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Housing and the State in Western Europe
Housing and the State in Western Europe P Boelhouwer and J Hoekstra, Delft University of Technology, Delft, The Netherlands ª 2012 Elsevier Ltd. All rights reserved.
Introduction The reason why governments intervene in the housing market can be explained on the basis of two important motives. The first motive is based on the poor results of a housing market which is completely steered by the free market. Almost all developed countries have established the right to decent housing in their constitution. Also, most countries have established minimum quality stand ards for housing in their legislation, which could in most cases not be realised in the free market. The second motive for government intervention in the housing market is the relation between housing and other policy areas. For instance, the battle against diseases and epidemics was the most important reason for many West European govern ments to start interventions in the housing markets in the nineteenth century. Also today, housing policy operates as a vehicle to reach policy goals across a broad spectrum of policy areas including social integration, environmental policy, spatial policy, and labour market policy. Despite the close relation between housing and govern ment policy, housing policy forms quite a specific element of the welfare state. As Torgersen put it: ‘‘Housing is the wobbly pillar under the welfare state’’ (Torgersen, 1987: 116). In contrast to social security, education, and health care, for example, identical and clear standard criteria which could be politically tested are lacking for housing. Politically it is not common that on the basis of certain objective criteria specific housing situations will be altered when the household situation changes. This is quite obvious, however, for health, education, and social security. The unclear way governments pay attention to the defini tion of housing need and the way this definition changes in time, changes in the housing situation of those who got certain benefits (like the increase in property prices and inheritances), or more broader policy goals like the creation of mixed neighbourhoods are the main reasons for the existing complex relation between the welfare state and housing. Also, Harloe states that housing is ‘‘the least decommodified and most market determined of the conventionally accepted constituents of welfare states’’ (1994: 2). Not only is the provision of housing mainly market determined, but it also differs in that, the costs of decommodified housing, and in particular social rented housing, are to a large extent charged to consumers. Finally, Bengtsson (2006) argued that housing policies, in contrast to other policies, are best understood as state correctives to the market.
WELFARE/WELL-BEING (Overview)
This complex relationship was for Esping-Andersen the justification for leaving out housing in his study, The Three Worlds of Welfare Capitalism (Esping-Andersen, 1990). Moreover, the position of housing within the wel fare state is far from obvious and has provoked a good deal of discussion. Some authors (e.g., Kemeny, 1992, 2001) focus on the relationships between the housing system and the welfare state, while others predominantly lay stress on the private market characteristics of housing (Harloe, 1995). The second part of this article pays atten tion to the way housing could be incorporated in the welfare state theory of Esping-Andersen and how this could be related to the development of the social rented sector in Europe. On the basis of the results of this elab oration, we also present a proposal for a modification of the welfare state typology of Esping-Andersen. Kemeny’s visualisation of corporatism plays a key role in this attempt. The problematic relationship between housing and government policy does not mean that governments do not have an important role to play in the housing market. On the contrary, despite the fact that exact definitions are difficult to formulate, almost all governments in the Western world have formulated general policy goals to establish enough affordable housing of good quality in the right place. Governments can hardly accept a full intro duction of the iron law of the housing market which states that those with the lowest incomes have to live in the least attractive houses (Doling, 1997; Priemus, 1978). After establishing the more general policy goals for housing by the government, the question arises as to what extent the government itself has to intervene actively in the housing market. The government has a choice of the following six policy options: doing nothing, exhortation, regulation, taxation, subsidisation, and self-realisation (Doling, 1997: 42). Only when using the last three instru ments does the government actively step in and become, together with households and housing suppliers, a direct player on the housing market. In this article, we first elaborate on the development of theories about housing and the welfare state. Since the 1970s, different theoretical frameworks have been devel oped to explain and describe this complicated relationship. In the second part of the article, we next focus on Esping-Andersen’s welfare state theory. His theory and typology have attracted considerable attention in international comparative housing research. Various researchers have discussed the position of housing within
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the welfare state in general and within Esping-Andersen’s framework in particular (see Boelhouwer and Van der Heijden, 1992; Brandsen, 2001; Doling, 1999; Harloe, 1995; Kemeny, 1992, 1995, 2001, 2006; Kemeny and Lowe, 1998; Kleinman, 1996; Matznetter, 2002). Most of the debate, however, has been at a conceptual or theoret ical level. Esping-Andersen’s work has rarely been tested, or directly related to housing practices. One exception is the study by Barlow and Duncan (1994), who relate the Esping-Andersen typology to housing production in the United Kingdom, France, and Sweden. Another excep tion is the research of Domburg-De Rooij and Musterd (2002) investigating the relationship between welfare state regimes (The typology of welfare states used by Domburg-De Rooij and Musterd differs from that of Esping-Andersen.) and segregation. And finally, Hoekstra tested the connection between welfare state regimes and dwelling type (Hoekstra, 2005). On the basis of an analysis of the conceptual framework of Esping-Andersen, the last section will present a modifi cation of his welfare state typology.
