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Public-private partnership in relevance
Western and non-Western
countries: a search for relevance
Fadhli Zul Fauzi and Bevaola Kusumasari 87
Department of Public Policy and Management, Universitas Gadjah Mada,
Yogyakarta, Indonesia Received 30 August 2019
Revised 17 March 2020
13 April 2020
Accepted 12 August 2020

Abstract
Purpose – This paper aims to compare the implementation of public–private partnership (PPP) in Western
and non-Western countries by analyzing several predetermined aspects such as government and political
system, PPP’s model of agreement, political commitment and the role of PPP supporting unit.
Design/methodology/approach – This study uses comparative case studies to compare the
implementation of PPP in seven Western and non-Western countries by using various appropriate data such
as frequently used agreements, government systems, political commitments and PPP-supporting units to
understand the extent of differences in the success of PPP implementation found in each country.
Findings – The results reveal that the implementation of PPPs in Western and non-Western countries do
not significantly differ, except for in the instance of political commitments. Political interventions in PPP
implementation still frequently occurred in non-Western countries, which consequently disrupted the
implementation of PPP itself.
Originality/value – Previous comparison of PPP studies only focused on the implementation of PPP without
analyzing the political context in each country. One of the contributions that this paper will bring to the
conversations around PPP is that the implementation of PPP will be analyzed with regard to political contexts.
Keywords Western, Public–private partnerships, Non-Western, Political commitment
Paper type Research paper

Introduction
The debate on the success and failure of implementing public–private partnership (PPP)
continues to develop along with the political and economic differences found in every
country, specifically concerning development planning (Leiringer, 2006). The results of
many studies discuss the concept of value for money (VFM) offered by the PPP model to the
public sector, as well as risk analyses in its implementation, such as payment delay,
government priority changes and even shift of development authority (Siemiatycki and
Farooqi, 2012; Romboutsos and Macario, 2013; Lawther and Martin, 2014). Meanwhile, other
studies attempt to analyze the critical failure factors (CFFs) of PPP by presenting cases that
occurred in various countries. Gauging these CFFs may be observed via both micro and
macro conditions within the development. Micro conditions refer to failure factors that
ensued on account of the project implementation itself, whereas macro conditions are those
caused by external factors (Trangkanot and Charoenngam, 2014).
Micro conditions look at failures from various factors such as incompetent contractors or
Journal of Financial Management
weak monitoring in a certain project. For macro conditions, failures occur because of factors of Property and Construction
such as the presence of political risks and economic crisis taking place in a country Vol. 26 No. 1, 2021
pp. 87-102
(Trangkanot and Charoenngam, 2014). However, the failures found in the analysis results of © Emerald Publishing Limited
1366-4387
the CFFs do not actually happen in countries with differing backgrounds. Other studies DOI 10.1108/JFMPC-08-2019-0071
JFMPC indicated the opposite results by elaborating success factors in the implementation of PPP
26,1 through analyses of critical success factors (CSFs). Several countries have succeeded in
implementing PPP because they were able to meet the criteria demanded by CSFs, namely,
the availability of competent contractors, support and assurance from the government, good
monitoring, clear documents and trust fostered between the collaborating parties (Jacobson
and Choi, 2008; Wibowo and Alfen, 2015; Kavishe and Chileshe, 2018). The differing issues
88 confronted by PPP in various countries would undoubtedly result in differing output.
Initially, PPP had become a strategy championed by numerous Western countries, such
as the United States and Western European countries, for implementing complex urban
development plans (Sagalyn, 2008). Along with the growing understanding of PPP, the
scheme has eventually started to be implemented in various non-Western countries, even
developing ones (Melville, 2017). Various Western countries are the most active in applying
the PPP scheme, and they have contributed numerous innovations in its implementation
(Himmel and Siemiatycki, 2017; Maniatis and Vassilakou, 2017). This is also corroborated
by the substantial amount of cumulative expenses made in implementing PPP (in the
transportation sector) that is dominated by Western countries (Carpintero, 2015).
Meanwhile, regarding non-Western countries, although there have been a number of
successful cases in PPP implementation (Tafesse, 2014; Kwofie et al., 2014), there are, in fact,
also quite a number of cases that experienced problems and failures (Kokkaew et al., 2013;
Trangkanot and Charoenngam, 2014; Ameyaw and Chan, 2015).
Some studies eventually begin to develop their research by comparing the
implementation of PPPs in various countries, and comparing the level of success or failure in
implementing PPP (comparative studies) in the respective countries (Boardman et al., 2015;
Dong et al., 2016; Hurk et al., 2016). One comparative study had even compared not only the
implementation of PPPs in various countries but it also analyzed how those countries
resolved conflicts in a particular PPP case (Osei-Kyei et al., 2018).
Nevertheless, it is observed that there are gaps in some of the existing research on PPP. As
described earlier, the success of implementing PPP is dependent on the political contexts of the
country (Leiringer, 2006). Meanwhile, according to some of the available studies, not much
comparison has been done regarding the implementation of PPPs in various countries by
examining those countries’ contexts in their entirety. This research aims to compare the
implementation of PPPs in various Western and non-Western countries by examining the
contexts of those countries in their entirety. The comparison of these PPP implementations takes
several aspects into consideration, such as geographical conditions, economic background,
system of government, regulatory system, the scheme used and project monitoring mechanism.
This paper is aimed to compare the implementation of PPP in Western and non-Western
countries by analyzing several predetermined aspects such as government and political
system, PPP’s model of agreement, political commitment and the role of PPP supporting
unit. The choice of comparing between Western and non-Western countries is because of
several prior studies indicating a high level of success in the implementation of PPPs in
Western countries (Carpintero, 2015; Himmel and Siemiatycki, 2017; Maniatis and
Vassilakou, 2017), as well as several problems and failures confronted by non-Western
countries (Kokkaew et al., 2013; Trangkanot and Charoenngam, 2014; Ameyaw and Chan,
2015). This article is divided into four sections. The first section provides a description of the
existing literature on the PPP model. The following section discusses the methodology used
in the study to analyze the data findings. The next part contains a discussion concerning the
data findings and their analyses. In the last section, a summary of the existing analysis
results and recommendations for future studies are provided.
Conceptual framework in public–private partnership Search for
Governments are not necessarily able to fulfil the constant rise of public needs because of relevance
the limitations these governments have. Consequently, the PPP scheme is considered a
viable alternative to address their needs by using the partnership model between public and
private entities (Broadbent and Laughlin, 2003; Jacobson and Choi, 2008; Rebeiz, 2012;
Elwell, 2012; Rashed et al., 2017). As the needs for PPP continue to grow, some theories on
factors that influence differences in the implementation of PPP in various countries have
also increasingly developed (Jooste and Scott, 2011; Boardman et al., 2015). Therefore, this 89
section contains the expansion of several previous deliberation results, which were
subsequently used as indicators in analyzing the data in this study.

