Professional Lobbying in Urban Planning: Publicity Management and Transparency Discourse on a Collision Course?

Abstract This article examines professional lobbying in urban planning and the related decision-making process, as perceived by lobbyists, planners, and politicians in Finland. The implications as to the transparency of planning are particularly discussed. Transparency is generally considered a key value of public governance under democratic control, while for professional lobbying a key asset is its ability to manage transparency and publicity. Examining lobbying in planning complements the picture of planning transparency, the deficiency of which has been identified as a problem of democracy. The prevailing transparency discourse appears to oppose the practices of publicity management, but does it produce only ostensible improvements to planning democracy? The emerging picture of planning transparency suggests that transparency, and thus democratic practices, play a smaller role in the legitimacy in planning than generally thought.


Introduction
In the field of urban planning and research, there has been a growing interest in lobbying (see e.g. Haughton & Allmendinger, 2016;L€ ahtinen et al., 2019;Lennon & Waldron, 2019), an activity intended to inform and influence legislation, regulation, government decisions and other public policy actions through communication with those who have power over these actions. In this article, the focus is on a less well-researched area: professional lobbying in urban planning performed by public affairs consultants (see e.g. Naurin, 2005). These consultants, also called contract lobbyists (Godwin et al., 2013; see also Drutman, 2015), work in communication agencies specialising in lobbying and political advocacy and operating on a for-profit basis. This activity is explored in the context of the Finnish planning system and local level decision-making.
In general, the research on lobbying tends to focus on national or European Union level politics (see e.g. Drutman, 2015;Godwin et al., 2013;Jaatinen, 1999;Kantola, 2016), leaving aside local level governance and political decision-making. However, professional lobbying is not uncommon at a local level either. Professional lobbyists can be engaged in promoting high profile development projects to local governments, administrative authorities, and citizens (Hirvola & M€ antysalo, 2019). Construction is a large industry sector, and, at the local level, the decisions concerning urban planning are among the most economically significant. Those involved in managing the built environment are likely to be of interest to lobbyists. Urban planning can be seen to play "a crucial role within the capitalist state apparatus" (McGuirk, 1995, p. 64). The approach to this sort of informal influencing in planning has been rather sceptical; it is argued that it leads to power imbalances between the general public and development interests (Fox-Rogers & Murphy, 2014;Hillier, 2000;McGuirk, 1995). Indeed, research focuses specifically on policy entrepreneurs consciously seeking to advance the overall shift of the planning system to favour a neoliberal direction (Haughton & Allmendinger, 2016;Lennon & Waldron, 2019). At the local level, in turn, the challenge is that interactions related to zoning decisions are considered to be particularly prone to corruption (Peurala & Muttilainen, 2015, pp. 29, 34-37;Salminen et al., 2012, p. 181; see also M€ antysalo, 2008). Against this background, lobbying indeed appears suspicious, not least due to its non-transparent practices (see e.g. Kantola, 2016).
In Finland, efforts are currently being made to add transparency to lobbying through a mandatory lobbying register, the "transparency register." The preparations for the register were begun in 2013 when Finland joined the International Open Government Partnership (OGP) and the Finnish Open Government project was launched to promote inclusion and dialogue in society and to strengthen Finland's international role as an active promoter of open government (Ministry of Finance, n.d.). Within the partnership programme, the government was committed to establishing a national lobbying register, which aimed to improve the transparency of decision-making and thereby prevent undue influence and reinforce public confidence (Ministry of Justice, 2021). Extending the register to the municipal level was not originally on the agenda, but the recent parliamentary steering group and working group report (Ministry of Justice, 2021, p. 11, 42) suggest this should be re-evaluated in the future when the monitoring data on the state-level register will be available.
While exploring professional lobbying, this article focuses on transparency, the lack of which has been identified as a problem of democracy in planning, especially in the early stages of the planning process (see e.g. Falleth et al., 2010;M€ antysalo & Nyman, 2001;M€ antysalo & Saglie, 2010), and the management of which can be considered a key asset for professional lobbying. While there may be several reasons for managing transparency (such as respect for privacy), we may rather speak of publicity management (Edwards, 2020) if it is primarily motivated by attempts to promote narrow, vested interests. The transparency register can also be seen to address this tension between transparency and publicity management, which to a great extent is parallel to the tension between democracy and lobbying.
Transparency is generally held as a basic principle of good governance, yet this article also offers a critical view of transparency requirements. A continuous drive for greater transparencya kind of "transparency discourse," within which transparency is considered as an end in itselfmay result in dissolution. The intentions behind this discourse are good, such as increased accountability, strengthened democracy and public confidence. However, when repeated like a mantra, the actual mechanisms to achieving these goals may become blurred. Transparency has been loaded with great expectations regarding the legitimacy of governance, but scholars have, to a degree, questioned whether it can deliver on its promises and whether it is always desirable (Chambers, 2004;de Fine Licht, 2014;Fenster, 2006;G€ otz & Marklund, 2015;Naurin, 2005Naurin, , 2007. Recently, also in the context of planning, attention has been paid to the ambiguity of the connection between the objectives and mechanisms of transparency (Marantz & Ulibarri, 2019). Now that the risks of lobbying and related non-transparency are being addressed by introducing control measures, it is also necessary to look at the current conditions, including the planning system, that we seek to protect against these risks by calling for more transparency.
In order to assess these risks, as well as the means to address them, it is crucial to identify the current state of planning transparency with its strengths and weaknesses. For this, first, the drive for greater transparency is examined in the Nordic and Finnish contexts, which is followed by discussion on its potential pitfalls. The professionalization of lobbying and the current lobbying regulation in Finland is then reviewed. Following this, the results of the empirical research are viewed to disclose how professional lobbying is perceived in the Finnish context of urban planning. In the empirics, three different perspectives are presented: those of (1) professional lobbyists, (2) local politicians and (3) urban planners. The results are then analysed from the point of view of transparency. The concluding section discusses the possibilities involved in the transparency register if extended to the municipal level. Furthermore, the results are discussed from the perspective of the legitimacy of planning in which transparency has a role.