Theories of the Development of Welfare States and Housing The way the government chooses to play a role in the housing market has a central position in research on the development of housing systems and their relations to the development of welfare systems. This research discipline commenced towards the end of the 1970s and was dominated by convergence theories. Wilensky et al. (1987) showed that social and economic convergence theories had dominated decades of research into the development and functioning of the welfare state. This enduring paradigm presumes a relationship between the level of economic development and the level of public expenditure on welfare, such as social security, housing, and education. Notwithstanding the differences in cul tural and social characteristics of different countries or societies, economic progress undermines the traditional structure of care, including assistance offered by families, the private sector, and charitable institutions. This process is also explained by the development of a complex post industrial society. Much of this comparative research on housing can be traced back to the work of Donnison, and in particular his 1967 book, The Government of Housing. His central idea is that housing policy also converges because of an increasing correspondence between economic and demographic developments in countries despite partypolitical, ideological, and/or institutional differences between countries. In 1982, Donnison and Ungerson pub lished a modified version of this important book. In this book, they distinguish between a marginal and an institu tionalised housing policy. The former seeks to ensure a
basic level of housing quality and concentrates on helping the weakest in society. The authors argue that this form of housing policy is principally followed by moderately developed industrial societies. As industrial growth con tinues, housing policy also takes on a more institutional form. The government then develops a complex policy directed not only to the construction of housing but also to the distribution and the management of the dwelling stock. In order to achieve this, an extensive set of policy instruments is developed. These are designed to ensure a degree of equity, an increase in the quality of housing, and a reasonable distribution of expenditure on housing. Despite clear differences in the political backgrounds of the respective governments, the increase in the scope of government activity has been both quantitative (involve ments in more fields of policy) and qualitative (more farreaching policy aims). This increase is related to the rising expectations of a postindustrial society. During the last few decades, several critical remarks have been made on the convergence theory. First, there is little empirical support for the principles on which the theory is based. The theory itself has led to hypotheses and a number of descriptive studies. Another problem with the convergence theory is the scale at which it can be applied (see also Doling, 1990). The theory was originally formulated to describe the development of a society in broad terms. In order to test such theories, it often suffices to refer to aggregate data on government expenditures for core activities and other general macroeconomic and dem ographic trends. However, expenditure levels and policy goals may fluctuate widely by sector and through time. A third point of criticism concerns the supposed outcome of the housing systems. In contrast to Donnison’s position, government may be said to retreat rather than expand as the level of affluence rises. When housing-market shortages ease up, government supposedly retreats from housing, giving market forces more leeway. An alternative approach to research in the tradition of convergence theory, which has proved its value in com parative housing research since the mid-1970s, is the ‘structure of housing provision’ (SHP). This approach distinguishes social groups that can influence the way in which the provision of housing and housing services comes about. The relationships between these groups must be defined in order to investigate many issues asso ciated with housing. This approach explicitly recognizes that processes of change take place. As a result, the inves tigation of institutional changes forms a key empirical question for housing-related research (Ball and Harloe, 1990: 1). The context in which housing-market processes operate is subject to continual change. To understand the changes in the provision of housing and housing services, it is precisely these institutional changes that have to be recognised.
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The SHP approach analyses the relations of consump tion and production, as well as those of exchange. The SHP approach is explicitly not presented as a theory of housing. It provides a context within which many hous ing-related issues can be examined. It certainly does not specify what theoretical approach should be adopted in explaining the differences observed. For this, one has to rely on existing explanatory models, such as those based on neoclassical, Weberian, or neo-Marxist theories. Harloe and Martens (1987) also subscribe to the prop osition that housing-market processes in every country are a product of the specific interaction between political, economic, and ideological factors. For instance, the size of the owner-occupied sector cannot be explained by the mere fact that a country supports a policy of privatisation. In practice, the owner-occupied sector in the underde veloped regions of France fulfils a completely different function than it does in, say, the southeast of England. Furthermore, countries organise their nonprofit rented housing sector very differently. As a result, public-sector rented housing in, for example, Great Britain is much more vulnerable to policies of privatisation than in the Netherlands or Denmark. As noted above, those subscribing to the SHP approach argue that it is important to describe and account for institutional structures in order to provide a satisfactory explanation of housing-market processes. Among these structures, they include the different financial mecha nisms, the development of the construction industry, and the government’s land-use policy. Of course, these structures have their origins in past ideological, political, and economic developments. As a reaction to these quite mechanistic convergence theories in which ‘politics doesn’t matter’ forms a key element, a new group of divergence theories became popular in the 1990s. These theories pay more attention to country- and region-specific cultural processes and actors. The view that institutionalised relationships and structures within the housing system themselves become formative of new structures over time has led to the proposition that housing and welfare systems more gen erally may be expected to diverge to an increasing extent (Milligan, 2003: 37). These theories are some times addressed as middle-range theories (Kemeny and Lowe, 1998). These authors stress the specific political, ideological, and cultural differences to explain the differ entiation between housing systems (see also Mandic and Clapham, 1996; Merton, 1957). To help explain the perpetuation of different national characteristics in housing systems, a number of researchers have intro duced the concept of ‘path dependency’ (Boelhouwer and van der Heijden, 1992; Kleinman, 1996: 15). This concept refers to the tendency for solutions to problems or policy decisions, whether accidental or deliberately chosen, to become locked in through institutional and
