Public-Private Partnerships in West Africa: A Policy Comparison of Nigeria and Ghana

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1. Introduction Grimsey and Lewis (2004) defined Public-private partnership (P3) as a long-term contractual relationship between a government entity and a private industry consortium for the purpose of delivering public infrastructure and/or services while sharing the associated risks and rewards.P3 has become very popular in recent times especially among developing economies (Leigland, 2018;Osei-Kyei & Chan, 2017a).One of the primary duties of all governments is to provide public, social, and community infrastructures for their citizenry (United Nations, 2004).These infrastructures include roads, power, rails, water, sanitation, airports, education and health facilities, public housing, and buildings among others.The government as part of its duties to the citizenry is to control strategic sectors of the economies (IMF, 2006) to stimulate growth and prevent private investors from taking undue advantage (IMF, 2006).Studies around the world have consistently shown a significant positive relationship between infrastructure and economic output (MOFEP, 2011) Despite the benefits that infrastructure can bring, most governments are unable to provide all the infrastructure that its citizens need, mainly because of financial constraints (MOFEP 2011) which are caused by limited budgets and short-term fiscal restrictions (Maryouri, 2013;Opara et al., 2021).
In response to the challenges that exist in infrastructure financing, governments across the world have resorted to a financing strategy where the private sector is invited to supplement the effort of the government in providing these infrastructures.This is referred to as public-private partnership (P3).According to the IMF (2004), P3 is a contractual arrangement between a public entity and a private sector party with a clear agreement on shared objectives in which the private sector provides infrastructure assets and services that were previously delivered by the government.P3s are not viewed as a panacea to public infrastructure investment problems -but they are seen as a complement and not a substitute for Government's infrastructure responsibility (MOFEP, 2011;Opara & Elloumi, 2017).
In Ghana, the concept of P3 is not new, as the private sector has been actively involved in service delivery since the early 1990s (Osei-Kyei & Chan, 2017a;Osei-Kyei, Chan, & Dansoh, 2017).Before the official introduction of P3 in Ghana, the government worked with the private sector in the delivery of public service in the areas of energy, sanitation, water, and sewage (Awortwi, 2004;Fuest & Haffner, 2007).P3 became a national policy in Ghana in the year 2004 (MOFEP, 2011).In 2011, the Public Investment Division was set up to assist and develop the institutional and regulatory framework for the implementation of P3 in Ghana (World Bank, 2011).The US$115 million Seawater Desalination Plant Project at Nungua is an example of the P3 currently ongoing in Ghana (Osei-Kyei, Chan, & Dansoh, 2017).Despite the great interest shown by the government of Ghana in the P3 policy, there are setbacks in its implementation due to the absence of institutional structures, incomplete transfer of risk, lack of skills, understanding by local practitioners, and high use of unsolicited proposals (Osei-Kyei, Chan, & Dansoh, 2017).
P3 in Nigeria is relatively new when compared to Ghana (MOFEP, 2011).According to Dominic et al, (2015), a significant infrastructural gap because of underinvestment and poor maintenance was responsible for Nigeria's choice for P3.The Infrastructure Concession Regulatory Commission Act (ICRCA, 2005) and the subsequent establishment of the Infrastructure Concession Regulatory Commission (ICRC) in 2008 are steps taken by the Nigerian government as part of the efforts to promote the successful adoption and implementation of P3 (Okwilagwe & Apostolakis, 2016).The government of Nigeria's adoption of P3 is based on the premise that the private sector has the machinery necessary to provide efficiency, broaden access, and improve the quality of public services through infrastructure development (ICRC, 2009).This research attempts to bridge two observed gaps in the nature and trajectory of current P3 research.Current research has tended to focus on a one-country study of P3 policy enactments and implementation (Opara et al., 2017;Opara, 2014;Opara et al., 2021;2022a).Furthermore, studies of P3 policy have been focused on the advanced economies of Europe, Australia, and North America while African P3 appear neglected or forgotten (Opara, 2014;Opara & Rouse, 2019;Opara et al., 2022b).However, this study enhances the robustness of P3 research by studying two countries simultaneously.And by undertaking a detailed post-mortem review of both policy enactments and implementation approaches in a developing region it uncovers the invisible impacts of the differences in institutional environment on policy outcomes (Opara et al., 2017;Opara, 2020).
The remainder of the paper proceeds as follows: We will explore existing literature on P3s, review the use of P3s, evaluate the effectiveness of P3 as a policy tool, and make a comparative analysis of P3 implementation in the two west-African countries.Finally, we will draw conclusions and suggest recommendations for the P3 management in the West African sub-region.

