Independent inquiry’s report will shape Sydney’s transport debate

It’s finally out – the interim report of the Independent Public Inquiry into Sydney’s public transport. 

The Inquiry’s report was prepared under the guidance of Mr Ron Christie, former NSW Coordinator General for Rail and former head of the RTA, who famously got the trains (and buses) to run on time during the 2000 Olympics. The inquiry was established and resourced by the Sydney Morning Herald, but was conducted on a completely independent basis. 

I felt honoured to be part of a team of transport advisers and planners who spent four months working with Mr Christie to develop the report, based on nearly 500 public submissions, meetings with key experts, detailed research into community attitudes and financial options, team members’ professional experience and expertise and, not surprisingly, robust debate within the team itself. 

I assisted in developing the governance section of the report. I also contributed to the overall debate, especially in raising social equity issues and the importance of looking at public transport provision in outer suburban areas, but the report is really a collaborative team effort. 

The result is a document which is far more comprehensive than any other transport planning initiative for Sydney I’ve seen in over a decade and which is also much more evidence-based than most transport plans. The report has six sections, starting off with what Sydneysiders actually said to the Inquiry about their own priorities for fixing the transport system, and perhaps more importantly the outcomes of an independent survey which clearly demonstrated their desire for change and willingness to pay for these improvements. 

Based on these responses, the rest of the 450-page report is divided into chapters on the long-term development of the transport network, fixing fares, short-term improvements, funding and finance and the chapter I contributed to, “Getting it done”. The recommendations based on these chapters are divided into nine, almost self-explanatory key themes, as follows: 

1. We have tried the ‘do nothing’ option for public transport. It has failed

2. We need a complete public transport network plan—and an agency that can deliver it

3. The three-legged stool: urban form, pricing and transport

4. Public transport, not just roads

5. A single, seamless public transport network

6. Cost-effectiveness

7. Short-term urgency and continuous improvement

8. Long-term commitment, now

9. Leadership and transparency for hard choices

I won’t try to summarise the report, because that has been done within the report itself as well as by the Sydney Morning Herald and by Mr Jarrett Walker, one of the team members. I would like however to talk about the two areas I was most involved in – governance, and the identification of transport priorities in Western Sydney. 

The governance section, “Getting it done”, was described by Mr Christie at the launch as being possibly the most important chapter in the interim report. To quote from the report: 

No matter how visionary a transport plan may be, it will succeed only if it is supported by a strong management structure committed to its long-term implementation.

This management structure, or “governance” system, must be:

  • Able to secure the resources required to deliver the infrastructure underpinning the plan
  • Strong enough to maintain a commitment to the plan in the face of short-­term political considerations
  • Able to manage the whole public transport system cohesively and with authority
  • Able to obtain enough funding to deliver a high level of services, and
  • Be prepared to champion public transport and other sustainable modes in the face of competing priorities and interests, such as the demands of private vehicles.

If the governance system is inadequate the public transport plan is most unlikely to be delivered. Critical infrastructure will not be built, services will be poorly integrated and the level of service provision will remain patchy and unreliable.

The governance section outlines the fragmented nature of Sydney’s current transport management. It compares this state of affairs to overseas and interstate experience, especially systems that operate successfully in places such as Perth, London, Singapore, Vancouver and Zurich. It also summarises proposals regarding governance expressed in many of the submissions received by the inquiry. 

The overwhelming conclusion is that to have any success in overcoming its current “silo” based management and ad hoc planning, Sydney must adopt a single new authority to plan, develop and manage all public transport in Sydney. This authority must be responsible for most activities relating to public transport provision, including: 

  •  long-term public transport planning
  • defining public transport fare structures and fare setting
  • implementing integrated fares and ticketing
  • specifying routes, timetables and minimum acceptable performance standards for transport operators
  • contracting for the provision of these services
  • providing network information
  • marketing and promotion of public transport services

The governance chapter also discusses the options for creating such an authority, including reforming the current structure or creating a new tier of governance (similar to the Mayor for London and the Portland Metro Council). It recommends a third option – the creation of an independent public transport coordination authority, called Transport for Sydney (TfS).