The Demand for Greater Transparency and the Evolution of the Concept
There is an international trend in public administration towards openness and transparency, which are key values also in Finnish society, and an important area of administrative development at both national and local levels. It is generally accepted that transparency is a basic principle of good governance. Transparency promotes accountability as it allows public scrutiny of decision-making. Transparency and accountability are thus seen to safeguard a viable democracy. Furthermore, transparency is seen as an antidote to corruption and a precondition for citizen participation.
In planning literature, transparency and openness are appealing concepts; access to information produced by governments is considered the cornerstone of planning practice, providing accountability and inclusiveness (Marantz & Ulibarri, 2019). Over the years, the Finnish planning system, which is based on a municipal planning monopoly and strictly regulated hierarchy of binding land-use plans, has evolved in the direction of transparency and public dialogue (B€ acklund et al., 2018;Rantanen & Rajaniemi, 2020). The Finnish Land Use and Building Act (132/1999), which regulates zoning, includes provisions on informing, consultation, and participation, and is supposed to ensure the openness of communications in planning. It states that there must be an open provision of information on matters being processed ( §1). Planning procedures must be organized, and the principles, objectives, and possible alternatives of planning publicized, so that those who are affected by the plan or are otherwise interested parties, have the opportunity to participate in preparing the plan, estimate its impact and state their opinion on it ( §62). The launch of the planning process must be publicized, and later the plan proposal must be made available to the public, to ensure participation and access to information ( §63 and §65). Transparency can thus be assumed to be inherent in formal, statutory planning, which "rests on the values of a strong welfare state and democratic decision-making," as Rantanen and Rajaniemi (2020, p. 323) put it. However, they also state that these concepts have recently been reframed to some extent, and the underlying new narrative emphasizes flexible and dynamically evolving networks and a strong civil society as a provider of social well-being (Rantanen & Rajaniemi, 2020, p. 323).
Finland and other Nordic Countries are often considered forerunners in the transparency and openness of government (G€ otz & Marklund, 2015;Waldemarson, 2015). The Finnish Act on the Openness of Government Activities (621/1999) instructs that official documents are to be made public, unless otherwise specified, making openness a prevailing principle in Finland. Due to the early introduction of such legislation on public access to government information, also in other Nordic countries, 1 transparency of government can be considered a Nordic institutional feature (Erkkil€ a, 2020, p. 8), and a foundation for the concept of "Nordic openness" (Erkkil€ a, 2015(Erkkil€ a, , 2020. Nordic openness is also associated with the consensual tradition of governance, a high level of institutional trust and stable democracy (Erkkil€ a, 2015(Erkkil€ a, , 2020. Here, openness refers to the policy-making process being open to civil society, as represented by organized interest groups. This Nordic neo-corporatist openness involves a close relationship between the state and civil society (see e.g. G€ otz & Marklund, 2015). However, such relationships may appear too close, with representatives of civil society, political parties and public administration establishing less transparent links with other organized interests of society and business (Marklund, 2015, p. 247).
Finnish openness can be defined as "Nordic" in every sense. However, in recent decades, Nordic openness has gone through an evolution. Since the 1990s, openness and transparency have been associated with high-level national competitiveness and they have increasingly been seen as incentives for efficiency (Erkkil€ a, 2015). The new millennium has continued the discursive trend towards competitiveness and growth, and today transparency and openness are increasingly motivated by liberal economic considerations rather than political and democratic ones (Erkkil€ a, 2015). The accountability system is anticipated to change so that the outcome would weigh more than the process Erkkil€ a, 2015; Ker€ anen, 2014), and the new, economically-oriented drive for transparency would regard openness and public deliberation merely as elements of performance management in search for effectiveness (Erkkil€ a, 2015, p. 73). Such neoliberal economy-, efficiency-and effectiveness-driven transparency may not provide opportunities for citizen participation or control of government.

Pitfalls of Transparency
The demands for greater transparency and openness have reached a point where we can speak of the "norm of openness" (Vesa, 2016). The decision-makers are under pressure to open up decision making, and this is echoed in soapbox speeches (Vesa, 2016, pp. 33-35.). However, enthusiasm about openness does not necessarily correlate to actual openness. For example, the persistent self-image of the Nordic countries regarding their superiority in terms of openness may be delusive and lead to complacency and a disregard for new challenges (G€ otz & Marklund, 2015). Importantly, it has recently been suggested that in Finland transparency is insufficient at several levels and stages of the public decision-making process, and especially in the communication between lobbyists and decision-makers (Niinim€ aki, 2019, p. 6). More transparency is offered as a remedy. However, the exaggerated fuzz about transparency may lead to hasty solutions that eventually do not ensure better accountability or other virtues related to transparency. In fact, academic discussion involves voices critical of the promotion of transparency (see e.g. Chambers, 2004;Fenster, 2006;G€ otz & Marklund, 2015;Naurin, 2005Naurin, , 2007. For example, the principle of public access to government information may sometimes reduce the willingness of politicians to file information to public records. This can result in the problem of "empty archives," and the emergence of an oral or informal decision-making culture (Waldemarson, 2015). Contrary to the original intentions, this contributes to the opaqueness of political decision-making. Waldemarson particularly highlights the discussions preceding formal decision-making in this respect: Lacking information about rejected proposals, political alternatives, clashes of opinion, and tactical considerations, we are forced to draw conclusions solely from political decisions in their final form. We do not know the underlying causes of an outcome and are led to believe that the chosen path was somehow necessary and uncontested. (Waldemarson, 2015, pp. 174-175) Indeed, how often are we informed about rejected proposals -initiatives that do not proceed to a formal planning system? Moreover, freedom of information does not mean freedom of expression. That is, institutional transparency as access to information does not necessarily mean political openness. And yet, this kind of politically motivated transparency and opennessenvisioning alternatives and change (see Marklund, 2015) is of particular interest in urban planning, especially in terms of its input legitimacy (see Falleth et al., 2010, M€ antysalo & Saglie, 2010. Heald (2012, p. 35;see also 2006) also recognizes values competing with transparency: trust, autonomy, confidentiality, privacy, and anonymity, for example. The amount of transparency has been problematized, too. How much transparency is enough? Fenster (2006) surmises that there is no such amount, but there always remains a fear of secrecy that open government laws cannot dispel. Moreover, negotiation theorists think that transparency can, in some circumstances, even be harmful and inhibit exploratory and tentative discussions. Naurin (2005, p. 7) states that "if actors do not feel safe about speaking their minds, brainstorming, throwing different options on the table, creativity in the problem-solving process is dampened." This points to the preservation of confidentiality and quality of deliberation, as stressed by Chambers (2004).