Overview of P3 and Conceptual Framework
The governments of developed, emerging, and Sub-Sahara African countries are challenged by the widening level of infrastructural paucity in public utilities.Similarly, the increasing limited budgets and short-term fiscal restrictions imposed on States, have necessitated the need and demand for investment from the private sector to support the lean resources of the government for economic development (Maryouri, 2013).Public private partnership (P3) is a major platform embraced universally by governments in the past two decades to address the rising gap in infrastructure provisions and delivery (Hodge, Greve, & Boardman, 2010;Appuhami et al., 2011;Newman & Perl, 2015;Siemiatycki, 2015).
Extant literature has defined P3 in diverse ways.One of the popular definitions is by the Canadian Council of Public Private Partnership (CCPPP, 2007;2012) that defined P3 as "a cooperative venture between the public and private sectors, built on the expertise of each partner that best meets clearly defined public needs through the appropriate allocation of resources, risks and rewards."On the other hand, Infrastructure Concession Regulatory Commission (ICRC) of Nigeria, adopting the definition of the US National Council on P3, defined it as; "a contractual agreement between a public agency (federal, state or local) and a private sector entity.Through this agreement, the skills and assets of each sector (public and private) are shared in delivering a service or facility for the use of the general public.In addition to the sharing of resources among the parties, each party shares in the risks and rewards potential in the delivery of the service and/or facility".In the Ghanaian context, P3 is defined as "a contractual arrangement between a public entity and a private sector party with a clear agreement on shared objectives for the provision of public infrastructure and services traditionally provided by the public sector" (MOFEP, 2011).P3 can be referred to as a mutual contract that involves the state (and its agencies) and the private sector which entails the sharing of resources, responsibilities, and risks optimally in the delivery of public services in a more rewarding manner to the parties.The fundamental objective of public-private partnership is to combine the best capabilities of the public and private sectors for the mutual benefit of the parties and the larger society.Ferk and Ferk (2018) say that the concept of public-private partnerships (P3s) refers to various forms of cooperation between public and private sectors for the provision of public services and/or public infrastructure in the public interest.The involvement of the private sector in the provision and delivery of public infrastructure is based on the common understanding that the private sector is more efficient in the provision of public goods in contrast to the government.Opara (2014) provides a comprehensive definition and defined it as any type of contractual arrangement that involves a long-term agreement between a private sector party and a government in which the private sector party designs, builds, finances and operates public infrastructure and/or service in exchange for some form of financial payment.
Public-private partnership (P3) is associated with several alternative names.These allied names include: Private Finance Initiative (PFI) -a term originating in Britain, and now used in Japan and Malaysia; Private Participation in Infrastructure (PPI), -a term given by the World Bank; P3/3Ps, a term used in North America; Private-Sector Participation (PSP) -a term also used in the development-financing sector; and Privately-Financed Projects (PFP) a term used in Australia (Yescombe, 2007).

Historical Development of P3 in Nigeria and Ghana
P3 has become a viable alternative vehicle for the development and delivery of infrastructure projects and services.It is widely acknowledged that P3 is used by countries as a conduit for infrastructural provision to citizens through a conscious arrangement and agreement between the public and private enterprises.Owing to its current use and discussions globally, many think that P3 is novel and recent.El-gohary, Osman, and El-diraby ( 2006) stress that P3 is not entirely a new concept in infrastructure development.However, the use of P3 in infrastructural development could be traced historically to the concession arrangement, which is one of the forms of P3s.