ideological processes and, subsequently, difficult to change (Kleinman, 1996: 15). One of the most influential scholars of the divergence approach is Jim Kemeny. Kemeny distinguishes a direct relation between the development of housing systems and the social structure of a society which in his terms is strongly influenced by the dominant ideologies. For Kemeny, it is the wider social arrangement and ideolog ical dispositions in different countries, not the economic logic of capital or particular configurations of political power, which better explain how the choices of policy strategies come about and are maintained. Essentially, in his view, societies are either more collectivised in their social consciousness or more privatised. The continuum between privatisation and collectivism is presented in two different models: home-owning societies against costrental societies (Kemeny, 1995). Anglo-Saxon countries are defined as home-owning societies and are character ised by a dual rental market. Against a large owneroccupied sector, a small social rented sector is placed which is only accessible for low-income groups and which is highly segmented. Rent setting is organised by the private rented sector. The State stimulates by man agement of speech and direct and indirect subsidies the growth of homeownership. In the continent of Europe, more cost rental societies can be seen. The rental sector is well developed and the rents are based on the cost price and not on the market value. The division between the private and social rented sector is small and both are subject to the same legislation. Kemeny’s approach provides a theoretical basis (the maturation process) for explaining the potential for differ ences in housing outcomes to arise from long-term differences in housing policy strategies. With maturation, Kemeny is referring to the growing difference between the debt per house for the existing stock and for newly built houses. The way the maturation process is developed determines the position of the social rented sector on the housing market. If the government allows the introduction of the principle of rent pooling, a high maturation will also be reflected in the rent level of the social rented sector. The impact of the social sector increases, and gives the organisations the possibility to become an important player at different policy arenas. In those systems, it is also the social rented sector which is in charge of rent setting and not the private rented sector (Kemeny, 1995). According to Kemeny, because of the central position of housing in the welfare state, the choice for a unitary or dual rented system also has consequences for other policy areas. A dual rental system often corresponds with a social security system that is based on a safety net for the most vulnerable households in society. In such a model, the housing allowances often have residual characteristics. A society which is based on a safety net for the most vulnerable households has also some correspondence with
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another type of welfare system: the ‘asset-based’ or ‘prop erty-based’ welfare system (Doling and Ronald, 2010; Elsinga et al., 2007; Horsewood and Neuteboom, 2006; Ronald, 2008). The principle underlying an asset-based approach to welfare is that, rather than relying on Statemanaged social transfers to counter the risks of poverty, individuals accept greater responsibility for their own wel fare needs by investing in financial products and property assets which augment in value over time (Doling and Ronald, 2010). These can, at least in theory, later be tapped to supplement consumption and welfare needs when income is reduced. The potential wealth tied up in owner-occupied housing has been considered, more or less explicitly, to be a solution to the fiscal difficulties involved in the maintenance of welfare commitments, and through that, the asset in asset-based welfare has frequently become property or housing assets (Doling and Ford, 2007). The above sections have summarised several methods and approaches employed in international comparative housing research. Given the vehement polemics that occasionally erupt among exponents of these approaches, both in the literature and at conferences, it would seem that the differences between these approaches are unbridgeable. In practice, though, this is not the case. In several publications, these authors acknowledge that each of the methods contains valuable features that sometimes complement each other (see Lundqvist, 1991; Oxley, 1990). In addition, these approaches do not purport to employ a universal explanatory model. Rather, they sug gest methods and techniques which seem to provide insight into housing-market processes. For an explanation of these developments, it is often necessary to revert to more general theories, such as neoclassical, Weberian, and neo-Marxist explanatory models. Exponents of the various approaches tend to agree on the subjects and aspects that comparative research should treat. All these different approaches recognise the importance of factors outside the sphere of housing. It is only in terms of actual interpretation that they differ from one another. According to convergence theory, these factors explain the differences between housing systems. Other approaches regard these factors more as the context within which housing processes take place. But all of these approaches devote attention to how adaptation to changing circumstances takes place. This can occur as the result of government policies (policy-oriented approach) or through activities of various social groups that influ ence the provision of housing and housing services (provision-oriented and institutional approaches). As mentioned in the introduction, in the next part of this article, we will again discuss in general the complex relationship between the development of welfare states and housing. Esping-Andersen argues that welfare states can be reduced to three ideal typical welfare state regimes, which differ fundamentally from
each other. This has resulted in his well-known and widely used typology of welfare state regimes. In his theory of welfare state regimes, EspingAndersen explains how the differences between the three welfare regime types came about. Three factors were of particular importance: the way in which the mobilisation of the working class took place; the coalitions between the political parties; popular support for the conservation and expansion of the welfare state (EspingAndersen, 1990). It is important to recognise that the Esping-Andersen typology is of ideal typical nature. Most countries will only to some extent correspond to the welfare regime they are classified in (see, e.g., Kvist, 1999). Therefore, the typology should not be seen as an exhaustive classification system. Rather, it is an analytical device that can be used to interpret differences in welfare systems between countries. The section ‘The Theory and Typology of Esping-Andersen’ gives a brief explanation of Esping-Andersen’s welfare state theory. An application of his theory for housing is presented in the section ‘The Welfare State Typology Applied to Housing’. The result ing scheme of analysis shows how the three welfare state regimes differ on some important aspects of the housing system. As a result of this analysis, the section ‘The Relation between the Modified Theoretical Framework and the Development of Social Housing in Europe’ gives a short elaboration of how this theory could be connected to the development of social housing in Europe.