In planning literature, transparency is rarely defined or operationalized, yet it is routinely called for by planning scholars (Marantz & Ulibarri, 2019). According to Marantz and Ulibarri (2019), transparency is often presented as an end in planning with no specific justifications. Elevating transparency to an intrinsic value is criticized (see e.g. de Fine Licht, 2014;Heald, 2006), but transparency as a tool for achieving other goals can be problematic as well. For example, more transparency may be proposed to enhance social welfare, but the mechanism or evidence for this is rarely presented (Marantz and Ulibarri, 2019, p. 4). De Fine Licht (2014, p. 16) stresses that the route from transparency to the goalsuch as accountability and civic engagement and, in the end, trust and legitimacyis not always clear. Indeed, the Finnish transparency register is supposed to reinforce public confidence (Ministry of Justice, 2021). However, public confidence is built to a great extent on other factors, such as a generous welfare state and small income disparities (B€ ack & Kestil€ a-Kekkonen, 2019), and the route from transparency to the goal remains vague. Importantly, Marantz and Ulibarri (2019) state that many transparency practices are not sufficient to achieve the goals, and, on the other hand, some practices are not necessary at all. This vagueness is, to some degree, caused by the "transparency discourse"; the demand for greater transparency being so dominant that critical voices are few. While a discourse allows certain views on certain topics, it limits or excludes alternative views. It determines us to organize our activities to match this discourse (Foucault, 1972;Hall, 1992, p. 291). 2 The rush to act according to the discourseto increase transparencymay therefore prevent us from recognizing the potential pitfalls and thereby avoiding them.
Transparency and openness are appealing concepts in planning but challenging ones for planning legislation. Despite the good intentions of the Finnish Land Use and Building Act (132/ 1999) regarding transparency and citizen participation, the problems related to the implementation of these objectives have long been recognized (M€ antysalo & Nyman, 2001;Hy€ otyl€ ainen, 2015). The Act has been argued to reflect neoliberal tendencies in urban policy and to provide instruments to strengthen the business perspective in planning (Hy€ otyl€ ainen, 2015). Here, there seems to be the kind of imprecise connection between transparency objectives and mechanisms as decribed by Marantz & Ulibarri (2019). A scheme, which covers participation and interaction procedures, "in good time" ( §63) is obligatory under the law. The problem here is that transparency only begins with the announcement of the initiation of planning proceedings. At this point, however, the municipality and the private actor may already have taken important decisions. The timing for participation and interaction is vaguely formulated, such that the law effectively allows for this (M€ antysalo & Nyman, 2001, pp. 54-55, 58). Similarly, for example, in the Norwegian planning system, there is an informal stage of zoning plan process which includes closed negotiations between market actors and the planning authority, and in which there are no requirements for proper transparency (Falleth et al., 2010, pp. 741, 747-748). Such practice is considered a problem of democracy since it does not offer a role for citizens or politicians and they may not know who to hold accountable for the initial agreements and negotiations (Falleth et al. 2010, pp. 741, 748;see also B€ acklund et al., 2018).
The perception of openness and transparency has shifted to a neoliberal direction, but when it comes to planning, the image of democracy-driven transparency and openness is being nurtured. The openness of planning, however, is likely to reflect the openness of government in general, whatever its status. Now the reform of the Finnish Land Use and Building Act is underway (Ministry of the Environment, n.d.)the legislative proposal is currently in consultationand transparency is again on the agenda. The discussion paper on the reform states that improving openness and transparency is a prerequisite for successful participation, and that information obtained through participation should be available at an early stage of planning (Ministry of the Environment, 2018, pp. 2, 10). However, the vague definition of the "early stage," to which M€ antysalo and Nyman (2001) refer, remains up in the air. Herein lies a potential risk of the vague connection between transparency objectives and mechanism.

Professionalization of Lobbying -The Industry in Flux
Professional lobbying is an evolving industry sector, yet lobbying per se can hardly be considered a new phenomenon (Kantola & Lounasmeri, 2014). Persuading a person or a group to take a favourable stand on the issue at hand by providing arguments supporting the desired outcome can be considered lobbying. It may involve communicating with the political decisionmakers and officials, the media, citizens, and stakeholders, or any other group relevant to the political process of a certain issue (Jaatinen, 1999, pp. 17-22, see also Drutman, 2015). Lobbying may also involve monitoring the given political situation and reacting and responding to unexpected situations. Lobbyists working for lobbying firms can be called communication and public relations consultants (Kantola, 2016) or external (or contract) lobbyists (Godwin et al., 2013; see also Drutman, 2015) or public affairs consultants (Naurin, 2005). Such lobbyists can facilitate a two-way flow of information between the client and the decision-makers (Hirvola & M€ antysalo, 2019). As the lobbying effort is often difficult to prove, communication between the decisionmaking, preparatory or executive body and a party with a decision-making interest (or its representative) is central to the definition of lobbying (Ministry of Justice, 2021).