Public–private partnership’s model of agreement

Unlike traditional schemes that are undertaken single-handedly by the public sector without the
need for any cooperative agreement, PPP, which embraces the private sector, requires a form of
model or agreement between the cooperating parties (Rebeiz, 2012; Kumar et al., 2017). This
agreement is considered as one of the forms of commitment in implementing PPP because in its
implementation, both parties have differing objectives. The public sector conducts infrastructure
development to fulfill the public’s needs, whereas the private sector focuses on providing the most
efficient service possible to gain financial benefits (Levitt and Eriksson, 2016). The contractual
arrangement agreed upon by both parties determines the extent of authority each party has
within an infrastructure development project. The more roles and risks imposed upon the private
sector, the greater the authority the private sector wields to run the project (Rebeiz, 2012).
In terms of implementation, the model of agreement frequently used by every country
varies. Agreement models such as build–operate–transfer (BOT) and build–lease–transfer
are often used by some developing countries to fulfill their large-scale public infrastructure
development needs (Tafesse, 2014; Kumar et al., 2017; Rashid et al., 2016). Developing
countries, which are by and large situated outside the Western area, commonly use the PPP
scheme to reinforce their economic infrastructure (Kahyaogullari, 2013). The concession
model is considered capable of increasing economic stability by having a transfer of
authority within a certain period. As for developed countries, of which a majority of them
are Western countries, they commonly use agreement models such as build–finance–
maintain, design–build–finance–maintain (DBFM) and design–build–finance–operate–
maintain for long-term or large-scale infrastructure development projects (Siemiatycki and
Farooqi, 2012; Lawther and Martin, 2014; Hurk, 2018).
A substantial submission of authority to the private sector for infrastructure projects in
developed countries is believed to be able to reduce the burden of the public sector, which
must distribute its resources for developing social infrastructure (Kahyaogullari, 2013).
However, various other models are also frequently used by various countries, in accordance
with their needs and some other considerations. Understanding the agreement models used
is an initial step to differentiate the implementation of PPPs in various countries. For that
reason, this factor is commonly discussed in articles relating to PPP. This article also
investigates the agreement models used in both Western and non-Western countries so that
it would eventually corroborate with previously existing studies.