The Theory and Typology of Esping-Andersen Three Welfare State Regimes The typology of Esping-Andersen makes a distinction between the three welfare state regimes. The most impor tant characteristics of these three regime types are briefly discussed below. We identify some countries belonging to each of the regime types. In social-democratic welfare state regimes, the provi sion of welfare services is dominated by the State. There are universal welfare services of a high level, to which a large proportion of the population has access. As a result of the redistributive effects of the welfare state, income differences are relatively low. Sweden is the classic exam ple of a social-democratic welfare state, although other Scandinavian countries also belong to this regime type. In corporatist welfare state regimes, the State is fairly active in the provision of welfare services. However, this does not lead to income redistribution, since preservation of the existing hierarchy in society is the starting-point for welfare polices at State level. Consequently, the welfare provision is segmented; different groups are entitled to different welfare services; and the traditional family is often explicitly favoured. Furthermore, the State is
Housing and the State in Western Europe 367
definitely not the only provider of welfare services. In this respect, the family and private nonprofit organisations (churches, trade unions, and so forth) also play an important part. Austria, Germany, Italy, and Belgium are representa tive corporatist welfare state regimes. In this article, like Esping-Andersen (1999: 4), we also treat the Mediterranean welfare state regime as part of the corporatist welfare state. The liberal welfare state regime is characterised by little State interference and a strong market orientation. Private companies are responsible for the majority of the welfare services. The State only provides help for a limited group of people with really low incomes (safety net). As a result, the society is characterised by dualism. There is equality (but also poverty) among the recipients of state welfare, while there is differentiation in income in the rest of the society. The United States, Australia and, to a lesser extent, the United Kingdom and Ireland represent liberal welfare state regimes, although the United Kingdom is sometimes seen as a mixed regime with both social democratic and liberal elements, though per haps moving more towards the latter.
The Welfare State Typology Applied to Housing Esping-Andersen discriminates between the three welfare state regimes on the basis of three (strongly interrelated) criteria: decommodification; stratification; the arrangements between the State, market, and family. These three cri teria are applied to housing and translated into four specific housing aspects, which are expected to cover an important part of the housing system. Figure 1
shows the relationship between Esping-Andersen’s three criteria and the four aspects of the housing system to which they have been converted.
Decommodification When applied to housing, decommodification can be defined as the extent to which households can provide their own housing, independent of the income they acquire on the labour market. Thus, governmental inter ference (It should be noted that the State is not the only actor responsible for decommodification, since the family can also have decommodifying effects. However, follow ing Esping-Andersen, we focus on the decommodification caused by the State.) is involved with the price of housing and with household incomes. The welfare state can decommodify housing not only via price regulation and production subsidies (affecting the price of housing), but also via subject or to the household directed subsidisation, which influences the household income (Lundqvist, 1991). The latter can involve both general income support (pensions, unemployment benefits) and subject subsidies that are specific to the field of housing. In this article, we have restricted ourselves to the last category. Thus, the decommodification is translated into the following two housing aspects: housing subsidisation (both object and subject subsidies), and price regulation.
Stratification The welfare state is a system of stratification; the way in which the welfare state distributes welfare services has
Arrangement between the State, markets and family
Stratification
Decommodification
Subsidisation
Price fixing and price regulation
Organisation production newly built houses
Housing allocation
Relation Translation Figure 1 The three criteria of Esping-Andersen applied to housing.
Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology.
Housing Theory and Society 20(2): 58–71.
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consequences for the hierarchy in society. In this respect, a distinction can be drawn between economic stratifica tion and social stratification. Economic stratification refers to income distribution within a society, whereas social stratification is related to differences in social status. Social stratification can be related to economic factors (income), as also to noneconomic factors such as ancestry, or occupation. In the field of housing, stratification is reflected in the process of housing allocation. Without State interference, housing allocation could be expected to be a direct reflection of the economic stratification in a society; households with the most resources would obtain the best and most expensive houses. However, the State is able to regulate the housing allocation process. Certain groups can be favoured by applying allocation rules. These State interventions can have different objectives. They can aim not only at increasing the choice for lowincome groups, but also at the preservation of status differentials.
The housing associations in the different European coun tries are a good example of such institutions. The relationships between the State, market, and fam ily determine which welfare services are provided, how they are distributed, and for which groups they are des tined. In other words, the mix between the State, market, and family is decisive for the decommodification and stratification in a country. Although Esping-Andersen is not explicit on this matter, we assume that the mix between the State, market, and family is superior to decommodification and the stratification. The specific configuration between the State, market, and family in a certain society then represents the essence of the welfare state. The implication is that the criteria discussed earlier in this section are in fact all influenced by this configu ration. The most direct influence can be seen in the organisation of the production of newly built dwellings and the way in which actors from the public, market, and household sectors participate in this process. Towards a Scheme of Analysis
The State, Market, and Family Mix Welfare services can be provided by the State (or public sector), as also by the market or the family (or household sector). The differences between the State, market, and family are connected with the so-called ‘decision units’ and the way the decisions are coordinated (Priemus, 1983). For the State, the decision units are public bodies; for the market, suppliers and buyers; and for the house hold sector, small groups (households, families, friends, and associations). Every sector is characterised by a spe cific kind of coordination of decisions. Public bodies are responsible for the decisions that are taken in the public sector (supported by laws or regulations), while the coor dination of decisions in the market sector takes place on the basis of the ‘market-mechanism’ (with the price as an important point of orientation). In the household sector, the coordination of decisions occurs without financial transactions and prices, often on the basis of reciprocity. It has to be noted, however, that the above-mentioned trichotomy between the State, market, and family refers to an ideal typical situation. In reality, there are many graduations and mixes, both with regard to the decision units and the coordination of decisions. First of all, it is obvious that the decision units in the State and the house hold sector frequently enter the market (mostly as buyers, but sometimes also as suppliers). On the other hand, nowhere in the world is a market totally free; every market is subject to government regulations and has some informal aspects. Eventually, it is important to real ise that there are decision units that do not properly fit within one of the three sectors. In virtually every country, there are institutions that combine private (household sector and market) and public (state) interests and tasks.