Lobbying is a subject of controversy. It can be seen as a vital part of representative democracy and healthy decision-making (see. e.g. Jaatinen, 1999;Korkea-aho & Tiensuu, 2018;Niinim€ aki, 2019;Tusinski Berg, 2009); the right of citizens or interest groups to petition the government and provide information (Zorack, 1990, as cited in Tusinski Berg, 2009). Indeed, pursuing one's own or someone else's interest is not illegal, nor is contacting authorities restricted. This applies to planning, inter alia. However, influencing through informal networks providing access to a select few may create power imbalances to planning (Fox-Rogers & Murphy, 2014) and this sort of "policy entrepreneurialism" is suggested to contribute to "neoliberalization" and de-democratisation of planning (Lennon & Waldron, 2019). Indeed, the opacity of informal channels precludes broad public involvement. With informal channels available, the weight of formal channels provided by the Land Use and Building Act (132/1999) in Finland, and used especially by citizens, is likely to diminish. According to McGuirk, economically and politically strong development interests may have little need for formal participation channels due to the variety of informal ones, which they dominate (McGuirk, 1995, pp. 73-74). Hillier, too, anticipates that the formal "reasoned" public participation processes are only followed by those with no or low capacities of informal influence over decision-makers, whereas those with resources and capacities are likely to turn to informal means of influencing (Hillier, 2000, pp. 38-44).
The professionalization of lobbying has gone hand in hand with the spread of the so-called "promotional culture" (Davis, 2013;Kantola & Lounasmeri, 2014;Wernick, 1988). The term reflects the concern about the excessive influence exerted by market forces in all possible areas (Wernick, 1988, p. 182). Indeed, today, promotion is given a greater priority and more resources than ever before, and lobbyists are considered "promotional intermediaries" (Davis, 2013). As for planning, promotional culture may have broadened public communication by increasing the means and forums for feedback, dialogue and debate, thus leading to greater transparency. On the other hand, instead of being employed for publicity of communication, promotional activity may be used to control it: pursuing a positive "spin" requires selective and carefully orchestrated information release (Davis 2013, pp. 135-53;Marklund, 2015, p. 241). This refers to publicity management (Edwards, 2020;Yeung, 2005) rather than transparency and openness. According to Edwards (2020Edwards ( , p. 1545, engaging in publicity is making visible something that "one desires to be seen in a particular way in order to reap the benefits of that perception." The professionalization development of lobbying is likely to have its roots in the spread of the promotional culture and the trend towards outsourcing. The development leading to regulation varies from country to country, but a corruption scandal often gives it an impetus (Korkeaaho & Tiensuu, 2018, p. 2). The unethical practices have not been foreign to urban planning. In the past, cronyism, the practice of having a small political-economic elite favouring each other in making planning decisions, was not unusual in Finland. Actors in high positions used their influence and networks to circumvent the formal channels of decision-making to safeguard their and their cronies" interests. In Finland, these networks were often linked to irregularities and unethical behaviour in municipal decision-making and administration (Klami, 1982;Laine & Peltonen, 2003;M€ antysalo, 2008). More recently, similar kinds of activities within planning in Irelandthe widely known and tolerated "endemic and systemic corruption" (Fox-Rogers & Murphy, 2014, p. 8)led to the introduction of the world's strictest lobbying transparency legislation in 2015, and later a mandatory, public lobbying register covering local level governance. What is of particular interest in Ireland's Act is the rigorous approach to land-use and zoning. The Act defines that anyone who communicates on land-use and zoning issues is considered a lobbyist and therefore falls within the scope of the law. The Act further specifies that communication on personal matters, which generally does not count as lobbying, nevertheless counts as such if related to land-use and zoning (Korkea-aho & Tiensuu, 2018, pp. 54-56).
Currently, lobbying is being regulated in Finland through the legislative framework consisting of, for example, the Criminal Code (39/1889), the Administrative Procedure Act (434/2003) and the Act on the Openness of Government Activities (621/1999). The Nordic countries have a common position in this regard, as none of them yet has specific legislation on lobbying practices (Korkeaaho & Tiensuu, 2018, p. 24). The professionalization development of lobbying is seenfrom within the lobbying industry itselfas a positive development, tackling non-transparency and resulting in proper practices (Joos 2016). Such internal control and self-regulation, however, may not be sufficient as nothing is binding and no sanctions are imposed (Korkea-aho & Tiensuu, 2018, pp. 24-25; see also Niinim€ aki, 2019). Moreover, Kantola, having identified the narratives through which communication and PR consultants legitimize their professionalism in political advocacy, claims that the consultants seek to foster the idea of professional lobbying as open and transparent, while, in practice, they tend to operate in a hidden and non-transparent manner (Kantola, 2016, pp. 34-35, 49). She criticizes the consultants" ambiguous role as in-between professionals by stating that it results in "a mixture in which the high principles of transparency and the hidden practices of political advocacy are at odds" (Kantola, 2016, p. 49). Calls for greater transparency are growing, and specific legislation is now being prepared in Finland. As for professional lobbying consultation, the parliamentary steering group and working group report (Ministry of Justice, 2021, p. 18) propose that lobbyists should register and disclose the business name and contact details of their clients, the entities contacted on behalf of the clients and the interests of these contacts. Further, the report proposes that an estimation of the resources used for lobbying activities should be provided on a yearly basis.

