7. Integrating stakeholder engagement into planning and decision making

The OECD Recommendation of the Council on the Governance of Infrastructure makes the following recommendation to ensure transparent, systematic and effective stakeholder participation in infrastructure decision-making:

“Providing and taking proactive measures to disseminate information on infrastructure projects, including their potential short and long-term effects, and allow for continuous, inclusive, social and open dialogues that are broad-based, involving relevant stakeholders in planning, decision-making and oversight.

Integrating consultation processes that are proportionate to the characteristics of the project (e.g. size, political sensitivity, environmental aspects, and impacted population) and that take account of the overall public interest and of the views of the relevant stakeholders through a disciplined, upfront stakeholder mapping and analysis, which can ensure engagement efforts cost-effectively to include relevant groups in decision making.

Ensuring meaningful stakeholder engagement with users and impacted communities to collaborate during the relevant phases of the project lifecycle, ensuring debate and oversight on the main economic, fiscal, environmental and social impacts of the project.” (OECD, 2020[1]) 

Stakeholder engagement and participatory initiatives bear tremendous potential to make decision-making address today’s societal problems effectively and credibly. Decisions about public investments can be significantly improved when those impacted are involved in the decision-making process. It allows for alternatives to be found, assumptions to be tested, and helps to build trust in government action. Stakeholder engagement can take place with citizens, affected property owners, businesses, representative organisations, the public sector and non-governmental organisations among many others. Given the wide range of potentially affected stakeholders, it is important to consult broadly, ensuring that all relevant impacts are assessed, and that decisions about public investments are – where appropriate – reviewed, amended and open to legal challenge.

Public investment decisions, and the process of making them, are expected to reflect the needs and reality of society, but they also ought to adapt and react quickly to changes. This can happen more easily when systems and practices for creating and improving regulations are fully embedded into the country’s decision-making processes, rather than viewed as a bureaucratic afterthought.

Stakeholder engagement can take place at various levels of government – from local communities to the national level – and be applied to most public investment decisions. It is particularly important for decisions about large, physical assets to include input from stakeholders, given the immediate impact that roads, water services, electricity infrastructure and public facilities have on people’s wellbeing, the productivity and operations of businesses and the policy decisions of national and sub-national governments. Another important aspect of stakeholder engagement involves land acquisition, where public works providers have recourse to acquire private land holdings. When engaging with affected property owners in particular, it is critical that governments are transparent, fair and timely with making decisions that impact the property and wealth of people and businesses.

But not all stakeholders are equally affected by a particular public investment proposal. Also, different stakeholders will have different information needs. Different stakeholder engagement options exist along a spectrum depending on the extent to which a particular stakeholder is impacted by the proposed public investment. Figure 7.1 depicts the spectrum of approaches to stakeholder engagement that are available depending on the nature of the activity. This can be a useful framework to help identify how different stakeholders can be best involved in a decision-making process about a particular public investment.

Different circumstances will require different approaches to stakeholder engagement. For example, larger, longer-lasting public investments that impact a wide range of people may need a more structured, systematic approach, involving many different methods of gathering information, to accurately capture a wide range of perspectives. A more specific public investment, which might have a direct impact on a small group of individuals, may require more in-depth, targeted engagement. Quality stakeholder engagement, which captures the perspectives of people from across society, will also use communications and engagement tools that appeal to people of a diverse range of ages, cultural backgrounds and gender.

While stakeholder engagement can be enormously beneficial to helping inform public investment decisions, this needs to be balanced against the need to bring certainty to communities, businesses and other stakeholders. This can mean seeking stakeholder input early in a public investment decision, but not necessarily allowing decisions to be revisited once they have been made with input from stakeholders.

Stakeholder engagement, when done well, can lead to better, more acceptable choices from environmental, economic and technical perspectives. It can also give decision-makers better information, avoid conflicts later in the process and raise the legitimacy of the decision-making process. Stakeholders also benefit by having better information, greater confidence in democracy and public institutions and public assets and services that better reflect their needs.

According to guidelines for the development of national, regional and territorial planning (Republic of Bulgaria, n.d.[3]), the principles of partnership and stakeholder participation are mandatory when preparing strategic documents. As a result, formal public consultation is widely used to inform public investment decisions across national and municipal levels. For example, all strategic documents at the national, regional and municipal levels are subject to public consultation.

For example, the Ministry of Transport and Communication’s Integrated Transport Strategy 2030 was developed with advice from a Steering Committee and with input from working groups that represented a wide range of stakeholders. The Integrated Transport Strategy was also informed by three public forums that took place in Sofia during its development.

All EC-funded programmes are informed by ‘thematic working groups’ and ‘monitoring committees’, which include representatives from different stakeholder groups. The Council of Ministers determines which institutions and types of organisations can participate in the stakeholder groups, which gives a limited criteria within which these institutions can nominate representatives. It is unclear whether there is a criteria that the Council of Ministers and institutions must follow. While a Programme Monitoring Committee for the stakeholder groups must approve a code of conduct setting out how conflicts of interest will be prevented (Republic of Bulgaria, 2022[4]), it is not clear whether members’ conflicts of interest, and the steps to resolve those conflicts, are publicly declared. For the stakeholder groups to have integrity and help build trust between government and citizens, it is important that there is a transparent criteria for selecting a diverse range of representatives and a process for managing any conflicts of interest. The Regional Development Act also specifies that regional development councils must involve stakeholders when selecting projects to receive funding under the Regional Development Programme.

At the municipal level, projects are announced and public consultation exercises are run by the relevant municipality. While all municipal strategies and plans are subject to public consultation, decision-makers have leeway on the extent to which public consultation can inform the final decision. The feedback from public consultations run by line ministries must be made publicly available and are typically uploaded to ministry websites. The Public Finance Act also requires that draft municipal budgets are subject to public consultation, including with input from the National Association of Municipalities. Naturally, there is a tension between the need to deliver infrastructure and ensure public investment decisions are adequately informed by affected parties and that environmental protections are met. Several public bodies tasked with delivering infrastructure described the frequency of appeals lodged by stakeholders on environmental or cultural heritage grounds, resulting in delays to projects and presenting difficulties to infrastructure providers in delivering their programmes. As noted in Section 4: Coordination Across Sectors, delays with acquiring land means some infrastructure providers struggle to fulfil the requirements of their permits, meaning they cannot progress with works. Land acquisition gets determined through a court process, which means waiting for a court decision can cause uncertainty about whether a project will happen. Compensation is often paid to landowners, but the proposed amount can be appealed, which requires more time for the courts to reconsider the land acquisition proposal. As noted above, the Spatial Development Act requires larger projects to be divided into sections. While the reasons for this relate to minimizing risk and managing funding, it can mean activities like land acquisition take place in a piecemeal manner, which can cause delays and uncertainty about the delivery of projects. The Ministry of Transport and Communications have proposed legislative changes to overcome this.

Protection of archaeological sites is a frequent cause of delays to the approvals process. Projects are being delayed by up to two years due to archaeological findings. Part of the issue is resource constraints – often there are too many permit applications for the number of people available to manage them in a timely fashion. Not only are staff numbers limited, but they are having to be trained ‘on the job’ while completing complex environmental assessments. This is a particularly significant issue for smaller municipalities, where staff are more constrained. Resourcing constraints may make it difficult to implement the Recovery and Resilience Plan in a timely manner, given it will bring new projects and therefore additional applications for new environmental permits. The larger municipalities tend to be better resourced, which has led to suggestions that municipalities should consolidate. However, being bigger is not always better: larger municipalities in Bulgaria can experience a lack of internal coordination. The section on Sharing of Services (Vertically and Horizontally) in Section 4: Coordination Across Sectors outlines the discussion within Bulgaria on the consolidation of municipalities and provides some matters to consider.

For specific projects, the findings from public consultation inform environmental impact assessments (EIA), which are a legal requirement for most infrastructure development and are assessed by the Ministry for the Environment and Water. In response to complaints about the time delays and costs imposed by engaging stakeholders and undertaking public hearings, the Ministry of Environment and Water say that while the EIA process can be long and thorough, it is an important step because it gives confidence to society that infrastructure providers are operating within environmental parameters. They argue that by allowing sufficient time and with good planning, infrastructure providers should benefit from the process. Helpfully, the Spatial Development Act specifies a tight definition of who public infrastructure providers must consult with. While the definition is open to interpretation, typically infrastructure providers are only legally obligated to consult with stakeholders who own land that is directly affected by their proposals. The judiciary decides whether an appeal is admissible. This can help reduce the number of appellants and ensure legal challenge is only granted to parties who are genuinely affected by a proposal, rather than those less directly affected who may oppose an activity on, for example, ideological grounds.

There are examples in Bulgaria of highly creative and thorough public participation processes. One example is the Sofia Municipal Council’s process for developing Vision for Sofia 2050 (Sofia Municipal Government, 2017[5]). Public participation included a series of public discussions, over 400 interdisciplinary meetings, wide use of social media, the use of surveys, a ‘hackathon’, extensive gathering of evidence and data from a wide range of sources, public exhibitions and other initiatives designed to attract as wide a catchment of stakeholders as possible. For the last two years, Sofia has also allocated approximately EUR 750 000 of the municipality’s annual budget to projects that citizens have voted for.

In all municipalities, the public must have been consulted on all budgets before they can be adopted. While the process for doing this across municipalities may vary, one municipality described how they invite proposals from citizens and representatives of settlements within the municipality, which they then discuss at the community level. This informs the composition of the following year’s budget.

While some members of the community are more engaged than others, generally public participation processes are effective at reflecting the preferences of people from all demographics and age groups. This is achieved by municipalities being as accessible as possible, such as by holding weekly open days and active use of social media.

Across the three municipalities we met on mission, which varied considerably in size, the municipalities had tailored their stakeholder engagement activities to what appears an appropriate level given the population size and scale of each municipality’s investment activities. For example, in Slivnitsa, a municipality of fewer than 10 000 people, municipality staff are highly attuned to the needs and views from within the community, which means they are less reliant on the formal, structured public participation exercises that larger municipalities might need to capture a wide cross-section of views from the community.


[2] IAP2 International Federation (2014), Stakeholder Participation: IAP2 public participation spectrum, https://i2s.anu.edu.au/resources/stakeholder-participation-iap2-public-participation-spectrum/.

[1] OECD (2020), Recommendation of the Council on the Governance of Infrastructure, https://legalinstruments.oecd.org/en/instruments/OECD-LEGAL-0460.

[4] Republic of Bulgaria (2022), Article 12, paragraph 2, Resolution No. 302 (29 April 2022) on the Establishment of Committees for Monitoring of the Partnership Agreement of the Republic of Bulgaria and of the Programmes Co-financed by European Funds under Shared Management 2021-27.

[3] Republic of Bulgaria (n.d.), Methodological Guidelines for the Preparation of Integrated Territorial Development Strategies of the Level 2 Planning regions for the period 2021 – 27, the Methodological Guidelines for the Preparation and Implementation of Integrated Munipalities.

[5] Sofia Municipal Government (2017), Vision Sofia 2050, https://vizia.sofia.bg/vision-sofia-2050/.

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