Ghana's P3 History and Experience
P3 idea is not particularly new in Ghana owing to the active involvement of the private sector in public service delivery since the early 1990s (Osei-Kyei & Chan, 2017;Osei-Kyei, Chan, & Dansoh, 2017).Prior to the birth of P3 in Ghana, (Awortwi, 2004;Fuest & Haffner, 2007) it was observed that the government through the private sector had been keenly engaged in public service delivery especially in areas like energy, sanitation, telecom, water and sewage sectors.Unlike Nigeria, the inauguration of national policy guidelines in 2004 opened the doors for P3 to be a national policy (MOFEP, 2011).Nevertheless, the Ghanaian government has demonstrated great interest in the PPP concept, especially for construction projects since 2004 (MOFEP).However, the P3 policy suffered hitches and cannot be implemented completely, due to the absence of institutional structures and lack of skills and understanding by local practitioners (Chan & Dansoh, 2017).P3 ideology commenced operations in 2011 (Chan & Dansoh, 2017) with the revitalization of P3 new national policy in 2011 and the establishment of P3 unit known as Public Investment Division (PID) with an authority to assist and develop the institutional and regulatory framework for the implementation of the P3 policy (World Bank, 2011).

Nigeria's P3 History and Experience
In Nigeria, the decades of significant infrastructural gaps owing to underinvestment and poor maintenance in infrastructural assets that held back the country's development and economic growth (Dominic et al., 2015) was responsible for the choice of P3 in Nigeria.The P3 concept was embraced in Nigeria as an apparatus for the government to raise finances and provide public infrastructure and services needed by the citizens.In order to ensure a successful adoption of P3 framework, the Nigerian government made some concerted efforts in initiating instruments and structures that would help tackle the challenges confronting P3 practice in the country by passing the Infrastructure Concession Regulatory Commission Act (ICRCA) in 2005 and the subsequent establishment of Infrastructure Concession Regulatory Commission (ICRC) in 2008 (ICRC, 2009;Okwilagwe & Apostolakis, 2016).The Infrastructure Concession Regulatory Commission (ICRC) was inaugurated with a mandate to develop the guidelines, policies and procurement processes for P3 through a greater participation of the private sector in infrastructure provision and delivery.Accordingly, the National Policy on P3 through ICRC adopted the model to design, build, finance and operate (DBFO) and to use this new marriage of policy between the private sector and the government or its agencies for public infrastructure provision.Dominic et al. (2015) notes that remarkable concessions have taken place which the federal government and some of its establishments had acknowledged to be impressive.Nigerian government's adoption of P3 is based on its expectation that the private sector has the machinery to enhance efficiency, broaden access, and improve the quality of public services through participation in infrastructure development (National Policy on Public-Private Partnership).、

P3 Structures, Forms, and Models
P3 arrangements characterize the type or form P3 procurement can take when decisions on public-private partnerships are to be embarked on.P3 structures take different approaches; some are in the form of development of new "Greenfield" facilities and some to the operation or expansion of existing "Brownfield" assets (Jacobi, 2009).A distinguishing feature that differentiates Greenfield and Brownfield structures is that the former deals with building new infrastructure while the latter deals with existing projects.P3s pattern of public infrastructure procurement is based on the objectives of public-private collaboration.Dominic et al. (2015) stress that the objectives of the government determine not only the type of procurement practice to engage in but also the choice of P3 model to be selected.P3 models on the other hand can be seen as "special form of P3 arrangement aimed at implementing certain tasks or providing services (Zakharina et al., 2020).Some authors suggest that the classification of P3 can be based on the degree of risks that each of the parties in P3 arrangements is involved in.Public-private partnerships can be categorized into numerous ways depending on the level of involvement of the public and private sectors and the allocation of risks (Damjanovic, Minic & Milovanovic, 2017).
As a procurement device P3 can be classified into various forms (World Bank, 2020;Davies & Fairbrother, 2003) that include: • Management and lease contracts; • Concession agreements/contracts; • Greenfield projects; • Divestiture (sale of assets); and • Management and outsourcing contracts In the midst of the above P3 categorization, concession is the most generally discussed, applied, and adopted when decisions on public infrastructure procurement, development, and provisions are mentioned.Concession is the widely used and most developing and developed countries in Africa and Asia favour concession above joint venture P3 for majority of their developmental projects (Olatunji, Olawumi & Ogunsemi, 2016).Concession refers to the granting of exclusive rights by a government to a private entity to provide, operate and maintain an asset over a long period of time in accordance with performance requirements (Olatunji, Olawumi & Ogunsemi, 2016).Normally, the concession period is for 25-30 years after which operation of the facility reverts to the government.It is assumed that the concession period has given the private sector adequate time to recoup its investment, operating, and financing costs and its profit by a user fee (Ndonye, Anyika & Gongera, 2014).
However, the popularity concession arrangement enjoys over other P3 structures could probably be attributed to the spectrum of models it offers.Nevertheless, studies have shown that P3 concession can be highly beneficial to the government if the form of agreement between the parties is structured in such a manner that it encompasses private sector operation and maintenance of the asset/service over its contract period (CCPPP, 2007).