We hypothesised that the four housing aspects in Figure 1 differentiate between the three welfare state regimes. The hypothesis led to the scheme of analysis (see Table 1), which could be applied to the housing system of a specific country. The scheme of analysis was deductively constructed on the basis of the welfare state typology of Esping-Andersen. A more detailed underpin ning of this deductive process can be found in Hoekstra and Reitsma (2002). This implies that the scheme is of an ideal typical nature; when constructing the scheme, developments that are specific for a particular country were not taken into account. Accordingly, the scheme should be considered as a mere analytical device that can be used to make sense of empirical country data on housing. The scheme solely applies to the national level. It does not take into account territorial differences within countries. Kemeny’s View of Corporatism According to Kemeny (1995), Esping-Andersen uses an unusual definition of corporatism, since he clearly relates this concept to conservative elements, like the preservation of status differentials in society and the preferential treatment of the traditional family. In the political sciences, the definition of corporatism is more neutral: there, corporatism is a system of cooper ation and compromise between capital and labour, coordinated by the State. Following this line of thought, Kemeny comes to the following working definition of corporatism: A system of institutionalised political rep resentation of different interest groups that is essentially founded on compromise, and accommodation between
Housing and the State in Western Europe 369 Table 1 Differences between the housing systems of the three welfare state regimes Criterion
Social-democratic
Corporatist
Liberal
Decommodification Stratification Mix of the State, market, and family
�
Large Relatively low � Dominant position of the State
� �
�
State regulation
�
Quite large High, mainly based on social status � Important position for the family � Considerable influence for private nonprofit organisations � Functional decentralisation, incremental, problem-solving policies � Preservation of the social stratification in society � Preferential treatment of the traditional family � Stimulation of households and other private actors to take initiatives on the housing market � Segmented subsidies; specific arrangements for specific groups
�
�
Moderate State influence State regulation of prices to correct negative effects of the market � State intervention to correct the market � Certain groups may be favoured in the allocation process
� Market determination of house prices
General housing policy objectives
Subsidisation
Price setting and price regulation Housing allocation
Strong central government influence � Guaranteed universal high level of housing quality
Large-scale production subsidies � Subject subsidies for large target groups � Strong State influence on price setting and price regulation � Allocation on the basis of need �
�
Low High, mainly based on income � Dominant position of market parties
Relatively little State regulation (at both central and local levels) � Dominant position for the market � State only supports marginal groups �
� �
Means-tested subject subsidies Few production subsidies
�
Market determination of housing allocation in a large part of the housing stock � Regulated allocation in a small part of the housing stock (reserved for lowincome groups) �
Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71.
conflicting power groupings – whether these be based on class, religion, or ethnicity (Kemeny, 1995: 65–66). Kemeny asserts that, when so defined, corporatism applies to corporatist as well as social-democratic wel fare state regimes. He argues that both the continental European countries (corporatist welfare state regimes) and the Scandinavian countries (social-democratic welfare state regimes) are characterised by a political structure that is based on corporatism (in the political science definition). In the Anglo-Saxon countries on the other hand, there is little political corporatism and often a dual political system (two main parties). According to Kemeny, the Scandinavian and continen tal European countries differ from each other in one important aspect: the influence of the labour movement in a historical perspective. In Scandinavia, the strong position of the labour movement has resulted in a welfare state in which the central government has a dominant position and social equality is of great importance. Kemeny refers to this as labour-led corporatism, where the workers have a relatively strong position (Kemeny, 2006: 8). In continental Europe, however, the labour movement was less strong. As a result, private nonprofit organisations played an important part in the provision of welfare services in continental Europe, and the ability to cope on one’s own was strongly stimulated. Kemeny
refers to welfare states of this kind by the term ‘capital led corporatism’ (Kemeny, 2001: 62). A Proposed Modification of the Theoretical Framework Kemeny’s ideas suggest that the political structure criterion should have an important position in the theoretical framework. Kemeny’s distinction drawn between liberal and corporatist (labour-led and capitalled corporatism) welfare states is made principally on the basis of this criterion. On the basis of the changing role of the central government in many Western European countries in the 1990s, we subdivide Kemeny’s capital-led corporatism into two types: con servative corporatism and modern corporatism. Conservative corporatism corresponds with corporatism as defined by Esping-Andersen, whereas modern corpo ratism refers to a style of governance whereby the central government switches to a more indirect mode of governance, by defining the policy frameworks within which the local authorities and the private actors operate (see Hoekstra, 2003, for an elaboration for the Dutch housing market). Thus, next to liberalism, we distinguish three different kinds of corporatism: labour-led, conser vative, and modern. In short, we have arrived at a
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modified theoretical framework that differs from the original framework (see section ‘The Theory and Typology of Esping-Andersen’, Table 1) on the follow ing three points: political structure criterion has been added to the • The criteria listed in Table 1. The social-democratic welfare state regime is consid • ered to be a specific form of the corporatist welfare
•
state regime: labour-led corporatism. The corporatist welfare state regime of EspingAndersen is subdivided into two types: a conserva tive corporatist welfare state regime (coinciding with Esping-Andersen’s original corporatist welfare state regime) and a modern corporatist welfare state regime.
Table 2 shows how the various welfare state regimes of the modified theoretical framework differ with respect to these characteristics. Figure 2 shows the same information in the form of a diagram, based on Evers’ State–market–family triangle (1988).