This body would undertake all the functions outlined above. The TfS would be managed by an independent Board with members from the State, Federal and local government and persons with experience in the transport sector, business, marketing and transport advocacy. A small secretariat, answerable to the Board, would manage Sydney’s transport through the following sections: 

  • Plan Process, responsible for developing and reviewing the Public Transport Network Plan for Sydney and conducting public consultations.
  • Infrastructure Development, responsible for the purchase (on a contestable basis) and project management of the design, construction and delivery of public transport infrastructure, plus the specification and setting of standards for all new rolling stock.
  • Operations, the core of TfS, which would be responsible for the development and sale of integrated journeys to the community and the coordinated purchase of these improved and expanded public transport services, on a contestable basis, from transport operators.
  • Budget and Government, responsible for financial management, funding negotiations and TfS’s relationships with State, Commonwealth and local governments in support of the Public Transport Network Plan.
Transport for Sydney governance model

Transport for Sydney governance model (click to see full size) from the Independent Public Inquiry interim report

The report goes on to discuss the relationships the proposed authority should have with state government agencies, the federal government and councils, as well as the role of an independent customer advocate and of consultation in the plan development process.

The Inquiry has proposed that the new authority prepare an initial plan for public comment and that subsequently drafts of the plan should be released nine months before every state election, thus providing additional scrutiny of the plan and the responses of the parties and politicians in the run-up to the election. As the report states: 

This four-yearly revision process, tied to the four-yearly electoral cycle, would present a major opportunity for the public, the government, the opposition political parties and individual electoral candidates to shape the policies and priorities of the transport authority.

The plan would then be finalised and adopted within 12 months of the election and would be protected by legislation against political interference outside of the plan adoption process outlined above.

The governance model proposed in the Inquiry’s interim report represents a clear break with the Sydney’s current complex and largely dysfunctional management processes. The primary intention is to greatly improve the planning and delivery of public transport in Sydney. In doing so, the model would remove many of the detailed aspects of transport administration from political control and interference, limiting the role of politicians to setting the broad directions of transport policy through the adoption of the four-year plan.

It is likely that this aspect of the proposed changes will meet the greatest political resistance, though, ironically, politicians stand to gain from being able to put day-to-day operational problems at arms length. Whether any or, ideally, all of the major parties have the courage to adopt the Transport for Sydney model remains to be seen.

In my next post I will look at Inquiry’s proposals for better public transport in Western Sydney.

Posted in Governance, Infrastructure, Planning, Public Transport, Sydney metro area, Transport | Tagged , , , , | 1 Comment

SMH publishes transport opinion piece

In late November last year, just before I left for Perth and then Paris, the Sydney Morning Herald published my opinion piece on Sydney’s current transport infrastructure saga.

The title the paper chose was: Three times denied: western Sydney misses out on transport, again – which pretty much summed up my core argument which was how Western Sydney continually misses out on new public transport inftrastructure despite its current and projected population growth. I made the point that whilst it was understandable that some of the schemes proposed by Bradfield for additional suburban railways were never built at the time, the failure to provide public transport to outer urban areas became less and less forgivable as the population expanded well beyond the harbour-focussed city of the 1930s.

I argued that in light of this neglect and the fact that Sydney’s population centre was now located near Ermington, the State Government’s current policy of prioritising inner-city metros and cancelling outer-suburban rail expansion was completely inappropriate. I pointed out that if the CBD metro goes ahead, more than $8 billion will have been allocated in less than two decades for new public transport projects in eastern Sydney ,which is eight times more than the amount allocated to Western Sydney projects.

After I submitted the article for publication (and just before it was actually published), the State Government has announced that construction will commence on the South West Rail Link after all. This does not however diminish the central points of my argument which are that Western Sydney is still not receiving its fair share of resources and that building the rest of the region’s transport infrastructure (for example the North West Rail Link and the Parramatta to Epping Link) should still receive priority over inner-city metros.

I’m pleased that my article, which can be found on the SMH website here, received a mostly-positive response judging from the feedback on the website and the comments made to me personally – and it will be interesting to see what happens after the State Government reviews its transport priorities and metro proposals yet again.

Posted in Growth, Infrastructure, Planning, Public Transport, Sydney metro area, Transport, Western Sydney | Tagged , , , | Leave a comment

Paris and peripheral cities

In December I was a participant in an international roundtable on peripheral cities held in Paris. This was part of a seminar organised by FALP (an acronym from the French for “Forum of Local Authorities of the Periphery”) in conjunction with the University Paris 8 at Saint Denis and the Plaine Commune, which is a regional organisation for eight municipalities of the northern periphery of Paris.