P3 Models
Public-private collaboration comes in different models.Once the decision on P3 adoption has been completed, it can assume several available models.These models or combinations of models present different roles, financing options and responsibilities to the partners (Opara, 2014).Sanda, Daniel, and Akande (2016) subsequently add that the spectrum of models is most often characterized by the degrees of participation and risks allocation between the public and the private partners.Some of the models have similar operations although with diverse nomenclatures.P3 models can be in any of the following forms: • Build-Operate-Transfer (BOT) • Build-Operate-Own (BOO) • Build-Lease-Transfer (BLT) • Build-Transfer-Operate (BTO) • Build-Own-Operate-Transfer (BOOT) • Build-Own-Operate-Remove (BOOR) • Build-Rehabilitate-Operate-Transfer (BROT) • Design-Build-Finance-Transfer (DBFT) • Design-Build-Finance-Operate (DBFO) • Design-Build-Finance (DBF) • Design-Build-Operate (DBO) • Design-Build-Finance-Operate-Manage (DBFOM) • Design-Construct-Manage-Finance (DCMF) • Lease-Renovate-Operate-Transfer (LROT) • Operate and Maintain (O&M) • Operate-Maintain/Manage (OMM) • Rental-Build-Operate (RBO) The above structure of P3 models can either be of Greenfield (new) or Brownfield (existing) projects.Greenfield projects naturally centre on design-build (DB) service accompanied with financing, operation, and maintenance bundled in for certain deal structures (Jacobi, 2009).The difference between the models is that while DBOM model excludes financing, DBFO as further expressed by Jacobi, demonstrates the extent the private sector assumes financial responsibilities in the project.The name that is applicable to a model is mostly dependent on the country of operation.
The ICRC, which is the Nigerian body that regulates P3 operation recommends that the model to be adopted by the government or its agencies in public infrastructure provision is Design, Build, Finance, and Operate (DBFO).
Similarly, Brownfield models are commonly in the form of an Operation and Maintenance (O & M) concession and long-term lease (Jacobi, 2009).

Data Collection
Lead by the existing published documents related to the objectives of this study, a systematic literature review was adopted in the collection and analysis of the required data.Thus, secondary data was used.This helped to situate the research in an existing body of work and to evaluate the objectives of the establishment of 3Ps in the two West African countries.The data sources included websites of the Infrastructure Concession Regulatory Commission (ICRC) of Nigeria, Ghana's Ministry of Finance and Economic Planning (MFEP), and the World Bank.The publications used were the Policy Guidelines for the implementation of Public-Private Partnerships in Ghana (2011), Infrastructural Concessions Regulatory Commission (ICRC, 2009), and the Public Private Partnership Act of Nigeria.Other relevant publications are listed in the reference section.A total number of 31 P3 projects of the Government of Ghana and 63 P3 projects of the Government of Nigeria were analyzed against the objectives of the P3 policies as spelled out by each of the two countries.

Data Analysis
Collected data were analyzed both quantitatively and qualitatively.By analyzing the data quantitatively, the number of projects started, completed, and the amount of investment in the P3s were evaluated.Measurement of the success of the projects was done by investigating the P3 policy initiation and implementation qualitatively to identify gaps and policy improvements for both countries.Gaps and policy improvements were determined by measuring how well the projects were able to meet the objectives for their implementations such as bridging of Infrastructural gaps-which is the main policy focus, Value for Money, International support Efficiency, and how both countries have handled challenges and constraints.

Findings
In this section the results obtained from the analyses of the collected data are presented.These findings seek to address the underlying objectives of this study.It addresses questions on the focus of the implementation of the P3s, whether there has been value for money, whether there has been international support, and whether there have been significant challenges and constraints in the P3 projects.These analyses were done for each of the two countries.