Successful factors in implementing public–private partnership

Political commitment
There are several articles providing elaborations by comparing influential factors in the
implementation of PPPs in various countries (Boardman et al., 2015; Dong et al., 2016;
Kahyaogullari, 2013; Hurk et al., 2016; Osei-Kyei et al., 2018; Verhoest et al., 2014, p. 3). Yet, there
JFMPC are only a few comparative studies on the implementation of PPPs in various countries that
26,1 conduct their analyses by examining the political commitment made by the public sector. In fact,
the political commitment of the public sector is one of the most influential factors in implementing
PPP (Seibert, 2006; Firmino, 2018). It can even be said that the political factor is one of the
elements that significantly influences the success and failure of PPP implementation in various
countries (Kokkaew et al., 2013; Ahmad et al., 2017; Neto et al., 2018). Thus, political commitment
90 is a crucial element that should be given substantial consideration when comparing PPP
implementations in various countries. There is actually an article that provides a comparative
study of PPP implementation in several countries by examining the influence of political
commitment found in those partnerships (Verhoest et al., 2014, p. 3), but we consider the political
commitment assessment made in that article to be lacking a rather detailed measurement
standard.
Thus, this article provides an analysis of the political commitment made in implementing
PPPs through the correlation between the government system and several aspects, such as
development consistency and policy influence. A different system of government, with all its
differing regulations and priorities, would surely influence the level of success in every country’s
implementation of PPPs (Hodge and Greve, 2017). Development consistency is examined from
the public sector’s seriousness in determining infrastructure development priorities through the
PPP scheme and the extent that such development can be completed properly and in line with the
public’s need. Weaknesses in determining priority scales and consistency in project
implementation are among the failing factors of PPP implementation in various cases, and
oftentimes, a change in a government system may also influence the development process
(Trangkanot and Charoenngam, 2014; Osei-Kyei et al., 2018). Hence, development consistency is
one of the significant aspects that should be taken into consideration.
The final aspect, which is policy influence, is used to examine how often policy changes
of PPP implementation occur in every country and how those policy changes affect the
success or failure of PPP implementation. Several previous studies also indicate that policy
changes made by the public sector often affect PPP implementation’s level of success
(Kokkaew et al., 2013; Rashid et al., 2016). The policy change is thus a crucial consideration
in examining PPP implementation’s success level. Accordingly, both of these interrelated
aspects within political commitment are points to consider in analyzing and comparing PPP
implementations in this article. When the two aspects are linked properly, they will generate
very strong political commitment, but when the three aspects are engaged in an incongruent
relationship, they will generate weak political commitment.
Role of public–private partnership-supporting unit. In addition to analyzing the
implementation of PPP in various Western and non-Western countries through their agreement
model and political commitment, this study also examines another factor considered relevant by
previous studies. Other than comparing the implementation of PPPs by analyzing the agreement
models used by every country (Dong et al., 2016), some articles compared the implementation of
PPPs by looking at another factor, namely, the role of a PPP-supporting unit (Jooste and Scott,
2011; Hurk et al., 2016). A PPP-supporting unit is usually an agency of the public sector under a
government department with the main objective of controlling and enhancing PPP
implementation through several tasks such as coordination and evaluation (Istrate and Puentes,
2011). Hurk et al. (2016) observed the extent of function and authority the PPP-supporting unit
has, and the organizational structure of the unit itself. The organizational structure of the PPP-
supporting unit may show the extent of the public sector’s role in the country’s implementation of
PPP (Hurk et al., 2016).
To measure the extent of the PPP-supporting unit’s role, the indicators written by Hurk
et al. (2016) were used, namely, authority and function, organization structure and role in
project implementation. Regarding authority and function, the extent of a PPP-supporting Search for
unit’s role in PPP projects is observed. When a PPP-supporting unit is merely tasked to relevance
provide capacity building, technical support, and repository of knowledge, then it is
classified in the dissemination role. However, when a PPP-supporting unit plays a role in
policy guidance and policy evaluation, then it is classified as holding a policy function.
Lastly, when a PPP project requires the input and assessment of the PPP-supporting unit,
then it is classified in the green-lighting role (Hurk et al., 2016). However, in this article, the
role of the PPP-supporting unit is elaborated with the indicators mentioned above, which are 91
political commitment and its inherent aspects.