Data and Methods
The empirical research consists of an interview study involving altogether 17 semi-structured interviews. Five politicians, six lobbyists and six planners in Helsinki were interviewed in 2017-2019. The interviewees were selected to obtain a comprehensive and balanced picture of the rather ambiguous phenomenon of lobbying. The research focused on the City of Helsinki, since professional lobbying at the municipal level by public affairs consultants was presumed most likely to occur in large cities. The public affairs consultants (L1, L2, L3, L4, L5 and L6) interviewed in the study were selected to represent the main lobbying agencies. They all worked as consultants "in the field," although they were also partners, CEOs or directors in their agencies. The politicians interviewed (P1, P2, P3, P4 and P5) represented a range of political backgrounds, and were all either current or former political group leaders within Helsinki City Council. In addition, they all had other relevant roles, such as member, chair or vice-chair of the City Board or the City Planning Committee. The urban planners interviewed (U1, U2, U3, U4, U5 and U6) were public officials or senior public officials in the Urban Environment Division of the City of Helsinki. Their expertise ranged from detailed planning to general planning and land property development, and their administrative status ranged from junior executive to senior. The interviews were recorded with the consent of the interviewees and transcribed afterwards. The anonymity of the interviewees was guaranteed to allow them to speak freely and sincerely, as the subject of the study can be considered sensitive, covering themes such as influencing and being influenced.
As professional lobbying in planning is a rather new phenomenon with no established terminology, the approach of the hermeneutic cycle was applied, and the preceding stages of the research influenced the following ones. The analysis was guided by the predefined themes and the themes that surfaced during the interviews. The multi-actor approach, consisting of three different perspectivespoliticians, lobbyists and planners, enabled a balanced view of professional lobbying in the context of urban planning in Helsinki.
As for the limitations of the study, no direct generalisations can be drawn, due to the context-specific nature of the subject and the small although varied sample of the interviewees. Therefore, rather than attempting to provide an all-encompassing review of professional lobbying in planning, this study aims at increasing understanding of the phenomenon and its relationship to transparency.

Results: Three Perspectives on Professional Lobbying
This section presents the empirical findings that illuminate professional lobbying in urban planning: what it is like, how it is perceived and how it affects the principle of transparency. The results confirm that professional lobbying does occur within the local governance of Helsinki, and planning is not free from it. All the politicians and planners interviewed had at least some experiences or observations of it. Some of them could immediately identify several urban planning cases in which they thought professional lobbying had occurred. This section proceeds by first presenting the public affairs consultants" accounts of their typical tasks and ways of working and their urban planning related cases. Next, it focuses on the experiences and observations of politicians before concentrating on those of planners.

Professional Lobbying -Public Affairs Consultants" Interpretations
The tasks of the public affairs consultants were identified from the interviews. They were, in part, overlapping and interconnected and they could probably have been categorized differently. Here, the aim was to present the tasks with sufficient detail to ensure that the individual tasks appear correctly in relation to each other and to avoid any of them being overemphasized. The following categories were identified: (1) acting as an interpreter of the processes, (2) communicating and formulating the key message, (3) providing networks and contacts, (4) situation mapping, (5) influencing the framework conditions in which the client operates, and (6) providing an extra pair of hands and brainstorming. The first four were more or less explicitly mentioned by all six interviewees, the fifth one by four, and the sixth one by two.
Influencing the framework conditions (reported by L1, L4, L5 and L6) refers to making them as favourable as possible for the client's operations. Often this operating environment is a result of a democratic decision-making process. Thus, all the interviewees identified an "interpreter of processes" as one of their roles. According to them, a consultant is expected to be able to identify the changes in the operating environment and know the actual arenas of decision-making, which may not be the formal ones. As for the effectiveness of lobbying in development projects, the interviewees agreed that the earlier lobbying is started, the better: No decisions are taken at the committee meetings or council meetings, even if, juridically, it seems that that decision is made there. The actual decision-making stage is prior to those meetings, the preparation by officials as well as the stage of taking political stands … (L1) This points to the ambiguity regarding transparency of decision-making in general, not just that of lobbying. The publicity strategy was seen as necessary in some cases: it can create public pressure on the decision-maker to take up the issue. In general, however, the aim seems to be to carry out the issue as quietly as possible: The issue becoming public usually makes things complex and more difficult to deal with, since the immense media publicity awakens the civil society at large to discuss about it. And that's when both proponents and opponents tend to wake up. And that makes it a lot more difficult to handle. (L1) It became clear that their job is to sincerely consider how the client's interest is optimally taken forward (L1).
In practice, the concrete measures may include giving advice on avoiding risks and finding new opportunities to gain competitive advantage over those operating in the same field. This requires dialogue: many consultants see themselves as intermediaries between the private and public sector. The importance of networks was thus recognized by all the interviewed consultants: those potentially influential with respect to the issue need to be identified, and they may be different than expected: There's the official way Finland works, and then there's the unofficial way. (L2) Hence, the official title of a person may not matter; not all the strong players are shown in the organization chart of the municipality. Finland is a country with a low hierarchy: an individual can quite easily access the powerful in decision-making and there is no need to buy contacts (L6). Most interviewees (L1, L2, L3, L5, L6) nevertheless recognized that communication is vital, and simply delivering information is not sufficient. Communication involves identifying and formulating the key message and conveying it to the decision-makers who rarely are specialists in the issue being lobbied. For example, the members of the Urban Environment Committee of the City of Helsinki have no particular links to urban planning except for personal interest. Therefore, the information considering a development project is formulated in a way that a busy decision-maker can quickly digest it (L1). Furthermore, one must be able to craft a tailored message to suit the specific target group, as described here: … in a way, the message was true, but it was told in different way to different parties, and it was linked to their particular goals and aspirations. And this is key: not that you go and tell what you consider important to you and your business, but rather, you reflect on the issue from the point of view of the decision-maker; why s/he should take the issue to his/her own agenda. (L2) This kind of simplification and "selling the idea" in tailored packages, which can involve omitting unfavourable information, was met with mixed reactions among the politicians interviewed.

