In the last three decades many countries introduced charter schools as an alternative school. One of the famous examples are the United States, which introduced charter schools at the beginning of the 1990s (Cortina & Frey, 2009, Hartong, 2018, Köppe, 2017). In more than 40 states in the USA charter schools are allowed. Other countries imitated charters schools as in Sweden (friskolor, fristaende skolor), England (academies, free schools), Australia (independent public schools), New Zealand/Aotearoa (partnerschools oder Kura Hourua) or Columbia (colegios en concesión) (Chapman & Salokangas, 2012, Exley, 2017, Vogt, et al., 2018). Canada also introduced a form of charter schools, but they are only pilot schools in some provinces (Mindzak, 2015).

Charter schools are financed as public schools and therefore are not allowed to raise tuition fees. The provider of charter schools could be companies, universities, parents, associations or even individuals, which make a contract with the government or the schools administrations at the local level. Charter schools are not autonomous as private schools, but they have more freedoms in the issues of curricula, personnel management, qualifications of teachers and their salaries and school life. Charter schools are characterized as a „public–private hybrid“ (Vergari, 2007, S. 15).

England and New Zealand are good examples for investigating the reform processes for the introduction of the end of charter school politics in liberal education regimes. In England New Labour introduced charter schools with the city academies programme in the beginning of the 2000s years. After winning the elections for the House of Commons in 2010, the Conservative Party expanded the academy programme and allowed with free schools another form of charter schools. In New Zealand the charter school project failed in 2018. In New Zealand a conservative led government also allowed charter schools in 2014, but only 4 years later a Labour-led government abolished the charter school programme. The article has the following research question: Why England introduced academies and free schools and why a charter school programme failed in New Zealand? England and New Zealand are both suitable for a country comparison since the analysis follows the logic of a most dissimilar case design as a research strategy in comparative political research (George & Bennett, 2005). Both countries belong to the cluster of liberal welfare states and education regimes (Busemeyer & Nikolai, 2010, West & Nikolai, 2013). This article adopts a historical-institutionalist perspective (Mahoney, 2000, Pierson, 2004), examining the sources of stability and the drivers of change in charter school politics. The articles argues that the historical legacy of past decisions in the 19^th and 20^th century is influencing the actual decisions in charter school politics. The paper also examines the ideational foundations of policy positions, preferences and strategies (Béland, 2009). For the empirical reconstruction of the event sequences and causal narratives, the study carried out a qualitative content analysis of parliamentary documents, official statistics, secondary literature, semi-structured interviews (10 in England and 15 in New Zealand) and newspaper reports. The material was interpreted with the help of a coding frame, which was developed based on the theoretical concept and evaluated over the course of the analysis.

This study employed different empirical sources: (a) political documents, (b) media coverage and (c) expert interviews with education-policy-makers. As political documents, the following document types were analysed: party manifestos, coalition agreements, protocols of parliamentary debates, statements of interest groups and ministerial documents (such as school development plans) and governmental statistics. With these documents, it was possible to trace the political process and to capture the contextual factors. Political documents were also a source for analysing the interests and ideational foundations embedded in the different texts. An important source for the analyses was parliamentary debates, which ‘are especially well suited for studying the transformation of public justification’ (Bleses and Rose 1998, 82, own translation). Political parties do use parliamentary debates as a public forum to justify their decisions to the electorate (ibid). Their goals, motivations and arguments are presented intentionally and carefully – in other words, these are not ‘shortterm interpretations’ but ‘official party statements’ (Bleses and Seeleib-Kaiser 1999, 119, own translation). The analysis of media coverage (together with the document analyses) included different articles from daily newspapers in Saxony and Berlin. By analysing the media coverage, it was possible to identify the relevant actors and to contrast the findings with the document analysis and expert interviews. At the core stands an analysis based on expert interviews with education-policymakers (10 for England, 15 for New Zealand). The results of the interviews have been anonymised. The expert interviews included interviews with members of the educational administration, members of parties in the parliaments (mainly Labour and the Conservative Party/National Party) and and representatives of interest organisations (e.g. teacher unions, private schools organisations). The interviews considered problem-focused and episodic elements using a semi-structured guideline. The interviews were conducted in 2018. All the empirical sources (documents, media coverage and expert interviews) were analysed using qualitative content analysis based on Schreier (2012) and the typology of mechanisms of change presented in the theory section.

