How do we build a better understanding of the housing system? What can we learn from past approaches and other countries? There are stark commonalities between housing crises in different countries, and there are significant lessons that can be learnt from challenges faced and solutions implemented overseas.
Land supply and infrastructure Planning systems are typically driven by national policies but, in England, detailed land use decisions implemented at a local level are less certain, allowing for more negotiation before planning permission is given. 70
The flexibility and the discretionary nature of English land use planning contrasts with the certainty provided through legally binding land use plans in other countries. The degree of negotiation over planning permission in England contrasts with decisions based more strictly on compliance (or lack of compliance) with local plans elsewhere. The English system allows for considerable negotiation late in the process, after plans have been made. In other systems, the emphasis is on greater negotiation before plans are in place. The potential for negotiation late in the planning process, as in England, can provide benefits of flexibility. However, it can also increase the uncertainty faced by developers. Planning systems in some other countries tend to have more significant development promotion functions. Land supply for residential use is actively promoted in such cases through land policies and processes in ways that are not found in England. Proactive, policy-driven land assembly and land supply processes in the Netherlands, Germany and France contrast with a more passive and reactive approach in England. Public policy influences infrastructure provision and the availability of serviced land at locations where the market is willing and able to respond.
In some cases, for example the Netherlands, local authorities are actively involved in trading in the land market and in supplying land that is ready for development. In Germany, local authorities are active in acquiring land and making it available for development and they are able to facilitate social supply by selling land cheaply for social production. There has been a tendency in other countries to promote development at desired locations as well as restraining it at others. This counterbalancing of the promotion of development is less apparent in England. The facilitating role of the state in planning infrastructure provision is clear in all these countries. Where development has been facilitated by government, it has often involved an amalgamation of actions similar to those obtainable in England, through local delivery vehicles that can enable and facilitate specific schemes. An examination of approaches in other countries suggests that policies that focus on dealing with constraints on the availability of suitable land by facilitating site assembly, infrastructure provision and the associated provision of services to support housing, can have positive effects on the volume and quality of, and demand for, the finished dwellings.
Tax incentives In the US, and in a number of European countries, tax incentives are widely used to leverage investment into the delivery of new affordable housing. The evidence for France and the USA in particular suggested that targeted tax incentives have the potential to boost the supply of rental housing of an acceptable quality and to improve affordability. The tax incentives support an investment in housing as long as the rents are limited and the dwellings are allocated to households on lower incomes.
Oxley MJ, Brown T, Nadin V, Qu L, Tummers, LC and Fernandez Maldonado, AM (2009). Review of European Planning Systems, London, UK: National Housing Planning Advice Unit, Department of Communities and Local Government UK [DATE ACCESSED: 8th June 2020]. Url: https://dora.dmu.ac.uk/ bitstream/handle/2086/7536/NHPAU%20Planning.pdf?sequence=1
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