Professional Lobbying -Politicians" Experiences and Perceptions
The politicians interviewed were all quite well aware of the different tasks lobbyists may have, and lobbying was considered to occur quite frequently. All the interviewees reported having been contacted by lobbyists about development projects. In some cases, it remained unclear to them whether lobbyists had been involved or not. The interviewees reported on phone calls and e-mails and invitations to events such as discussions, workshops or briefings, to which four out of five had participated (P1, P2, P3, P5). One-on-one meetings and meetings involving several councillors were mentioned. The purpose had been to promote the client's project by providing information, or to inquire about personal or group stands regarding urban planning cases. Two (P1, P4) mentioned having been asked about how a certain project is proceeding in the administrative or political procedure: It is often such that they ask what you think about it [the planning project lobbied], how your group finds it, or how you think the city planning committee might be dealing with it, and what kind of things should be emphasized, in order for the project to be properly understood and viewed positively. (P4) The general perception among politicians was that these services are used when a private actor/developer has a huge financial interest. The voting decisions of the city council were recognized as potentially having enormous effects: Of course, those developers wanted to build only small, best-selling apartments. It was incredible that suddenly a vote in the city board or in some committee could lead to a million euros being passed on to someone when the rules were suddenly removed. Relying on whatever the justification. Just a simple vote. (P1) It seems that there are always actors willing to seize the opportunity, since politics is not always predictable, and changes are possible. All the politicians interviewed admitted that, in some respects, professional lobbying has an effect, however, it may also be negative: constant contact causes frustration and may make the politician take a negative view of the issue (P3). All politicians had also noticed lobbying through the media, not necessarily in a positive sense: And media plays an important role here. That is, media publishes imaginary pictures and illustrative sketches of nearly anything, spa or park or whatever the project … There is no architectural plan, nothing, but you can draw any sort of a starfish to describe the shape of the building and to create impressions for people. (P1) The attitudes towards the phenomenon varied among politicians, to a great extent. Professional lobbying in development projects was not further problematized by three politicians interviewed (P2, P4, P5). Some compared it to lobbying performed by NGOs. Others found that there is a huge difference, and that professional lobbyists are absolutely not on the same footing as other lobbyists because of the money involved. In general, those leaning politically to the left were more critical whereas those leaning to the right were more positive. Some emphasized the need for this kind of dialogue: In a way, I find it really, really important that there is societal dialogue, and the various actors understand each other's activities. And as a decision maker … You know, there are many cases where my own understanding would have been utterly insufficient without professional lobbyingwhether there is NGO or civil society or anyone behind it. (P2) Others had serious doubts about lobbyists' underlying motives and the possible hidden agendas: The thing is, in my opinion, that it is always somehow obscure what the real interests and ethos are behind. You know, it's always strangely concealed. (P3) It was speculated that such big money advisory services may distort democracy (P1, P3). Two politicians (P1, P5) saw that there is a danger that professional lobbying will become a shortcut to political decision-making, and that eventually actors are forced to use these services to get anything done. The interviewees were concerned about such practices becoming commonplace: The City of Helsinki treats all the actors equallythis has to do with the accountability and attractiveness of the city toohowever, if this situation can now be eroded by public affairs consultancy and money, we will lose what is good and characteristically Nordic. (P1) Two interviewees were more worried about the lack of time when it comes to examining all the facts and aspects thoroughly for balanced decision-making (P2, P5). Because of time constraints there is a real risk that only the loudest voicestrengthened by glossy brochures or marketing campaignsis heard (P1, P2, P4). To conclude, lobbying was regarded negatively by some because it was considered distressing and burdensome, it was considered non-transparent, and the idea that influence could be bought was found troubling due to concerns about a possible power imbalance. However, these concerns were not yet seen as acute but as potential future problems.

Professional Lobbying -Planners" Experiences and Perceptions
The planners interviewed had less experience of explicit persuasive activity but a lot of experience of interaction with private sector actors involving exploratory dialogue and situation mapping, which is typical of professional lobbying. Three out of six planners (U3, U4, U5) did not report on promotion by public affairs consultants. However, three (U1, U2, U6) had diverging experiences: Well, in a way, I have a wide variety of experiences. One example is the preparation of a new master plan for Helsinki and all the steps involved … And there was a great deal of such public affairs activity as well. At different stages, from vision to acceptance of a proposal in the city council. (U1) The same interviewee also confirmed that professional lobbying is a channel for communication when it comes to development projects (U1). Also, it was reported that the Urban Environment Division of the City of Helsinki has itself purchased services from public affairs consultancies to communicate its own projects to developers, investors and future residents. The main aim has been to brand the projects and gain acceptance from the public (U1, U6). Many plannerseven if they had no personal experiencehad seen an actor seeking support for the project initiative from politics or publicity. This was considered acceptable -"they have every right to do that" (U2)even though it was not considered "standard" practice.
Even though this kind of persuasive activity and promotion was not widely experienced by planners themselves, most of them (U1, U3, U4, U5, U6) nevertheless recognized the kind of exploratory dialogue, which often preceded private development initiatives. This interaction includes general mapping of the urban planning situation of the city: What are the current and future intentions of the city regarding services, housing and workplaces as well as traffic and densification of the urban structure? And vice versa: What are the intentions of private actors, developers and companies regarding their needs for property development, new premises etc.?