The Relation between the Modified Theoretical Framework and the Development of Social Housing in Europe The modification of the theoretical framework in the previous section was constructed inductively. Adaptations were partly derived from concepts defined by Kemeny. The modified theoretical framework could be used as a basis for the interpretation of the develop ments within country-specific housing systems. In this
article, we will connect in short, the new theoretical framework to the development of social rented housing in Europe. The development of the social rented sector in Europe has been described by several authors in the past (Boelhouwer and van der Heijden, 1992; Danermark and Elander, 1994; Harloe, 1992, 1994; Murie, 1992). As noted by many of these authors before (see Danermark and Elander, 1992: 2 for an overview), the concept of social housing, although used as if its meaning was selfevidently clear, takes on different meanings in various national contexts. Sometimes it is connected to council housing (like in the United Kingdom), sometimes as pub licly subsidised housing, irrespective of ownership (like in Germany), sometimes as intermediate housing (like in the Netherlands), or as an umbrella concept, covering various types of housing in terms of ownership and tenure. Nevertheless, despite these and other differences, histor ically, the term social housing has been ascribed some dimensions that are quite similar from country to country, thus making comparative discussions meaningful (Danermark and Elander, 1992: 2). As summarised by Harloe (1992), social rented housing can be very broadly characterised as having three major characteristics: First, it is provided by landlords at a price which is not primarily determined by considerations of profit. Second, it is administratively allocated according to some concep tion of ‘need’. Thirdly, government control over social rented housing is extensive and has become more over time. With regard to this last characteristic, things have changed in the last decade. Social landlords, for instance, in the Netherlands are much more independent of the government than they were before.
Table 2 Main characteristics of the four welfare state regimes according to the modified theoretical framework
Decommodification Influence of central government Degree of political corporatism Fragmentation in the provision of welfare services Treatment of the traditional family in welfare policies Role of the State, market, and family in the provision of welfare services
Labour-led corporatist
Conservativecorporatist
Modern corporatist
Liberal
High High and direct
Relatively high Quite high and often indirect Many corporatist structures and processes Fragmentation on the basis of occupation and/or social status
Relatively high Quite high and often indirect Many corporatist structures and processes Fragmentation on the basis of measurable criteria
Low Low
Preferential treatment for the traditional family Important (if not dominant) position of the family
No preferential treatment for the traditional family Welfare services are provided by both market and the State
Many corporatist structures and processes Fragmentation on the basis of measurable criteria No preferential treatment for the traditional family Dominant position of the State
Few corporatist structures and processes Fragmentation on the basis of measurable criteria No preferential treatment for the traditional family Dominant position of the market
Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71.
Housing and the State in Western Europe 371
Conservative corporatism
Traditional family privileged
Fragmentation to maintain stratification
Family
State
Market Traditional family not privileged
Liberalism
Few corporatist structures and processes Few and direct state interference
Modern corporatism
Labour-led Fragmentation on corporatism objective grounds
Corporatist political structures processes Moderate and indirect state interference
Low decommodification
Many and direct state interference High decommodification
Figure 2 A proposed new conceptual model for the welfare state. Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71.
With our adjusted welfare state typology, it is possi ble to structure the position of the social rented sector more precisely. As explained in the section ‘Theories of the Development of Welfare States and Housing’, Kemeny’s elaboration between home-owning and costrental societies could be the starting point. In his article ‘Corporatism and Housing Regimes’, Kemeny (2006) argues on the basis of a division between capital-led and labour-led corporatism that there is a connection between the specific corporatistic welfare state and the existence of an integrated rental market with a strong social rented sector. Kemeny argues that the corporatist power system indicates the need to achieve compro mises. Corporatist compromise solutions entail a political solution that takes into consideration several different interests. The fragmentation of political parties resulting in coalitions and minority governments being the norm may be part of the explanation for the rise of an integrated market and a strong social rented sector. The latter can take many shapes and forms such as municipality-owned companies, voluntary or charitable societies, trusts, rental cooperatives, and even privately owned nonprofit enterprises (Kemeny, 2006: 12). For right-wing hegemonic coalitions who could be classified as liberal welfare states, it is quite clear that there will be a choice for a dualist rental system where nonprofit activities are restricted and nationalised. Social rented housing is incorporated into a publicly controlled planned economy and shaped into a low-income
housing sector (command economy means-tested public renting). Examples are the United States, Canada, Australia, New Zealand, and, to a lesser degree, the United Kingdom. The corporatist welfare states are more related to an integrated rental market with a specific leading role for the social rented sector (Kemeny, 2006: 13). In conservative corporatist coun tries, we could still observe a strong influence of rightwing parties and a social rented sector which is limited and has a limited impact on the rental market. We also could expect a variety of ownership forms of social rental housing. Examples of these countries are Germany and Switzerland. In the labour-led corporatist countries, we would expect a bigger and more uniform social rented sector and a very small profit rented sector. The social rented sector is then big enough to have a leading position on the rental market. Also, the influence of the tenant and/or the State could be more explicit. Clear examples of these types of corporatist states are Sweden and Denmark. In the modern corpo ratistic welfare state, the role of the State is smaller and the role of the market, also for the social rented sector, is bigger than in the labour-led corporatistic state. A clear example of that is the social rented sector in the Netherlands. With 33% of the housing stock, the social rented sector in the Netherlands still has a dominant position not only in the Dutch rental market, but also in the overall housing market. The State largely confines itself to creating the conditions and to
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formulate the policy frameworks within which local government authorities and private actors operate. This new policy framework brought the housing asso ciations in the Netherlands into a very powerful position. They are financially very strong and are in the bigger cities dominating the local rental market with regard to their housing stock and have a crucial role in urban renewal developments. A relevant question for the future is if more corporatist welfare states will develop in the direction of a modern corporatist welfare state and if the right-wing/conservative parties and the liberal-oriented neoclassical economies will approve such a development. More specifically, the role of the European Commission and the way the policy of free competition is implemented in the near future by spe cific laws from Brussels will probably provide an answer to the question of whether corporatist welfare states in general will have a bright future. See also: Asset-Based Welfare; Economics of Social Housing; Gender and Urban Housing in the Global South; Housing Subsidies and Welfare; Social Housing and Social Problems; Social Theory and Housing.
