordinances, voting appropriations, and having overall supervisory authority for city government. The city manager has executive responsibility for the implementation of policy and for the hiring and management of staff.

Commonwealth of Massachusetts

General Laws – City Charters

Two Examples of the Manager/Mayor/Council Division of Powers in the U.S.

Councils with A Directly Elected Non-Executive Mayor

New Zealand
Alongside the election of the council, each local council area directly elects a mayor who is chair of the council. The mayor is not given any particular executive functions but has a moral authority by virtue of popular election. Each local authority is obliged to employ a chief executive officer with responsibility for implementing the local authority’s policy agenda. Councils are elected every 3 years.

New Zealand law specifies that there should be a clear split between policy aspects of local government and the operationalisation of such policies. Within this set up the CEO reports to the council while all other staff report to the CEO. The council is described as acting as a Board of Directors acting on behalf of the community.

It should be noted that the lower tier local authorities in New Zealand have a similar range of functions as Irish local authorities, although it is also noteworthy that around 90% of New Zealand’s local authority expenditure is raised locally.

Indirect Election of Executive Mayor
Local authorities in Spain and France are governed by councils who in turn elect executive mayors for the lifetime of the council.

Spain
Spanish legislation provides for an executive mayor to be elected from among the elected councillors of the local authority. In turn, the mayor can, if he or she wishes, create governing teams, cabinet-type bodies that assist the mayor in executive and organisational functions.

In turn, Spanish law allows councils to grant professional city managers the functions of organising and managing their administrative services, who operate in a similar manner to a CEO in an English local authority. The actual powers given to a manager can vary depending on the size of the local authority area, with the manager’s role increasing in complexity with the size of the city.

France
French mayors often have a very high profile and this can sometimes give the erroneous impression that they are directly elected while in reality they are appointed by the elected council. In France, there are three main tiers of local administration: the commune, department and region.

80 per cent of communes have fewer than 1,000 residents. Each commune has a deliberative or decision-making body (the municipal council) and an executive (the mayor). The number of municipal councillors is proportional to the population. Municipal councillors lay down guidelines for municipal policy, adopt the budget, manage municipal assets, notably primary school buildings and equipment, and decide how the municipal administration is to operate.

The mayor is both the commune's elected authority and the state's representative in it. Mayoral acts are unilateral administrative acts, generally orders, whose legality is subject to control by the courts, when they are issued by the mayor as the commune's chief executive, and to the approval of the Departmental Prefect to whom the mayor is subordinate when acting in the capacity as the state's representative.

Direct Election of Executive Mayors

Italy
In Italy, the mayor, who has executive functions, is directly elected by the people living within the commune, as is a council of between 15- 80 members. The term of office for a mayor is five years, and they cannot normally serve for more than two consecutive terms.

Larger towns (with populations over 10,000) employ Segretari Generali with professional administrative functions. Laws enacted in 1990 introduced the concept of managerial responsibility. These laws established a series of managerial functions that had to be performed by the SGs as long as the laws or municipal statutes of each town hall had not reserved these functions for the councils themselves. These tasks include managing services, supervising the work of department heads, coordinating their activities in accordance with the mayor’s directives, and implementing the decisions taken by the political bodies.

Germany
Germany is a federal parliamentary democracy, made up of 16 states or Länder. There are around 14,000 municipalities in the 16 Länder. Following reforms in the 1990s all Länder have enacted legislation which provides for the direct election of executive mayors. In the middle-sized and larger cities these are full-time salaried positions while in small municipalities they operate on a part-time, non-salaried formula.

The direct election of the mayor was meant to further extend the rights of citizens in local decision-making. It also aimed at strengthening the political and administrative leadership in local policy making and administration as, particularly in the case of the “strong” mayor, he/she is not only chairperson of the elected council, but also holds the chief executive function in directing local administration.

Above the local tier and beneath the Länder, a tier of 300 units of local administration known as Kreise (districts) also exists. A district council oversees these with a mandate varying between one and four years.

Cabinet or Collective Government
Some countries operate collective, or cabinet-like local governance, with executive power invested in a small executive elected from among the local council.

The Netherlands
In the Netherlands, the mayor (burgemeester) is de facto appointed by the national cabinet, de jure by the monarch. She/he is the leader of the municipal executive, which in turn is selected from the municipal council. The municipal council is directly elected. In effect, executive power is exercised by the executive rather than the mayor, who is its formal head.

The municipal council supervises the executive. In keeping with the way he or she is elected, the mayor mainly exercises a supervisory role over the proper preparation, adoption and implementation of city policies. For example, he or she must publish an annual report on the quality of services, which is then passed to the city council and made public.