The point here is that each side is informed about the other (U2). This kind of continuous interaction was considered commonplace and useful by planners. Most planners recognized that a professional lobbyist may have a role in the stage where the initial assessment of the project's viability is made. Then again, this sounding out is much more often operated by actors themselves, and whether there are professional lobbyists involved, providing advisory services in the background, is not necessarily visible to planners.
Like politicians, all the planners interviewed saw that professional lobbying may have an impact, but some found that it may also be negative (U2, U6), and cause the planner to take a cautious stance on the issue. In general, however, interaction was considered rather welcome; "something that is supposed to affect planning" (U1). Continuous dialogue with the largest retail chains was also mentioned as an example (U3). One interviewee explained: Yes, it probably can have an influence. Within a certain framework. But it doesn't get through … Through lobbying you can't win acceptance for bad solutions. But yes, it must have influence. That someone pursues some interest from a certain viewpoint, and if it's not overriding public interest, then, then … … why not? In my opinion, it's pretty normal influencing. But nothing like heavy pressure. That's something we haven't yet experienced. Indeed, none whatsoever. (U4) Some planners showed understanding for the non-transparency of these tentative discussions. They seemed to recognize the private actors' vulnerability in this stage. This might be due to competition: actors want to protect their ideas (U2, U6). Also, they may want to come to publicity only when they are quite confident about the project proceeding: they do not want to appear as "losers" in the public eye (U2). In addition, postponing publicity may be due to trade secrets or the avoidance of reputational damage that are related to the financial and other risks the private actor is taking (U6). As for publicity at the very early stage, one interviewee found that it can be a serious disservice to many: That's not really in anyone's best interest. Or at least I don't see that it could serve anyone. As for those projects, they're not certain yet, they are discussed. At that stage, it is about mapping whether it is even possible. And yes, such a discussion must be enabled. (U6) To conclude, lobbying, as experienced by planners, is not so much about pushing projects through by dubious means, but rather about interaction and preparing for the future by identifying different alternatives. The purpose of the meetings and negotiations was to find a mutually agreed concept to proceed with, sometimes behind closed doors. Whilst planners are not immune to informal influencing, it is, however, part of their job to deal with it. Planners did not seem to notice much difference between professional lobbying and other kinds of influencing. They stressed that they have no obligation to accept everything; the project must be in line with the objectives of the city (U4, U6). According to planners themselves, it is their professional responsibility to bring out their own professional views, regardless of the influence exercised.

Analysis: Publicity Management Meets Transparency Discourse
In this study, attitudes towards professional lobbying varied. Plannersperhaps unexpectedlytook this kind of interaction mainly as everyday dialogue. This section offers an interpretation for this by suggesting that planners" attitudes reflect their views on transparency in planning in a more general manner.
The opacity of this kind of informal influencing was sometimes associated by politicians with secrecy and hidden agendas. The lobbyists, however, explained the lack of transparency with the nature of the industry. Hidden practices were considered part of the business: If it is in the client's interest to stay out of publicity, then this is the way to go. Market logic obviously does not encourage greater transparency, since the benefits of non-transparency often seem to outweigh it. Kantola (2016) states that these mediating professionals operate under the tension of facing both high principles of transparency and hidden practices of political advocacy. However, given that public affairs consulting is business, it is hardly surprising that whilst the logic of democracy and the logic of the market are at odds, the latter nevertheless dominates.
While among the politicians the attitudes varied, and the two extremes emergedboth very suspicious and very positiveamong the planners the attitudes were rather neutral. At worst, they found lobbying irritating, but not democracy-threatening. Nor did they particularly call for more transparency. For them this sort of activity appeared as rather normal interaction. The commercial logic explains the lobbyists" view of non-transparency, but what would explain that of the planners? Based on this study, planners have certain reservations, and they stay vigilant about possible hidden agendas. Furthermore, the irritation caused by promotional practices may even increase this vigilance. Despite the irritation, they seemed to recognize the delicate nature of the early stage of the development project when nothing has yet been decided and both the private actor and the city need to take risks. This sort of initial non-transparency and publicity management (Edwards, 2020;Yeung, 2005) was considered reasonable to a degree. In the vein of negotiation theorists (e.g. Naurin, 2005Naurin, , 2007, the planners seemed to acknowledge the situational need for mutual trust that allows private actors to juggle their ideas and options and speak freely without the risk of losing face or the risk of others stealing their business ideas. As stated above, promotional practices can be used selectively to achieve the desired outcome. Planners, too, may do so. Aspects unfavourable to the smooth progress of the project may be omitted. Planners, too, control the information flow and may have a desire to restrict publicity for fear of resident opposition (Puustinen, 2006, pp. 168, 318). This study, in turn, shows that planning authorities sometimes purchase services from public affairs consultancies to communicate about city projects. Public approval keeps the protests to a minimum, allowing projects to proceed smoothly without getting bogged down in lengthy appeal processes. Thus, not only lobbyists and private actors use promotional practices, but also city authorities. It is evident that promotional culture (Davis, 2013;Kantola & Lounasmeri, 2014;Wernick, 1988) has indeed entered urban planning, and publicity management is hardly anything new there.
Furthermore, the attitude of planners can be interpreted as an indication of increased competition and the normalization of the role and significance of market forces in planning. Without the opportunity for tentative discussions in the climate of mutual trust, the actors may go elsewhere with their ideas. However, herein lies a risk that planners will be tempted to attract private developers with terms that are too loose, unless there is transparency to ensure accountability. The urgent need to attract development investment can be a driver for evolution where planning becomes essentially facilitative of the demands of capital (McGuirk, 1995, p. 74). Based on this study, planners find informal pre-application negotiations with developers to be part of their work: they are obliged to give advice. Indeed, planners' institutional position authorize them to negotiate with market actors (Falleth et al., 2010, p. 741, see also Puustinen, 2006). According to planners in this study, their professional liability and integrity guide their work, whether the negotiations are open or closed. Is the vigilance of planners sufficient to prevent power imbalances in planning, given that such negotiations can be considered as strong evidence of the informal leverage of development interests (McGuirk, 1995, p. 67), and planners are considered to be in a relatively powerless position to challenge them? (Fox-Rogers & Murphy, 2014, p. 18).