References Ball M and Harloe M (1990) Rhetorical barriers to understanding housing provision, what the ‘provision thesis’ is not. Paper presented at the International Housing Research Conference ‘Housing Debates – Urban Challenges’. Paris, France, 3–6 July. Barlow J and Duncan S (1994) Success and Failure in Housing Provision, European Systems Compared. Oxford, UK; New York; Tokyo: Elsevier Science Ltd. Bengtsson B (2006) Swedish housing corporatism, a case of path dependency? Paper presented at the ENHR 2004 Conference ‘Housing: Growth and Regeneration’. Cambridge, UK, 2–6 July 2004. Boelhouwer PJ and van der Heijden HMH (1992) Housing Systems in Europe, Part I: A Comperative Study of Housing Policy. Housing and Urban Policy Studies 1. Delft, The Netherlands: Delft University Press. Brandsen T (2001) Bringing actors back in: Towards an institutional perspective. Housing, Theory and Society 18: 2–14. Danermark B and Elander I (1992) Social Rented Housing in Europe: Policy, Tenure and Design. Housing and Urban Policy Studies 9. Delft, The Netherlands: Delft University Press. Danermark B and Elander I (1994) Social Rented Housing in Europe: Policy Tenure and Design. Housing and Urban Policy Studies 9. Delft, The Netherlands: Delft University Press. Doling J (1990) Housing policy and convergence theory: Some comments on Schmidt, Research note. Scandinavian Housing and Planning Research 7: 117–120. Doling J (1997) Comparative Housing Policy. Government and Housing in Advanced Industrialized Countries. London: Macmillan Press Ltd. Doling J (1999) De-commodification and welfare: Evaluating housing systems. Housing, Theory and Society 16: 156–164. Doling J and Ford J (2007) A union of home owners, editorial. European Journal of Housing and Planning 7(2): 113–127. Doling J and Ronald R (2010) Home ownership and asset-based welfare. Journal of Housing and the Built Environment 24: 1. Domburg-De Rooij T and Musterd S (2002) Ethnic segregation and the welfare state. In: Schnell I and Ostendorf W (eds.) Studies in Segregation and Desegregation, pp. 107–131. Aldershot, UK: Ashgate.
Donnison D (1967) The Government of Housing. Harmondsworth, UK: Penguin. Donnison D and Ungerson C (1982) Housing Policy. Harmondsworth, UK: Penguin. Elsinga M, De Decker P, Teller N, and Toussaint J (2007) Home Ownership Beyond Asset and Security. Housing and Urban Policy Studies 32. Amsterdam: IOS Press. Esping-Andersen G (1990) The Three Worlds of Welfare Capitalism. Cambridge, UK: Polity Press. Esping-Andersen G (1999) Social Foundations of Postindustrial Economies. Oxford, UK: Oxford University Press. Evers A (1988) Shifts in the welfare mix – introducing a new approach for the study of transformations in welfare and social policy. In: Evers A and Wintersberger H (eds.) Shifts in Welfare Mix. Vienna: European Centre for Social Welfare Training and Research. Harloe M (1992) The social construction of social housing. In: Danermark B and Elander I (eds.) Social Rented Housing in Europe: Policy, Tenure and Design, pp. 37–52. Housing and Urban Policy Studies 9. Delft, The Netherlands: Delft University Press. Harloe M (1994) The People’s Home? Social Rented Housing in Europe and America. Oxford, UK; Cambridge, MA: Blackwell. Harloe M and Martens M (1987) Innovation in housing markets and policies. In: Turner B, Kemeny J, and Ludqvist L (eds.) Between State and Market: Housing in the Post-Industrial Era, pp. 190–214. Ga¨vle, Sweden: Almqvist & Wiksell International. Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71. Hoekstra J (2005) Is there a connection between welfare state regime and dwelling type? An exploratory statistical analysis, Housing Studies 20(3): 475–495. Hoekstra J and Reitsma A (2002) De zorg voor het wonen. Volkshuisvesting en verzorgingsstaat in Nederland en Belgie¨ [The Care for Housing. Housing and the Welfare State in the Netherlands and Belgium]. Volkshuisvestingsbeleid en Woningmarkt 33. Delft, The Netherlands: DUP Science. Horsewood N and Neuteboom P (2006) The Social Limits to Growth. Housing and Urban Policy Studies 31. Amsterdam: IOS Press. Kemeny J (1992) Housing and Social Theory, pp. 64–81. London; New York: Routledge. Kemeny J (1995) From Public Housing to the Social Market. Rental Policy Strategies in Comparative Perspective. New York: Routledge. Kemeny J (2001) Comparative housing and welfare: Theorising the relationship. Journal of Housing and the Built Environment 16(1): 53–70. Kemeny J (2006) Corporatism and housing regimes. Housing, Theory and Society 23(1): 1–18. Kemeny J and Lowe S (1998) Schools of comparative housing research: From convergence to divergence. Housing Studies 13(2): 161–176. Kleinman M (1996) Housing, Welfare and the State of Europe. Cheltenham, UK; Brookfield, WI: Edward Elgar Publishing Limited. Kvist J (1999) Welfare reform in the Nordic countries in the 1990s: Using fuzzy-set theory to assess comformity to ideal types. Journal of European Social Policy 9(3): 231–252. Lundqvist LJ (1991) Rolling stones for the resurrection of policy as the focus of comparative housing research. Scandinavian Housing and Planning Research 8: 79–90. Mandic S and Clapham D (1996) The meaning of home ownership in the transition from socialism: The example of Slovenia. Urban Studies 33(1): 83–97. Matznetter W (2002) Social housing policy in a conservative welfare state: Austria as an example. Urban Studies 39(2): 265–282. Merton RK (1957) Social Theory and Social Structure. Glencoe, IL: The Free Press. Milligan V (2003) How Different? Comparing Housing Policies and Housing Affordabilty Consequences for Low Income Households in Australia and the Netherlands. Netherlands Geographical Studies 318. Utrecht, The Netherlands: University of Utrecht. Murie A (1992) Public rented housing in Britain. In: Danermark B and Elander I (eds) Social Rented Housing in Europe: Policy, Tenure and Design, pp. 77–94. Housing and Urban Policy Studies 9. Delft, The Netherlands: Delft University Press.