The seminar was organised in the run-up to the FALP and the United Cities and Local Governments (UCLG) “Peripheral Cities” second congress planned for 10-12 June 2010 in the Spanish city of Getafe. Within the framework of preparing for this conference, several seminars are being held in different countries. 

The FALP network was founded in 2003 by councils on the edges of large cities in Latin America and Europe. Today, over 150 local authorities from 22 countries participate, mainly still from Europe and Latin America, but also some from Africa and the Middle East. 

I understand I was invited to participate in the FALP Paris seminar on the basis of my work at the urban periphery through the Western Sydney Regional Organisation of Councils (WSROC) and I believe that I am the first Australian to participate in one of these forums. 

The overall theme of the Paris seminar was “suburbs as hearts and hubs for solidarity-driven cities” (I think it loses a little in translation). As the program noted: 

Cities are at the heart and hub of the 21st century’s key social, democratic and environmental challenges. The question is whether they should all simply fit into the same mould and embrace the competitive, market-shaped rationale, at the risk of deepening social exclusion, spatial fragmentation, environmental harm and democratic deficits.

My roundtable was on the theme: “A different development model: inclusive metropolises”. The program summarised this as:

The worldwide economic and financial crisis is challenging the predominant metropolitan development model today, and its limits are becoming palpable. So it is vital to shift the paradigm and focus on building fair and balanced cities that rank human and environmental concerns above merely economic factors.

 Whilst there was general agreement that outer urban areas are bearing the brunt of economic, social and cultural change, there was less consensus about the best policy responses – for example, do we develop decentralised centres at the fringe to offer suburban residents the same sorts of services that inner-city dwellers enjoy, or do we improve connectivity from the suburbs to the centre? There was also a strong emphasis on the rights of suburban residents and the importance of social housing, which receives much more attention and support in Europe than in Australia.

I’ll post a summary of my presentation shortly. If anyone is interested in attending the peripheral cities conference in Spain in June, please post a comment here or send an email to alex@goodingdavies.com.au

Paris at the periphery - a different view

Paris at the periphery - a different view

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SOAC addresses cities in Perth

In November the 2009 State of Australian Cities Conference brought together academics, researchers, planners and many others involved in urban design and management at the University of Western Australia in Perth to discuss the current status and direction of our cities.

After opening addresses by the WA minister for planning and the shadow minister for regional development, over 120 papers were presented across six themes: Economy, Environmental, Governance, Health, Infrastructure and Social. The presentations were diverse and occasionally controversial, but taken together they present a fascinating and detailed snapshot of the shape or cities are in.

My paper was titled: How the west was lost – the causes and consequences of under-investment in Western Sydney’s infrastructure and was, not surprisingly, in the infrastructure stream. It highlighted how unlike other Australian and overseas cities, Sydney had failed to reverse the post-war pattern of under-investment in rail infrastructure to deal with continued population growth, particularly in Western Sydney, whilst making significant expenditure in motorways.

The paper also discussed how factors such as the pattern of development of Sydney’s infrastructure prior to the 1950s, its post-war pattern of growth, the current political and economic environment and continuing resistance in some quarters to investment in public transport had contributed to this situation, as well as the potential consequences for Sydney’s future. A copy of the paper can be downloaded here and other conference papers should be available online shortly.

Perth skyline across the river

Perth skyline across the river

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Promoting good governance in China

In October I was fortunate to have the opportunity to address 150 local government officials in Beijing on the theme of building good governance at the local government level.

The attendees were staff of the Beijing Municipal Commissions for Development and reform. This meant that they had a wide range of backgrounds in areas such as policy development, local government reform, project management, performance monitoring and anti-corruption activities.

The conference room before the presentation ....

The conference room before the presentation ....

 At short notice I ended up presenting for four days straight, as my co-presenter had to withdraw at the last minute. It was an exhausting but fascinating experience; the presentations were demanding, especially as for the most part I was lecturing through an interpreter, non-simultaneously, with only limited opportunities for workshop sessions or questions.

When the questions did come they were very broad-ranging, covering areas from exactly how did the NSW Independent Commission Against Corruption catch corrupt local government officials, through to the impacts of the implementation of the Rudd Government’s code of ministerial conduct. Needless to say I was fortunate to have access to the internet in my accommodation to follow up on some of these queries!