Planners' attitudes towards lobbying and the related lack of transparency may reflect the neoliberal reality of urban planning and how planners deal with it. Perhaps this also applies to their reservations towards transparency discourse and the tacit acceptance of the status quo regarding planners' jurisdiction and legitimacy of planning. Even without professional lobbying with promotional practices and publicity management, there are non-transparent, closed decision-making situations within urban planning. Despite the prevailing transparency discourse in public administration, no significant changes seem to occur in planning.

Conclusions and Discussion
While this study has drawn a rather undramatic picture of lobbying in planning in Finlandno unethical behaviour was revealed but rather a "pretty normal influencing"it has nevertheless revealed interesting aspects related to the transparency of planning. As power imbalances are linked to informal, non-transparent influencing in planning (Fox-Rogers & Murphy, 2014;Hillier, 2000;McGuirk, 1995), this section discusses whether and how they could be tackled by increasing transparency. Finally, the results of this study are discussed from the perspective of the legitimacy of planning in which transparency has a role.
Public planning seeks to adhere to the principle of equality in the treatment of private actors with development interests and at the same time to ensure the public interest. The principle of publicity contributes to safeguarding this objective. Informal influencing is seen as posing challenges for the successful performance of this task and creating power imbalances (Fox-Rogers and Murphy, 2014). Lobbying performed by consultants further adds to this concern as it introduces elements from the business world, such as professional publicity management and profit-making. The Finnish transparency register should be of help here. It will be aimed at tackling undue influence and reinforcing public confidence by improving the transparency of decision-making (Ministry of Justice, 2021). However, it is not altogether clear that these objectives will be achieved. As previously said, public confidence is built to a great extent on other factors than transparency (B€ ack & Kestil€ a-Kekkonen, 2019). As for inappropriate influence, the register might be of help. Yet the power imbalance causing concern in planning does not necessarily arise from undue influence, at least in Finland. Rather, it is likely to arise from differences in the capabilities and channels available to different actors; they are not inappropriate as such, and transparency does not directly redress this imbalance. The register, if extended to the local level, could nevertheless contribute to making these differences visible to decision-makers, helping them to take power imbalances into account. Furthermore, being aware of lobbying and promotional practices helps the decision-makers to weigh up the information and not only hearing those with the loudest voices. In the context of planning, this could enhance the equal treatment of private actors with development interests.
The value of transparency lies, not only in the fight against undue influence, power imbalance and controlling those in power, but also in creating opportunities for participation. Professional lobbying can be considered "stakeholder participation." However, it often occurs in the initial stage before formal planning begins, which excludes others, potentially affected by planning and willing to participate. There is no access for the public to this stage, and it cannot be found in the planning process chart. Yet, it is at this stage that lobbying, or any influencing is likely to be most effective.
Careful consideration should be given as to whether the desired transparency can meet the expectations placed on it. Within transparency discourse, transparency may be pursued "blindly" without determining its exact goal. However, if legislation, on both planning and lobbying practices, is carefully formulated and avoids the pitfalls of transparency, it is possible to establish a precise connection between the desired objectives and the chosen mechanisms and to establish practices that support democracy-oriented transparency. Examination of the system and those responsible for decision-making prevents those who perform influence being given too much weight in assessing the possible risks of lobbying. As promotional practices seem to be pervasive in every facet of social life, planning included, it is the planning system that needs to support transparency and openness. At present, the lack of structure of the pre-application negotiations in the Finnish planning system impedes attempts to control promotional practices. M€ antysalo and Nyman (2001, p. 57) pose a question whether these negotiations are part of planning procedure or not. They do not seem to be, and this has implications for the presumed legitimacy of planning.
As for planning democracy, transparency can be considered a precondition for civic engagement. The planners' acceptance of non-transparency can indicate that planners do not consider transparency to play that big a role in planning. It is true that public planning is not subject to public debate and decision-making in its entirety. The question is, how much weight do the democratic practices hold in the overall legitimacy of public planning? Transparency discourse may have, in part, blurred the limits of the democratic legitimacy of planning. The status of the initial stage, prior to formal planning, is an indication of this. Not only is it non-transparent but it is almost as if it does not exist since it is excluded from the process chart of formal planning. By defining the planning process to begin only after the negotiations, a crucial phase can be ignored to streamline the procedure (M€ antysalo & Nyman, 2001, p. 58-59). Furthermore, by excluding this phase from what is considered "planning," one can maintain the impression that planning is more democratic and transparent than it actually is. The transparency requirements seem to be metall the phases are transparenthowever, there is some intellectual dishonesty. Conversely, defining the initial phase to fall within the scope of public planning, while at the same time keeping it out of the public eye would be a strongand unexpected, given the prevailing transparency discourseindication of the limitation of democratic practices in planning, but at least it would be honest.
In addition to drawing a picture of professional lobbying in planning, the results of this study have shed light on the actual boundaries of the democratic legitimacy of planning in Finland. If the status quo in planning is to be maintainedthat is, not advancing the transparency of the initial phase prior to formal planning in any waythe least we can do is openly acknowledge what remains hidden. If the benefits of non-transparency are valued higher than those of transparency, it should be explicitly stated and acknowledged that legitimacy comes from sources other than democratic practices. Or, alternatively, it can be acknowledged that this stage is not legitimate.