P3 Policy Focus
It was reported that one of the major developmental problems affecting the growth of the Nigerian economy is the huge deficit in basic infrastructure services particularly in the areas of energy and transportation.To address this infrastructure gap, and to unlock Nigeria's undoubted economic growth and developmental potential, the Federal Government of Nigeria (FGN) under the governance of former President Umaru Musa Yar'adua established the Infrastructure Concession Regulatory Commission (ICRC) in 2008 under the Infrastructure Concession Regulatory Commission Act (ICRC 2005), to monitor and regulate the Public-Private Partnership (P3) endeavors of the Federal Government.The findings from the study suggests that the scope of Nigeria's national policy on P3s was to create new infrastructure, and the expansion and/or refurbishment of existing assets.This revealed that the country's P3 policy was geared towards undertaking both Greenfield and Brownfield projects across various sectors of the economy.In an article published in 2009 by the ICRC, it was estimated that Nigeria requires about US$100 billion to meet its infrastructure deficit necessary for sustainable economic growth and development by the year 2020.The World Bank's snapshot of Infrastructure Finance, P3s, and Guarantees also reports that as of 2021 a total number of 62 P3 projects worth US$14.385 billion had been undertaken by the Federal Government of Nigeria with a majority of these projects falling under the Greenfield type of P3s.These projects covered a variety of sectors such as airports, electricity, ICT, natural gas, ports, railways, roads, and treatment/disposal.Several major P3 projects undertaken by the FGN include the construction of Gurara Hydro Power Plant, Tincan Island Multi-Services Container Terminal, Shiroro Hydro Electric Power Plant, Ajaohuta-Kaduna-Kano Gas Pipeline, Concession of Lagos-Ibadan Expressway, Concession of Nnamdi Azikiwe International Airport, Abuja, Concession of Murtala Muhammed International Airport, and the most recent one being the establishment of a new National Airline (Nigeria Air).

Value for Money
The ICRC's policy statement provided an overview of value for money (VFM) and how it relates to P3 projects in Nigeria.Thus, the achievement of Value for Money required that the project's cost and quality must be a critical component of the investment decision.This also involved the overall assessment of the long-term affordability of public services, and the need to quantify the wider economic, social, and environmental benefits that will accrue from the project (Opara, 2018).For instance, the 2009 annual report of ICRC indicated that the ICRC is expected to monitor the implementation of P3 arrangements to ensure that the desired service standards are attained and maintained, and that value for money is assured.However, the concept of Value for Money was not fully achieved taking into consideration the current happenings in the Nigerian economy.For example, the commission continued to engage in active dispute resolutions concerning the contractual agreement between Federal Aviation of Nigeria and Bi-Courtney Aviation Services for the Build Operate and Transfer (BOT) of Murtala Muhammed International Airport domestic airport terminal 2 in Lagos.Others included disputes arising from concessions of Lagos-Ibadan Expressway, Guto-Bagana Bridge Contract, Lekki Toll Road, and the Lagos International Trade Fair Complex.The dispute arising from the concession of Lagos-Ibadan Expressway even became dire considering the poor state of the road and complaints from users as reported regularly in the national dailies.During the year 2021 under review, conceited efforts were put in place to sensitize the Ministries, Departments and Agencies (MDAs) to establish a Special Concessions Accounts (SCA) to ensure that revenues accruing to government from P3 transactions are properly accounted for.

International Support
The designing, structuring, and implementing of P3s remains a challenging and complex endeavor in most developing countries (World Bank, 2015).Nigeria received significant international support (technical and financial) from various stakeholders to ensure the successful implementation of its P3s program.The Commission received support and assistance from the World Bank, UK's Department for International Development (DFID), African Development Bank, Agence Francais De Development (AFD), and Partnerships United Kingdom.For example, in 2010 the Commission in partnership with the World Bank developed a detailed set of P3 regulations and guidelines to ensure the development of a sound institutional framework for P3s in line with international best practices.Also, in 2011 Nigeria received an amount of US$315 million Adaptable Program Lending (APL) through the World Bank and International Development Association to support the ICRC in the development of a national P3 project.This loan facility covered key components including Capacity Building and Legal/Regulatory Reform, P3 Preparation and Transaction Advisory Support, P3 Project Implementation, Monitoring and Evaluation, and Infrastructure Financing in support of P3 transactions.It was also noted that the outlook for the P3 investment climate in Nigeria remained optimistic due to the continuous engagements between the International Finance Corporation (IFC), African Development Bank (ADB) and the ICRC in implementation of bankable P3 projects.