Methodology
This study compares the implementation of PPPs in various Western and non-Western
countries; accordingly, the analysis used was a comparative case study (CCS; Goodrick,
2014; Bartlett and Vavrus, 2017). A CCS was used to compare several cases with similar
outcomes but differing effects, or a number of cases with similar effects but differing
outcomes (Goodrick, 2014). In this study, the effects of the PPP scheme in public
infrastructure development of the respective countries with their varying outcomes are
observed. By using the CCS method, similar data was selected according to a predetermined
standard and gathered systematically to produce a structured collection of data; the data
collection results were subsequently made to go through a focused comparison process
(Hurk et al., 2016). Every case in this article is a representation of Western and non-Western
countries that are compared by using several set criteria.
Unlike traditional case study methodology, CCS is considered as a method that can
increase data findings by comparing several previous cases, and it can interpret every
process up to the results obtained from every case (Goodrick, 2014; Kurniasih et al., 2016;
Dinour et al., 2017; Martinus and Hedgcock, 2015). Both general and specific sources from
the respective countries were used by applying the CCS method to compare them. The data
sources were acquired from country reports, policy papers, policy evaluations or
constitutional amendments, government websites and even previous studies containing the
opinions of various experts (Hurk et al., 2016).
The comparative study conducted in this paper involves comparing the implementation of
PPPs in various Western and non-Western countries. The case of PPP implementation in
Western countries includes Belgium, France, Italy and the UK. These countries have increasingly
been using PPPs to accelerate the development of major infrastructure projects. Furthermore,
these countries are highly economically and administratively developed and find that the private
sector is more able than the public sector to supply a variety of goods and is more able to manage
financial risks. On the other hand, India, Indonesia and Thailand were chosen as the example of
cases in non-Western countries because the interest of PPP in these countries is growing in
sustaining and expanding Asia’s economic growth (van der Geest and Jorge Nunez-Ferrer, 2011).
Promoting PPP implementation appears to offer a solution to overcome barriers to growth in the
various sectors such as infrastructure, transportation, electricity, tourism and other public
facilities. Although several countries were selected to represent Western and non-Western
countries, it should be emphasized that the sources obtained from those countries may have
differing degrees of reliability. This is because of a difference in data availability regarding PPP
implementation in the selected countries. Additionally, PPP implementations were observed in
the infrastructure development projects conducted in the selected countries in general, and the
countries representing the Western and non-Western countries were also those considered to
have adequate data sources. Accordingly, it is expected that the study results have gathered
enough data to appropriately explain the differences in PPP implementations in various Western
JFMPC and non-Western countries. Subsequently, the criteria from the respective countries were
26,1 analyzed based on the topic, methodology, and theory used. As for the criteria used, they are in
line with a few factors explained in the previous part of this article, so that data findings capable
of explaining the difference of PPP implementation in various Western and non-Western
countries were eventually obtained. The frequently used agreement model and the government
system of the country were set as a standard in differentiating PPP implementations in the
92 Western and non-Western countries under study (Table 1).
In this study, the source of the data obtained not only comes from articles in international
journals that discuss the implementation of PPP in selected countries and government
reports but also from international institutions (Table 2). The data obtained from these
various sources was then selected according to the need of study which is based on the
predetermined criteria (Dinour et al., 2017).

Comparative analysis: Western and Non-Western public–private partnership

This section presents comparative analyses of each of the predetermined components. At
the end of this section, every component is elaborated to arrive at the differences and
similarities of PPP implementations in the various Western and non-Western countries. The
states representing the Western countries are Belgium, France, Italy and the UK, whereas
those representing the non-Western countries are India, Indonesia and Thailand. The

PPP’s model of BOT

agreement DBFM
DBFO
Government and Parliamentary republic
political system Presidential
Constitutional monarchy
Semi-presidential
Parliamentary
Political Development consistency Priority changes result in development suspension
commitment Priority changes hinder the development process
Priority changes do not hinder the development
There is no priority change
Policy influence Weak PPP policy
Conducted policy changes several times with
outputs hindering PPP implementation
Conducted policy changes several times with
outputs improving PPP implementation
Good and strong PPP policy
Function and authority Purely dissemination function
dissemination and policy function
dissemination and green-lighting
dissemination, policy function and green-lighting
The role of Organization structure Public body under ministry
PPP-supporting Public law body
unit (Hurk et al., Separate legal entity without private sector
Table 1. 2016) participation
Separate legal entity with private sector
PPP
participation
Implementations Role in project implementation No responsibility
criteria in Western Limited responsibility (indirect)
and non-Western Substantial responsibility
countries (direct)
Countries Sources
Search for
relevance
India Chotia and Rao (2018), Kalidindi and Singh (2009), Parthasarathi and Aryasri (2017), The
World Bank (2018), Saha (2017), The World Bank (2019)
Indonesia BAPPENAS (2018), Berawi (2018), PGI (2016), The World Bank (2018), The World Bank
(2019)
Thailand Chittmittrapap and Thammavaranucupt (2019), Kokkaew et al. (2013), SEPO (2014), The
World Bank (2018), The World Bank (2019), Trangkanot and Charoenngam (2014) 93
Belgium ECA (2018), Eynden et al. (2019), Hurk (2018), Hurk et al. (2016), Hurk et al. (2013), EPEC
(2012), Werneck and Saadi (2019)
Table 2.
France Maniatis and Vassilakou (2017), EPEC (2012), ECA (2018), Hurk et al. (2016)
Italy Werneck and Saadi (2019), ECA (2018), Carbonara and Pallegrino (2014), Hurk et al. (2016), Data sources for PPP
MEF (2015), EPEC (2012), Rossi and Civitillo (2014) implementation in
UK Debt (2017), Kahyaogullari (2013), Shaoul et al. (2006), Werneck and Saadi (2019), Hurk et al. Western and non-
(2016), EPEC (2012), ECA (2018), Richards et al. (2019), Shaoul et al. (2006) Western countries

countries were selected based on data availability that is considered appropriate with the
need for analysis (Table 3).

Public–private partnership’s model of agreement, government and political system

Data findings (as shown in Table 4) indicate the differences of PPP implementations in Western
and non-Western countries with their varying forms of model agreements. However, many of the
Western and non-Western countries have a similarity in terms of the government system and the
agreement model they use. For instance, India and Italy both have a parliamentary republic
system of government, and they also use a similar PPP agreement model, which is the BOT
model, although basically Italy often uses other agreement models such as design–build–
operate–transfer and design–build–finance–operate (DBFO) in implementing PPP (Carbonara
and Pallegrino, 2014; Parthasarathi and Aryasri, 2017; Rossi and Civitillo, 2014). Meanwhile,
countries with a president as their head of state, such as Indonesia and France, often use the
concession model in their implementation of PPP for infrastructure development (Maniatis and
Vassilakou, 2017; BAPPENAS, 2018).
Prior studies and thoughts stating that PPP implementations in developing countries
frequently use the BOT model are corroborated by the results of this study. All the states
representing non-Western countries in this study often use the BOT model to implement
PPP in their respective countries, which is also complemented with other agreement models
in accordance with their needs (Kokkaew et al., 2013; SEPO, 2014; Werneck and Saadi, 2019).
Yet, for the Western countries in this research, only Belgium was found to often use DBFM
for implementing PPP, whereas other Western countries use agreement models such as
concession, BOT and DBFO (Werneck and Saadi, 2019).

Political commitment: consistency and policy

In past studies comparing PPP implementations, there have not been many analyses on the
political commitment of the countries in implementing PPP. While in fact, political
commitment is regarded as the most vital element in PPP implementation, and it often
jeopardizes the development process (Brzozowska, 2006; Parvu and Voicu-Olteanu, 2009).
Each country evaluated in this study had varying degrees of political commitment, as
observed from the development consistency and policy influence of the respective countries.
The study results, ultimately, present several findings in comparing the political
commitments of states, particularly in Western and non-Western countries.
 94
26,1

Table 3.
JFMPC

Comparative
analysis of PPP

Western and non-

Western countries
implementations in
Government Political commitment The role of a PPP-supporting unit
and political PPP’s model Function and Organization Role in PPP
Country system of agreement Development consistency Policy influence authority structure implementation