The city manager’s main job is to assist the executive committee, the mayor, and the committees created by both. The executive committee specifies the functions that the manager must perform. The importance of this figure varies according to municipality. In the majority of cases, the position is quite strong; he or she heads the entire administrative organisation and takes decisions on his or her own initiative. In other cases, however, the manager merely provides technical assistance.

Sweden
In Sweden, the mayor is directly appointed by the central government. A legislative municipal council of between 31 and 101 members is elected from a party list system of proportional representation at municipal elections. The council in turn appoints a municipal executive board from its members. The executive board is headed by its chairperson.

This executive board holds executive power, performing the functions of strategic management and coordination. The president of the executive board is the political leader of the local council in Sweden, and often leads the largest political party on the council. In addition to the executive the council may also create permanent committees with executive competence over operational matters.

Legally, in Sweden the CEO is not a powerful figure. The position is optional, and if it is created, local politicians define the role which the CEO is to perform. Despite this, CEOs tend to have important responsibilities and take on administrative coordination. The 1992 reform of local government specified that the CEO may only perform administrative functions and must execute political decisions without questioning them.

Finland
In Finland there are no mayors as such. The form of local government is similar to that in Sweden with an elected council and an executive committee.

The highest executive official (manager) is appointed to public office by the city council. The manager is given the responsibility of executing the decisions of the council. All functions are performed under the direction, supervision and monitoring of the executive committee, that is, the city board of directors. The city board of directors are responsible for the administrative and financial management of local governments, for preparing the matters that must be dealt with in the council, and for implementing the council’s decisions.

The city manager supervises the administrative and financial management of the local
governments and is only subordinate to the board of directors.

England and Wales
Prior to the reforms under the Local Government Act 2000, executive and policy making responsibility in English local authorities rested with the elected council. Much of the executive decision making was undertaken by committees of the council. In turn, decisions were implemented by council officials working under a chief executive. While a chief executive did not have the powers of a county manager in Ireland, it was, and is, still the case that councillors and committees depended on the chief executive for advice and guidance. In practice therefore, the chief executive had to establish a close working relationship with the council leader/mayor and committee chairpersons. The mayor/leader in the English local government model was elected annually, and similar to Ireland, the lack of continuity in office was seen to give rise to a lack of public recognition.

Local Government Act 2000
In an effort to bolster local democratic leadership and the visibility of local leaders, the U.K. Government reformed the system of English and Welsh local authority governance to provide for a political executive which was to be separate from the majority of council members. The Local Government Act 2000 provided for 3 possible models of executive:

Of the 3 models proposed, most of England’s 400+ councils adopted the second option – that of a leader and cabinet executive. 12 councils opted for a directly elected mayor, while only one council opted for the mayor and manager option. In total, referendums to seek the provision of a directly elected mayor were held in approximately 35 local authorities. Local populations have therefore voted 2 to 1 against elected mayors.

The effect of the changes in most councils, therefore, was to place power in a cabinet type structure. The upside was that it delivered key leaders, but it has been criticised as marginalising the powers of “backbench” councillors.

The October 2006 Local Government White Paper, entitled Strong and Prosperous Communities, reviewed this issue again. It stated that local authorities in England and Wales adopted “a cautious approach to change”, and it went on to criticise the fact that most leaders face election every year: “This can make it hard to take and see through essential but difficult decisions that may in the short term be unpopular. It also brings uncertainty for senior management teams in pursuing and implementing longer term strategies. The Government believes that it is important that councils move towards having more stable and more visible political leadership.”

Therefore, the U.K. Government has now decided to legislate for 3 models of executive arrangement as follows:

All executive power is to be vested in the mayor/leader but power may be delegated to members of the local authority cabinet. These changes are now being legislated for.

Local Government Reform in Northern Ireland
Currently in Northern Ireland the 26 district councils have a very limited range of services (these include waste management, building control, recreation services etc). Power rests with the elected members and councils are administered by Chief Executive Officers. Under Direct Rule, the Review of Public Administration Report Better Government for Northern Ireland (March 2006) contained decisions for reforming the administrative structures in Northern Ireland, including reducing the numbers of councils from 26 to 7 while giving those councils additional powers in areas such as planning, roads, urban renewal etc.

The decisions of the 2006 report were reviewed by the new devolved administration. On 13 March 2008 the key decisions on the future shape of local government were announced. The 26 local government districts are to be rationalised to create 11 districts, and a range of functions will be transferred to the new councils, including aspects of planning, rural development, certain roads functions etc.