The argument of the article that partisan factors and the strength of teacher unions may explain why England and New Zealand are differing in regard to charter school politics. Whereas in England the expansion of academies and the introduction of free schools became possible with the election victory of the Conservative Party in 2010, the winning of Labour in New Zealand 2017 made it possible to stop the charter school programme of the former conservative government. In contrast to England, the teacher unions in New Zealand has a strong role in political life. The teacher unions vehemently opposed the charter schools and utilized different channels to influence the political debates. The grassroots campaigns included protest from individual schools against the introduction of charter schools in their communities, lobbying with the central government and national media campaigns. In England, the teacher unions struggled with New Labour in the 2000s years as they introduced the city academies programmes. The representatives of New Labour (like Tony Blair, Andrew Adonis, Michael Barber etc.) favoured the marketization in school politics and were not seeking to join forces with the teacher unions. However, the article will show that also ideas play an important role for charter school politics. In England, school politicians, who favoured charter schools, tried to imitate the private schools with their strong discipline and their focus on learning efficiency. Following a ‘private school ethos’ is an important factor for charter school politics. In New Zealand, the majority of school politicians uphold the image of the importance of a public school system, dating back to the first Education Act in 1877. Therefore, in New Zealand there is no wide support for policies of privatisation in the school system.

Béland, Daniel. 2009. "Ideas, institutions and policy change." Journal of European Public Policy 16 (5):701-18. Bleses, Peter, and Edgar Rose. 1998. Deutungswandel der Sozialpolitik. Frankfurt a.M./New York: Campus. Bleses, Peter, and Martin Seeleib-Kaiser. 1999. "Zum Wandel wohlfahrtsstaatlicher Sicherung in der Bundesrepublik Deutschland: Zwischen Lohnarbeit und Familie." Zeitschrift für Soziologie 28 (2):114-35. Busemeyer, Marius R., and Rita Nikolai. 2010. "Education." Oxford Handbook of Comparative Welfare States, edited by Herbert Obinger, Chris Pierson, Francis G. Castles, Stephan Leibfried and Jane Lewis, 494-508. Oxford: Oxford University Press. Chapman, Christopher, and Maija Salokangas. 2012. "Independent state-funded schools: Some reflections on recent developments." School Leadership & Management 32 (5):473-86. Cortina, Kai S., and Kristina Frey. 2009. "Privatschulen in den USA: Geschichte und aktuelle Kontroversen." Zeitschrift für Pädagogik 55 (5):701-15. Exley, Sonia. 2017. "A Country on Its Way to Full Privatisation? Private Schools and School Choice in England." Private Schools and School Choice in Compulsory Education. Global Change and National Challenge, edited by Thomas Koinzer, Rita Nikolai and Florian Waldow, 31-47. Wiesbaden: Springer VS. George, Alexander L., and Andrew Bennett. 2005. Case Studies and Theory Development. Cambridge, MA: MIT Press. Hartong, Sigrid. 2018. "Neue (unsichtbare) Formen der Privatisierung von Schule in den USA?" Ökonomisierung von Schule? Bildungsreformen in nationaler und internationaler Perspektive, edited by Sigrid Hartong, Björn Hermstein and Thomas Höhne, 232-47. Köppe, Stephan. 2017. "A Bicyle Built for Three: Private School Governance and Politics in the United States." Private Schools and School Choice in Compulsory Education. Global Change and National Challenge, edited by Thomas Koinzer, Rita Nikolai and Florian Waldow, 9-29. Wiesbaden: VS Springer. Mahoney, James. 2000. "Path Dependence in Historical Sociology." Theory and Society 29 (4):507-48. Mindzak, Michael. 2015. "What Happened to Charter Schools in Canada?" Equity & Excellence in Education 48 (1):105-17. Pierson, Paul. 2004. Politics in Time: History, Institutions, and Social Analysis. Princeton: Princeton University Press. Schreier, Margrit. 2012. Qualitative Content Analysis in Practice. London: Sage. Vergari, Sandra. 2007. "The Politics of Charter Schools." Educational Policy 21 (1):15-39. Vogt, Bettina, Kathleen Falkenberg, and Florian Waldow. 2018. "Effizienz durch Vermarktlichung? Zu Entwicklung und Konsequenzen der Einführung von Bildungsmärkten am Beispiel Schwedens." Ökonomisierung von Schule? Bildungsreformen in nationaler und internationaler Perspektive, edited by Sigrid Hartong, Björn Hermstein and Thomas Höhne, 248-71. West, Anne, and Rita Nikolai. 2013. "Welfare regimes and education regimes: Equality of opportunity and expenditure in the EU (and US)." Journal of Social Policy 42 (3):469-93.