The people I met seemed genuinely committed to achieving good governance and at least appeared receptive to the central message of my presentation – that in Australia, good governance and high ethical standards are the result of strong and independent public institutions, a free press and strong community input and expectations.

Thanks to the Trans Asian Education and Culture Association for arranging the presentation and for the care they took of me throughout the trip.

 

and during - things were kept very neat!

and during - things were kept very neat!

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Space-time gap

Apologies to anyone who is following these blogs – I’ve been off interstate and overseas, lecturing and speaking at a number of conferences, as well as having some time off. I know that is a poor excuse for not posting in an age of netbooks, wi-fi and 24/7 connectedness, but when you’re trying to think on your feet before an audience in a foreign country, keeping up to date with a blog comes a distant second!

 Anyway, I am resuming writing and providing some feedback from my travels, particularly through the Strategy Matters blog, so stay tuned.

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“Red Ken” looks outside the building

The former Mayor of London Ken Livingstone’s recent City of Sydney CityTalk address contained a strong argument for greater investment in education, infrastructure and sustainable transport to tackle climate change, but he made another  important comment on city management  in the Q&A session afterwards. As a result it did not appear in the published version of his talk and has therefore not received the attention it deserves. 

Livingstone was musing how his position as a popularly elected mayor contributed to his sweeping reforms of planning, public transport and other areas of service delivery in the UK capital. He noted that the extensive powers devolved by the UK government  in setting up the position certainly helped, but another key factor was the way in which the position had been structured. 

He observed that as a member of the British Labour Party he had spent most of his political life making deals “inside the building” as he put it, within the party room and caucus, both inevitable features of the Westminster system and very similar to their counterparts at the state and federal levels in Australia. 

Livingstone pointed out that the reinstated and radically reformed position – in effect the creation of a directly elected executive mayor – had forced him to look “outside the building” for the first time. 

He had been required to negotiate and build alliances directly with organisations and structures that were not necessarily part of the political system, as well as with the wider community, to build support for his policies. Livingstone concluded that this aspect of accountability contributed to making a directly-elected mayor an ideal city manager. 

The initial reaction among many in the audience after his address was admiration for the results Livingstone had achieved mixed with an almost-universal attitude of “obviously it’ll never happen here”. This is due to the remote prospect of any Australian state government creating a directly-elected metropolitan-wide position that could be seen as a competitor. 

However, Livingstone’s perspective is still food for thought. With the partial experience of Brisbane, no major Australian city has a single entity, elected or not, with sole responsibility for city management, in particular around key planning and transport issues. Most of the key decisions are still made not only within state governments, but firmly “inside the building”. 

The apparent success of Livingstone’s London “experiment” should make state governments and councils in Australia look outside their own buildings a bit more, to reassess their perspectives on urban management and consider experimenting with different forms of more direct and accountable metropolitan governance.

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Christie’s Sydney public transport inquiry hearings kick off

Well, it’s inevitable that the next few posts will be dominated by Sydney public transport and planning issues. On Tuesday the public hearings for the Sydney Morning Herald’s independent public inquiry headed by transport expert and former Director-General Ron Christie kicked off with a meeting in Castle Hill. 

It’s fitting that the hearings started in the north-west, an area that is starved of public transport and which also seems to be continually short-changed by governments. Around eight hearings are being held through September and October, leading up to the deadline for submissions to the inquiry on 8th October 2009. 

I would encourage everyone with an interest in Sydney’s future to attend a hearing and to make a submission. Ultimately the inquiry isn’t just about transport, but also and more importantly about how the decisions we make about transport will impact on the sort of future this city will have (go to http://www.transportpublicinquiry.com.au/ for more details about the hearings and the inquiry process). 

The Castle Hill meeting was well-attended and it was interesting how many of the audience had clearlyy read Garry Glazebrook’s  A 30-year public transport plan for Sydney, which is one of the references cited by the transport inquiry. This lead to a lot of questions regarding the respective virtues and deficiencies of metros, single-deck trains and double-deckers. 

Fortunately there was also a range of comments on other topics, including the importance of cross-regional transport between the northwest and the southwest, as well as the frustrations imposed by the almost complete lack of rail transport in the region. Not surprisingly this meant there was little feedback on issues such as the state of services on the current system, which will certainly feature more strongly in the hearings in those areas which actually have trains. 