Housing and the State in Western Europe 373 Oxley M (1990) The aims and methods of comparative housing research. Paper presented at the International Housing Research Conference ‘Housing debates – Urban Challenges’, Paris, France, 3–6 July. Priemus H (1978) Volkshuisvesting; begrippen problemen en beleid. Alphen aan den Rijn, The Netherlands: Samson Uitgeverij. Priemus H (1983) Volkshuisvesting en woningmarkt [Housing System and Housing Market]. Volkshuisvesting in theorie en praktijk nummer 1. Delft, The Netherlands: Delft University Press. Ronald R (2008) The Ideology of Home Ownership. Basingstoke, UK; New York: Palgrave Macmillan. Torgersen U (1987) Housing: The wobbly pillar under the welfare state. In: Turner B, Kemeny J, and Ludqvist L (eds.) Between State and Market: Housing in the Post-Industrial Era, pp. 116–127. Gavle, Sweden: Almqvist & Wiksell International.
Wilensky HL, Luebbert HL, Hahn GM, et al. (1987) Comparative Policy Research. Berlin: Gower.
Further Reading Boelhouwer PJ (2002) Trends in Dutch housing policy and the shifting position of the social rented sector. Urban Studies 39(2): 219–235. Bourne LS (1981) The Geography of Housing. London: Arnold. Leibfried S (1992) Towards a European welfare state: On integrating poverty regimes into the European Community. In: Ferge Z and Kolberg J (eds.) Social Policy in a Changing Europe, pp. 245–279. Frankfurt, Germany: Campus Verlag.
Introduction The reason why governments intervene in the housing market can be explained on the basis of two important motives. The first motive is based on the poor results of a housing market which is completely steered by the free market. Almost all developed countries have established the right to decent housing in their constitution. Also, most countries have established minimum quality stand ards for housing in their legislation, which could in most cases not be realised in the free market. The second motive for government intervention in the housing market is the relation between housing and other policy areas. For instance, the battle against diseases and epidemics was the most important reason for many West European govern ments to start interventions in the housing markets in the nineteenth century. Also today, housing policy operates as a vehicle to reach policy goals across a broad spectrum of policy areas including social integration, environmental policy, spatial policy, and labour market policy. Despite the close relation between housing and govern ment policy, housing policy forms quite a specific element of the welfare state. As Torgersen put it: ‘‘Housing is the wobbly pillar under the welfare state’’ (Torgersen, 1987: 116). In contrast to social security, education, and health care, for example, identical and clear standard criteria which could be politically tested are lacking for housing. Politically it is not common that on the basis of certain objective criteria specific housing situations will be altered when the household situation changes. This is quite obvious, however, for health, education, and social security. The unclear way governments pay attention to the defini tion of housing need and the way this definition changes in time, changes in the housing situation of those who got certain benefits (like the increase in property prices and inheritances), or more broader policy goals like the creation of mixed neighbourhoods are the main reasons for the existing complex relation between the welfare state and housing. Also, Harloe states that housing is ‘‘the least decommodified and most market determined of the conventionally accepted constituents of welfare states’’ (1994: 2). Not only is the provision of housing mainly market determined, but it also differs in that, the costs of decommodified housing, and in particular social rented housing, are to a large extent charged to consumers. Finally, Bengtsson (2006) argued that housing policies, in contrast to other policies, are best understood as state correctives to the market.
WELFARE/WELL-BEING (Overview)
This complex relationship was for Esping-Andersen the justification for leaving out housing in his study, The Three Worlds of Welfare Capitalism (Esping-Andersen, 1990). Moreover, the position of housing within the wel fare state is far from obvious and has provoked a good deal of discussion. Some authors (e.g., Kemeny, 1992, 2001) focus on the relationships between the housing system and the welfare state, while others predominantly lay stress on the private market characteristics of housing (Harloe, 1995). The second part of this article pays atten tion to the way housing could be incorporated in the welfare state theory of Esping-Andersen and how this could be related to the development of the social rented sector in Europe. On the basis of the results of this elab oration, we also present a proposal for a modification of the welfare state typology of Esping-Andersen. