Public Services Management: Disunited nations: Paul Gosling tells the one about differences between councils in England, Northern Ireland, Scotland and Wales

LAST November Ian Lang, Secretary of State for Scotland, announced a range of options for the future of the water supply and sewage industry north of the border. These varied from privatisation to retention by local authorities of the control of water. Many people in England were astonished, assuming it was already privately controlled, sold off with the English and Welsh water boards in 1989.

Political commentators in the media often take a very English-centred approach, failing to make clear that the United Kingdom operates not under one political system, but comprises several. While the local government structures of England and Wales are similar, there are many differences in Scotland, even more in Northern Ireland, while government of the Channel Islands and the Isle of Man appears almost feudal in character. The Isles of Scilly could be a case study for a unitary authority, with the powers and responsibilities of a county and district council, plus a parish council, and also in charge of water supply.

Responsibility for Northern Ireland's water supply was transferred in 1973 from councils to the Northern Ireland Department of Environment, which still retains it. The other significant difference, reflecting the rural character of much of the province, is that 4 per cent of the Northern Irish population are without piped water, and 10 per cent use septic tanks.

In England the figures are smaller: half of 1 per cent of the population are not on piped water supply, and 5 per cent use unadopted sewage pipes or septic tanks. The figures are 2 per cent and 5 per cent in Scotland, where water supply, for the time being at least, is the responsibility of the nine regional and three islands councils.

The existence of the Scottish regional councils is itself an oddity. They are much larger geographically than English or Welsh counties, partly reflecting a broader spread of population. Meanwhile, the three outer islands councils - Western Isles, Shetland and Orkney - are already unitary authorities.

The Scottish Office introduced plans last October to bring in unitary authorities, and will almost certainly abolish the regional (but not the islands) authorities. Last October's consultation document suggested alternative options of 15, 24, 35 and 51 councils. If the Scottish Office were to propose 51 unified authorities, which would be very close to the present 53 districts, the result would be an increase in local government spending, as well as a very fragmented system. The most likely outcome is 24 councils, or slightly more.

The Convention of Scottish Local Authorities (Cosla) represents both regional and district authorities, and is lobbying for retention of the current system. Albert Tait, Cosla's deputy secretary of finance, says: 'The Government has not assessed whether there is a valid case for change. The Secretary of State is doing nothing to strengthen local government. You will always have a conflict between the idea of strategic authorities and councils with a local identity.'

Proposals to reorganise local government in Wales are more advanced. A White Paper, due to be published shortly, is expected to recommend that the present 37 district and 8 county councils be replaced by 24 unitary authorities. The Council of Welsh Districts (CWD) welcomes the proposals. Paul Griffiths, assistant secretary, says: 'It is returning to the historic counties, though it is seen as a district-based solution. It would not easily be transposed to England where the districts generally are the newcomers. Some Welsh authorities would be much smaller than any English unitary authorities, for example Merioneth, with 32,000 residents.'

According to the Assembly of Welsh Counties (AWC), reorganisation based on the districts will cost pounds 100m, though the CWD argues that it will produce small savings. The AWC's main case against the proposals is that the abolition of counties as strategic authorities will necessarily lead to undemocratic and unaccountable joint agencies. It is likely that joint arrangements will be necessary for highway planning, fire services and even libraries and trading standards.

Fire services are part of county councils. But it is accepted that the new, smaller unitary authorities in Wales would not be an efficient basis for running fire services, which will therefore be run by joint boards. The Home Office wishes to see fire services cover larger areas than at present, to take advantage of economies of scale, so they may in the future be run by far fewer boards than the present number of county councils.

There are just four police authorities in Wales, covering much larger areas than the county councils, with the exception of Gwent which is the only county which is also a police authority. The future is largely dependent on the Home Office's review of management arrangements for the police, which could end the traditional role of police committees in local authorities, as well as introducing much larger operational areas for constabularies.

Since Northern Ireland's local government reorganisation of 1973, there have been 26 district councils and no counties. However, it is misleading to think of them as unitary authorities, as the vast majority of local authority powers were removed and given to nine area boards. Housing, planning, road maintenance, water supply, education and health were among the responsibilities taken away, leading to complaints that councils were 'only left with burying the dead and emptying the bins'. Some councils had proved themselves unable to do much more without discriminating against the minority Catholic population.

Northern Ireland Office spokesmen openly admit that these changes were brought about by the civil disturbances of 1968. Removing powers from the councils did nothing to make them apolitical, however. A Northern Ireland spokesman comments: 'In the absence of devolved administration, councils have become much more political - on health matters, security, the presence of Sinn Fein, for example - because there is nowhere else for these matters to be debated.'

Another distinctive characteristic of Northern Irish local government is that elections are conducted using the single transferable vote system of proportional representation, adopted 20 years ago. Councillors in Northern Ireland face election this year, as they do once every four years. In Scotland, elections for the regional authorities occur once every four years, with the last election held in 1990. The Scottish districts also hold elections every four years, with the last held in 1992.

But English and Welsh council elections are the most complicated. The counties hold full elections once every four years, including this year. The London borough elections take place once every four years, with the next election in 1994. The English metropolitan councils are required to hold elections each year, except years when county council elections take place, with one-third of members up for election.

English districts have a presumption of elections by thirds, but are allowed to opt for full elections once every four years, provided that a two-thirds majority of the council agrees. The majority, 182 of the 296 shire districts, have opted for full elections once every four years. Welsh districts are given a straight choice between elections by thirds and all members being up for election once every four years. Of 37 Welsh district councils just four hold elections by thirds.

Many of the differences in local government structure across the home nations arise for no better reason than historical accident. Yet the political consequences of attempting a common system would produce more conflict than advantages. Confusion is simply the price that the public has to pay.

(Photograph omitted)