Challenges and Constraints
It was revealed that the ICRC had difficulties in ensuring the efficient discharge of its functions of continuous P3 projects monitoring and evaluation due to inadequate resources for project site visits.In the last three years, the Commission's budgetary allocation reduced consecutively while P3 projects were on the rise which limited the Commission's capacity to undertake physical monitoring of project sites.That is, the Commission's ability to monitor the progress of the federal government's P3 initiatives, ensure compliance and engage in dispute resolutions continued to be severely constrained.Also, Nigeria's P3 program faced challenges such as lack of continuity due to a sudden change in leadership and political interferences.

P3 Policy Focus
As has been the case with many developing countries, the Government of Ghana (GoG) has had a hard time building infrastructure and providing public services which has slowed the growth of the Ghanaian economy.This necessitated the Government to partner with private sector organizations through the Ministry of Finance and Economic Planning to bridge its infrastructure gap.In 2011, Ghana formalized its P3 arrangements and protocols via a P3 policy framework known as the Public Private Partnership Act.
Ghana had most of its infrastructural projects categorized under the Greenfield type of P3s with these projects cutting across various sectors of the economy.It was reported that Ghana had committed an amount of $9.993 billion to P3s since 1990 and a total of 31 projects have come out of this investment.Paramount among the active P3 investments is the Tema Port Extension project, Takoradi Integrated Container and Multi-Purpose Terminal Project, the upgrade of the current biometric passport system, the development of World Cocoa Centre Project, the development of hostel facilities and lecture hall complex at Ghana Communications Technology University, the Sakumono Ramsar Site Project, the Government of Ghana Affordable Housing Project among others.Ghana's P3 policy applied to all sectors and levels of government.According to the World Bank's Country Snapshot of Infrastructure Finance, P3s and Guarantees, among the 31 P3 projects undertaken by the Government of Ghana, 13 of them were under the Power (Electricity) sector, 8 were under the Information and Communication Technology sector, 4 were under the Transport (Port) sector, 3 were under the Water and Sewage sector, 1 under the Integrated MSW, 1 under Natural Gas, and 1 under Treatment/Disposal sector.

Value for Money
A key principle that guided all P3 arrangements in Ghana is the concept of Value for Money.In achieving this principle, the public sector was to ensure the planning and identifying of infrastructure and public service needs and overseeing the enforcement of the P3 agenda.The private sector was to effectively deliver the infrastructure and facilities required by the public sector and consumers.The Government was not left out in the bid process to ensure that there is Value for Money.It was to provide support by developing a range of instruments to support the project's preparation and financial viability among others.Overall, Ghana's P3 investment projects achieved Value for Money.For example, the construction of the Takoradi Inland Container Terminal and the Tema Terminal 3 Project has helped increase infrastructure availability in Ghana, and the subsequent surge in container traffic following the implementation of the project.

International Support
Ghana, just like Nigeria, received financial and technical support from various stakeholders to facilitate the learning, promotion, and implementation of its P3 agenda.The Government of Ghana collaborated with international partners and institutions to promote its P3 agenda and to provide information on Ghana's P3 policy framework.For instance, Ghana collaborated with the Economic Community of West Africa States (ECOWAS) to validate and approve its regional P3 policy and guidelines.Further, in April 2021 Ghana in collaboration with the United Nations Office for Project Services (UNOPS) and the University of Oxford developed Sustainable Development Goals (SDG)-related infrastructure projects.Furthermore, there has been ongoing engagement between the Government of Ghana and international agencies such as the World Bank aimed at building P3 capacity in the country.Ghana expected about US$3 billion in private sector Foreign Direct Investments (FDIs) and P3s between 2021 to 2023.

Challenges and Constraints
The findings of this study revealed that Ghana, just like Nigeria, faced a series of challenges in the implementation of its P3 program.In a study conducted on the implementation challenges of P3 in infrastructure development in Ghana, Baba (2021) found that the politicization of concessions and lack of continuity of P3 investment projects by successive governments impeded the successful implementation of P3 projects in Ghana.It was further stated that there is always a high tendency that the current P3 framework was subject to change by successive governments.That is, governments from different political backgrounds and ideologies become reluctant in continuing projects started by previous governments.For instance, numerous projects including the dualization of the Accra -Kumasi Highway, the Boankra Inland Terminal, the various Affordable Housing Projects, the Ameri Power Deal, and the Maternity and the Baby Unit building project, which was started in 1976 but has since been abandoned.

Discussion
The study demonstrates that the scope of Nigeria's P3 policy was geared towards undertaking both Greenfield and Brownfield projects, whereas Ghana had most of its infrastructure projects categorized under the Greenfield type of P3s.We also found that Nigeria's P3 policy witnessed several shortcomings in the form of active disputes concerning some contractual and concession agreements which undermined the principle of Value for Money.Ghana's P3 policy initiatives can be said to have achieved Value for Money.For instance, it was reported that the construction of the Takoradi Inland Container Terminal helped modernize the infrastructure of the port and increased efficiency.Another important finding was that the ICRC had challenges in the continuous monitoring and evaluation of P3 projects largely due to inadequate resources for project site visits, and the politicization of concessions and lack of continuity of P3 projects impeded the successful implementation of P3 projects in both countries.More broadly, our findings have important implications for investors, public policy managers, and practitioners as discussed below.
First, our findings suggest that fewer disputes arising from P3 contracts and/or concession agreements reflect high quality and the achievement of Value for Money.A typical example is a dispute arising from the concession of the Lagos-Ibadan Expressway which even became more critical considering the poor state of the road, and frequent complaints from road users.
Second, our findings on the difficulties in the continuous monitoring and evaluation of P3 projects by the ICRC in Nigeria due to inadequate resources which at least hint that the P3 policy outcomes of both countries were partly dependent on the implementation approach adopted.For instance, the Public Investment and Assets Division (PIAD) within Ghana's Ministry of Finance and Economic Planning was responsible for the efficient and effective development, implementation, and regulation of P3 infrastructure and services.In the case of Nigeria, the Infrastructure Concession Regulatory Commission (ICRC) was established in 2008 under the Infrastructure Concession Regulatory Commission Act (ICRC, 2005) to superintend and regulate the country's P3 endeavors.This means that the establishment of a completely new institution to take charge of Nigeria's P3 policy required a lot more resources as opposed to delegating its P3 policy development and implementation to an already existing institution.
Third, it is worth discussing these interesting facts revealed by the results of the politicization of concessions and the lack of continuity of P3 projects in both countries.This study suggests that the influence of political leadership was crucial in the successful implementation of P3s.These results tie well with recent studies by Opara and Rouse (2019) and Opara and Elloumi (2017) on the role of political leadership in fertilizing and catalyzing the emergence of P3s.The political environment has a significant influence on P3 project performance and permanence/continuity.It was further argued that strong political leadership support and a favorable policy environment for P3s are critical factors for the successful implementation of P3s (Opara et al., 2017).
Overall, this study contributes to P3 literature in two key aspects.First, this study emphasizes the importance of the invisible forces of the institutional environment to policy making and outcomes.When the underlying institutional environment is ignored in policy formulation and implementation, it is almost a recipe for policy failure as the mistakes of the past are repeated, resources are wasted, and the welfare of citizens are diminished.And this tends to follow a path dependence pattern (Opara et al., 2022).Being cognizant of the visible and invisible elements of the policy environment mitigates the risk of policy failure.
Second, is peer learning.This study highlights the relevance and applicability of peer learning in policy making and implementation at the country level.Peer learning helps policy makers to learn from the challenges that proximal countries may have encountered and how they were overcome.And this avoids the mistakes that were made thus leading to a better understanding of policy implications and outcomes (Topping et al., 2017;Topping, 2005).
This study also has some limitations.First, our study focuses on the extensive use of the systematic literature review methodology approach.Future studies may look at combining interviews with this approach to present a more comprehensive picture.Also, this comparative study is restricted geographically as it is conducted in a West African context.More studies of similar nature may investigate the relevance and applicability of P3s in other geographical regions.