A Comparison of Tendering and Contracting Systems for Public Works between Japan , the United States and EU Countries 1 )

*Born in 1965. Completed a master’s degree at Graduate School of Economics, Kyoto University in 1997. Having worked for Sanwa Research Institute Corporation (currently Mitsubishi UFJ Research and Consulting Co., Ltd.) since 1990. Special Audit Staff at the Construction Planning & Housing Audit Division, 3rd Bureau, Board of Audit of Japan from fiscal 2001 to 2004. Member of Japan Economic Policy Association, Japan Public Choice Society, Society for Environmental Economics and Policy Studies, Japan Society of Civil Engineers, Network for Policy Analysis, Association for Public Policy Analysis and Management and others. Major publications: Public Investment and Road Policy (co-authored), Keiso Shobo. 2001; Structure of National Budget (co-authored), Toyo Keizai Inc. 1997; “On the Consequences of the Different Ways of Appraisal among Similar Public Investments-A Comparison of Roads, Harbor Roads and Regional Farm Roads,” Governmental Auditing Review (in Japanese No. 25, March 2002; in English: Volume 10, March 2003) **Born in 1963. Graduated from the University of Tokyo Faculty of Law in 1986. Joined the Board of Audit of Japan in 1986. Assumed the present position after working at the Agriculture Audit Division, Construction Planning & Housing Audit Division, etc. 1) This paper is based on data as of December 2004. Following the revision of EU directives on public procurement in the end of April 2004, the EU member states are required to harmonize their national laws with the revision. Accordingly, they will make changes to their rules on public procurement. 2) These three directives were integrated as 2004/18/EC in April 2004.