I have just had a paper accepted for the State of Australian Cities conference to be held in Perth in November which looks at Sydney’s pattern of development and provision of public transport infrastructure – and the lack thereof in Western Sydney (click here for further information about the SOAC conference). I’ll talk a bit more about the issues I explore in this paper in future posts, as well as sharing some of the ideas I am thinking of raising in my submission to the inquiry.

Posted in Infrastructure, Planning, Public Transport, Sydney metro area, Transport, Western Sydney | Tagged , , , , | Leave a comment

Australian product provides new window on local economic performance

Melbourne-based firm .id (informed decisions) have just launched economy.id, an online economic profile to “describe, explore and promote” local economies.

economy.id joins the .id stable of profiles and other web-based programs, including profile.id, atlas.id, forecast.id and housing.id. .id’s main client base is local government, with over 180 councils and regional organisations of councils across Australia using one or more .id product. However the beneficiaries of economy.id and the company’s other products are not just councillors and local government staff, as most councils also make these products available online for local residents, businesses, community organisations and others to use (click here for an overview of .id’s products).

economy.id (which so far can be viewed for Penrith City Council in NSW, the City of Monash in Victoria and the City of Joondalup in WA) has a deceptively simple structure. It sets out to answer questions in two key sections called “our economy”, focused on economic characteristics and performance and “our resources”, which concentrates on profiling the resident workforce as well as the labour force and key local infrastructure.

econidcapture1The questions include, for example, “what is the size of the local economy?”, “how is the local economy performing?” and “what are the local labour force characteristics?”. These questions economy.id attempts to answer through a series of accessible tables, graphs and thematic maps – and whilst the focus is on the local, most tables and graphs provide comparisons to relevant metropolitan and state level benchmarks.

Like the company’s other products, economy.id is hosted on the .id server, but councils and other clients can customise the profile’s appearance, incorporating their logos and linking it to their own websites. This approach is consistent with .id’s other products and the company has largely succeeded in maintaining a similar look and feel.

This belies the complexity involved in putting together a local economic profile, which has required the integration of a wide variety of data, including information from the census, national accounts, and other ABS data sources, DEEWR small area labour markets data and input-output modelling from REMPLAN. The latter is particularly significant for councils, providing accessible input-output modelling at the local level.

All this means that economy.id moves well beyond the parameters of .id’s “flagship” product, profile.id, which is mainly based on census data. Not surprisingly the costs are also higher, with an up-front charge of $35,000 and an annual fee of $7,500, the latter covering hosting the profile, regular updating as new data becomes available and a comprehensive training program. However, as a council staffer pointed out at the NSW launch, economy.id has the potential to deliver significant savings to councils in financial and staff resources.

econidcapture2Until now, councils interested in researching and analysing local economic performance have had to commission either academic researchers or private consultancy firms, usually on a one-off basis. Invariably this approach is very expensive and whilst the results can be and often are of a high standard, this has not always been the case. In addition the data produced has usually been static in nature and difficult to update, with limited community access, especially online.

economy.id succeeds in addressing these issues. It also provides a more consistent and higher standard of economic data available for use within council (ensuring, for example, that all reports to council use the same economic parameters and even the same graphs and tables) and in promoting the local area for investment. This information will also put councils in a much better position when negotiating with state government, federal government and the private sector.

This is not to say that economy.id is perfect. Ideally, some modules such as local infrastructure will be fleshed out with more material in future. In addition, the issues noted in the supporting information regarding data sources and quality need to be considered carefully. Whilst economy.id may not meet everyone’s requirements for local economic analysis but it will go a long way by providing a baseline of the best available and up-to-date economic data in a consistent and accessible format.

Whilst councils need to decide whether this product will meet their local needs (and, as with all web-based products, should always assess the relevant Web 2.0 risk factors discussed here), economy.id has the potential to provide great value for money. It will allow councils and others using economic information to redirect their resources away from basic number-crunching, formatting and presentation to more strategic analysis of the results.

Ultimately it will also provide a great local community resource. Local communities, businesses and organisations may well be the major beneficiaries, especially if enough councils across the country or even within a particular region adopt economy.id as their standard for local economic profiling and make it publicly available through their websites.

Disclaimer: whilst the author has no current relationship with .id, he was once involved in commissioning the company to prepare a regional profile based on the 2006 census.

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Using mind mapping in strategic thinking and organisation management

Before I return to NSW growth, employment and infrastructure – and in case some of you are getting bored by these weighty matters – I thought I would make a brief diversion into the practical side of strategic thinking.

When we initiated this blog, we stated that we wanted to look at strategic thinking within organisations, as well as examining “big picture” strategic planning affecting the wider community. An important aspect of this is the use of new tools to assist in strategic planning and thinking, including project planning and organisation management.

One such tool is mind mapping software. Mind mapping has been around for a long time as a manual, pen-on-paper exercise. Wikipedia provides as good a definition as any:

“A mind map is a diagram used to represent words, ideas, tasks, or other items linked to and arranged around a central key word or idea. Mind maps are used to generate, visualize, structure, and classify ideas, and as an aid in study, organization, problem solving, decision making, and writing.”

Many organisations, consciously or otherwise, use a form of “manual” mind mapping when they hold brainstorming sessions to develop strategic plans, set up projects or respond to new opportunities or unexpected crises.

However there are often problems with the manual approach. Most of you will be familiar with the brainstorming process – a room full of people around a whiteboard or gathered in small groups with sheets of butcher’s paper, trying to capture the “big picture”. At the end of the forum, someone has the unenviable task of translating a set of indecipherable notes linked by a scrawl of lines and arrows into some sort of report.

The result often bears only a limited resemblance to the original session because the “tools of trade” such as whiteboards and butcher’s paper are inadequate to the task. In addition the linear structure of a written report is often too limited to properly present the big picture that everyone was seeking in the first place. And even if you do have a printout of the original whiteboard scribbling that is legible, it often becomes a static document, disconnected from the following implementation processes.

Mind mapping software presents an effective tool to overcome these limitations. There are dozens of mind mapping programs out there, but most work the same way, allowing a single user planning a project – or with the aid of a data projector and screen, a group of participants developing a major strategy – to add ideas as branches to a core concept. The software allows you to move these ideas around the resulting tree on screen, detaching them from one branch and attaching to another, and to add new ideas as sub-topics to these branches, as the following example shows:

mindjet_mindmanager_bp_brainstorming

 

Most programs will allow you to prioritise these topics and sub-topics, to format them in other ways and to add information such as deadlines, resources, document files and web links. These features point to what may be the greatest advantage of the software over the manual approach – the efficiency and flexibility of the documentation process.

All mind mapping programs can provide a simple, visual one-page map of a planning session. By themselves, these are often much more effective than a conventional report. However, these maps can also become effective “live” management documents which can be used as frameworks for implementing an organisation strategy or to manage a project.

Some programs feature extensive project management features to record and “roll-up” progress directly on mind maps and/or allow them to be synchronised with project management programs, as well as with Outlook and other office software. These maps can be used to as overarching project files to manage all resources associated with the project and to present progress on implementation at team meetings.

There are many different mind mapping programs and I don’t intend to review them all here. Virtually all companies provide free trials and some online Web 2.0 programs have feature-limited versions which are free on an ongoing period. There are also free, open source programs and many are also cross-platform. Some of the major programs are:

ConceptDraw MindMap

Commercial mind mapping program

Comapping

Freemind

Online program

Free open source program

iMindMap

Commercial program, endorsed by Tony Buzan, one of the key developers of the mind mapping concept

MindDomo

Online program with both free and charged accounts

MindGenius

Commercial mind mapping program

MindManager

Probably the most widely used commercial program

MindMapper

Commercial mind mapping program

MindMeister

Online commercial program with free account

MindView

Commercial mind mapping program

NovaMind

Commercial mind mapping program

PersonalBrain

Three-dimensional multi-centred commercial program

Visual Mind

Commercial mind mapping program

XMind

Free open source program with online accounts and commercial pro version

As well as strategic planning and project development, mind maps can be used for a wide range of other purposes, which I’ll discuss in a future post.

At Gooding Davies Consultancy we use MindManager extensively and can provide a range of strategic planning and program management solutions for your organisation based on this versatile program.

Posted in Local Government, Mind Mapping, NGO, Social Media, Web 2.0 | Tagged , , , , | 2 Comments