India Parliamentary BOT The priority change has Frequently change the Dissemination, policy Public body under Substantial
republic impacted to development policy that hinders PPP function and green- ministry responsibility
delayed implementation lighting (direct)
Indonesia Presidential BOT The priority change has Policy change for better Dissemination Public body under Limited
impacted to development PPP implementation function, the policy ministry/public law responsibility
delayed function body (indirect)
Thailand Constitutional BOT The priority change has Policy change for better Dissemination, policy Public body under Substantial
monarchy impacted to development PPP implementation function and green- ministry responsibility
delayed lighting (direct)
Belgium Constitutional DBFM The priority change has Availability of PPP Dissemination and Public body under Limited
monarchy not impacted to policies policy function ministry responsibility
development delayed (indirect)
France Semi- DBFO The priority change has Policy change for better Dissemination, Policy Public body under Substantial
presidential not impacted to PPP implementation function and green- ministry responsibility
development delayed lighting (direct)
Italy Parliamentary BOT The priority change has No adequate PPP policy Dissemination and Public body under Limited
republic not impacted to policy function ministry responsibility
development delayed (indirect)
United Parliamentary DBFO The priority change has Policy change but hinder Dissemination and Public body under Limited
Kingdom impacted to development PPP implementation policy function ministry/separate responsibility
delayed legal entity without (indirect)
private sector
participation
Countries PPP’s project Model of PPP
Search for
relevance
India Road sectors, such as expressways and national highways, BOT
commonly use the BOT model in their implementation
(Parthasarathi and Aryasri, 2017). The development of 1,000 km
of expressways under the National Highways Development
Program is an example of the BOT model in India (Kalidindi and
Singh, 2009). 95
Indonesia Jakarta-Bandung High-Speed Railway is a top project PPP in Concession, BOT
Indonesia today; it is a partnership involving several Indonesian
and Chinese companies. This project is planned to be extended to
Surabaya (Jakarta-Surabaya HST Project) by using a concession
scheme along with several companies in its implementation
(Berawi, 2018).
Thailand Data from PPI (PPI World Bank) shows that Bangkok Pink and Concession, BOT
Yellow Monorail Lines is one of the PPP’s projects under the
concession model, with $3.129m of total investment.
Belgium Brabo I Light Rail in the North of Belgium was one of the Flemish DBFM
PPP projects with DBFM as the agreement model used (Hurk
et al., 2013).
France New generation access network in Limousin (DORSAL) is one of DBFO, concession,
the examples of a concession scheme with a contract period of partnership
20 years for construction and maintenance, while the Waste Water contract
Treatment Plan Grand Prado on The Reunion Island is an
example of the DBFO model in France (The European PPP
Expertise Centre, 2012).
Italy BOT is the most traditional model of PPP implementation in Italy, BOT, concession
which came about along with the advent of PPP regulation in the
1990s (Carbonara and Pallegrino, 2014). Most PPP projects in Italy
are in health-care construction, with the construction of nine
hospitals as examples of the concession model implementation
(MEF, 2015).
Table 4.
UK A69 Newcastle-Carlisle is one of the PPP implementations in the DBFO
UK, with a DBFO scheme and agreement to construct a 3.5 km by- PPP agreement
pass. Another example is the M1-A1 Motorway Link, with a total models in Western
distance of 30 km and a total investment reaching £214m (Shaoul and non-Western
et al., 2006). countries

The study results (as shown in Table 3) indicate that non-Western countries usually
experience problems with policy and development consistency, wherein they often make
priority changes impacting the PPP project development process. In India, the government’s
weak role in the development process led to the suspension of numerous PPP projects (Saha,
2017). Based on data from the World Bank, Private Participation in Infrastructure (PPI) in
India in 2015 dropped within the past five years, and it reached its lowest amount of $3.9bn.
The role of the government in PPP development projects is believed to be one of the causes
of problems in PPP implementation, be it suspension of land acquisition, changes in
government interest, or even constantly expanding costs and protracted time (Saha, 2017).
As a result at the end of 2016, there were as many as 287 development projects that were on
hold, which were also caused by the numerous policy changes that occurred and the length
of agreement given by the government to private parties (Parthasarathi and Aryasri, 2017).
Indonesia and Thailand also experienced similar issues as India in implementing PPP,
wherein government consistency in development implementation remained a problem. The
difference was that Thailand and Indonesia carried out changes by revising the PPP policies
JFMPC in their countries and improving them, although there were still a number of problems in the
26,1 implementation. Thailand made a policy change by swapping the use of the previous
Private Participation in State Undertakings Act BE 2535 (1992) (The PPSU Act), to using
Private Investments in State Undertakings Act BE 2556 (2013) (The PISU Act). This change
in policy was based on the several weaknesses that the PPSU Act had during its two
decades of implementation, which was a lack of clear regulations regarding the scope,
96 duration and authority of each party in the planning and implementation of PPP
(Chittmittrapap and Thammavaranucupt, 2019).
Thailand’s political instability since the military coup of 2006 has been highly influential
in hindering the country’s investment for infrastructure development. Investments for large-
scale projects in Thailand were consequently disrupted by government interventions
attempting to align the investment plan with their political basis and interests (Kokkaew
et al., 2013); hence, it was considered that the advent of the PISU Act would provide clear
standards and reduce political interventions by the government. Meanwhile, Indonesia also
made changes in PPP policy along with changes in its administration. The current priority
of the Indonesian Government, which is the acceleration of infrastructure development,
requires policy improvements in support of that priority (PGI, 2016; BAPPENAS, 2018).
Indonesia issued Presidential Instruction No. 1/2016 and No. 3/2016 to increase development
project acceleration by expanding the authority of local and central governments in
managing and implementing projects. The new regulation also lends support to operational
needs such as ease of land acquisition process for development projects (PGI, 2016).
Nevertheless, despite the non-Western countries’ efforts to improve the PPP policies in their
country, in reality, they still experience the same problems, namely, the intervention of interests
by various parties in development consistency (Kokkaew et al., 2013; PGI, 2016; Parthasarathi
and Aryasri, 2017; Saha, 2017; Chittmittrapap and Thammavaranucupt, 2019). Practices of
corruption and nepotism in those countries actually have an impact on the implementation of
PPP (Kokkaew et al., 2013; PGI, 2016), and in countries such as India, this is exacerbated by
changes in PPP policies, which have raised subsequent problems in PPP implementation
(Parthasarathi and Aryasri, 2017).
Meanwhile, concerning the Western government’s political commitment to the
implementation of PPP, it is shown that results are opposite to that experienced by the non-
Western countries. Several PPP policies in Western countries do not tend to change, so this does
not inflict any direct impact on the implementation of PPP (Maniatis and Vassilakou, 2017; Hurk,
2018; Rossi and Civitillo, 2014; Eynden et al., 2019). However, in some cases such as Italy, the lack
of policy changes has in fact led to problems in implementing PPP. Italy is undoubtedly one of the
countries with a rather high degree of PPP activities, yet Italy’s PPP policy is still considered
ineffective (Rossi and Civitillo, 2014). Italian law does not prescribe the estimation of VFM before
the approval of a PPP project; some conditions of PPP project implementation in Italy are instead
determined by the private sector, which is then considered to weaken the commitment of the
private sector (Rossi and Civitillo, 2014; Carbonara and Pallegrino, 2014).
However, the political interventions that took place in some of the Western countries above
are actually considered low, and the implementation of PPP projects in those countries tended to
run smoothly (Carbonara and Pallegrino, 2014; Rossi and Civitillo, 2014; Maniatis and
Vassilakou, 2017; Eynden et al., 2019). Nevertheless, issues in PPP implementation were observed
in the UK, wherein the policy changes made by the government had disrupted the
implementation of PPP and led to numerous problems that resulted in suspending the
development process in various cases instead (Debt, 2017). The PF2 policy in the UK, which was
issued in 2012, with a total capital investment reaching £1bn in the form of 46 schools and one
hospital, had not reached a financial close, except for the Midlands Metropolitan Hospital project Search for
in 2016 (Richards et al., 2019). relevance
The data presented above does indeed indicate that every country, both Western and non-
Western, has various problems with political commitment. Yet, it is indisputable that the non-
Western countries above, of which the majority are developing countries, still experienced
political interventions and policy changes that influenced PPP implementations in their
respective countries. However, despite the rather low level of political intervention seen in
Western countries, some of them actually have various issues with political commitment in 97
implementing PPP.

Role of public–private partnership-supporting unit

Unlike the political commitment variable, the role of every PPP-supporting unit observed in
the Western and non-Western countries did not indicate any specific differences between
them (as shown in Table 3). Data concerning the role of PPP-supporting units in Western
countries was obtained from the results of research conducted by Hurk et al. (2016), which
had previously studied the role of PPP-supporting units and the activities of PPPs in
Western countries. However, this article is supplemented with elaborations on the role of
PPP-supporting units in non-Western countries, and another variable, which is the political
commitment of every country. According to the study results, every country has a PPP-
supporting unit with their respective authoritative capacity, and out of all the countries
taken as samples above, it is shown that the authority of every PPP-supporting unit has
covered the dissemination and policy function.
Even PPP-supporting unit in non-Western countries, such as India and Thailand, already
have the authority to provide inputs and assessments in the implementation of PPPs (green-
lighting). Thailand has the PPP Committee and the State Enterprise Policy Office (SEPO) as its
PPP-supporting unit, which has direct authority over the implementation of PPPs in the country.
In the ESCAP Report (2014), the PPP Committee and SEPO deliberate on the implementation of
Thailand’s PPP, in which subsequently both PPP-supporting units also approve of the planned
project proposal. In the implementation of PPP, the representative from SEPO is also one of the
representatives of the project agency, which means it has direct authority in the implementation
of PPPs in Thailand (SEPO, 2014). PPP-supporting units in non-Western countries hold a
prominent role, whereas in some Western countries, the PPP-supporting unit does not even have
a direct role as their counterparts do in non-Western countries.
In terms of organizational structure, the PPP-supporting units do not indicate any specific
differences between Western and non-Western countries. The organizational structure of PPP-
supporting units in every country is commonly under a ministry or a public legal entity. The UK
is the only country with a different organizational structure wherein its PPP-supporting unit
bears separate legal status and involves the participation of the private sector within its
organization. However, in reality, the role of the PPP-supporting unit in the UK during the
implementation of PPPs is indirect in nature with limited responsibilities (Hurk et al., 2016).
Furthermore, PPP in non-Western countries is still inconsistent in their implementation. Non-
Western countries have problems with canceling projects or having other problems (in
accordance with the World Bank data). The same data source (World Bank) indicates that within
the 1990–2016 period, Indonesia merely completed 113 projects with total investments reaching
$44.856m. Projects canceled or under distress in Indonesia amounted to 12 projects, which
represented 91% of the total investment. Meanwhile, in Thailand, 162 projects had achieved
financial closure with total investment value reaching $35.007m, and the projects canceled or
under distress were 3 projects, which represented 91% of the total investment. PPP
implementations in Western countries were usually focused on the field of technology and social
JFMPC development, and they have good consistency in their implementation up to their completion
26,1 (European Court of Auditors, 2018; The European PPP Expertise Centre, 2012). Within the 1990–
2016 period, the total PPP projects in the UK reached more than 1,000 projects with a project
value of more than e150bn (European Court of Auditors, 2018). The PPP implementation case in
Italy shows that the implementation focused on social development, with health-care construction
development being the highest PPP activity in the period 2010–2014 (MEF, 2015). PPP
98 implementations in Italy also had a project value of nearly e20bn in the 1990–2016 period, despite
having only executed around 100 projects (European Court of Auditors, 2018). Data from ECA
also indicates that other Western countries, namely, France, had project value reaching more than
e30bn, with a total of only 200 projects being carried out.

Conclusion
Based on the classification conducted in this study, it is shown that the implementation of PPPs in
Western and non-Western countries does not significantly differ. When observed through the form
of government systems and the agreement they frequently use, no noticeable differences were
found because some of the Western and non-Western countries had similar government systems or
frequently used agreements, although in some cases, the agreement model used by each country
had a different understanding. However, a difference in PPP implementation is very much apparent
in the political commitment that the Western and non-Western countries maintain. Political
interventions in PPP implementation still frequently occurred in non-Western countries, which
consequently disrupted the implementation of PPP itself. Although in terms of the policy, some of
the non-Western countries above had made changes toward better results. In reality, the
intervention of interests from various parties still influenced the implementation of PPP. Even
though such problems also occurred in Western countries, such as the UK, which made policy
changes and disrupted development consistency in implementing PPP, political interventions in
Western countries are classified as low. The problem that caused the delay or cancelation project in
non-Western countries was considered as an impact of the weak political intervention that still
occurred in these countries.
The strong political will and legal structure extend to all countries in this study
experienced are the crucial factors in implementing PPP models. PPP has typically proved
less costly than normal procurement in Western and non-Western countries because the
private sector is increasingly productive. PPP can at the same time allow countries to build
infrastructure and public facilities faster and cheaper, however, PPP often leads to increased
risk of failure where the specifics of the project service rates and the distribution of the risk
are not very well prepared and identified.
PPP provides the government with a way of building and improving public service without
taking on the financial strain of the projects necessary. The financial climate and unpredictable
future policy changes will however influence the implementation of PPPs across countries and
sectors. This article offers the ideas for future research that focuses on specific parameters to
determine, select and enforce PPP desirability to allow the sustainability of long-term projects to
be carried out in PPP contract terms. However, in view of the longer duration of PPP contracts,
public and private sectors both should seriously concerned with how to plan for risk which is
uncertain or even unpredictable in the future. Furthermore, in the best approach to the selection of
PPP models, the levels of economic development of countries should also be taken into account.
As infrastructure and services sectors evolve, PPP implementation should be focusing on services
delivery in some economic system. In the future, new approaches and criteria for selecting PPPs
should also include anthropological and environmental concerns as well as political, social and
economic concerns that drive the expectations of stakeholders as never before. As a consequence
of new technology development, the risk will be seen as a potential opportunity to enhance the Search for
implementation of PPP through creative funding in the future. relevance

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Further reading
Bing, L., Akintoye, A., Edwards, P.J. and Hardcastle, C. (2005), “The allocation of risk in PPP/PFI
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Trafford, S. and Proctor, T. (2006), “Successful joint partnerships: public-private partnerships”,
International Journal of Public Sector Management, Vol. 19 No. 2, pp. 117-129.
Zhang, X. (2005), “Critical success factors for public-private partnerships in infrastructure
development”, Journal of Construction Engineering and Management, Vol. 131 No. 1, pp. 3-14.

Corresponding author
Bevaola Kusumasari can be contacted at: bevaola@ugm.ac.id

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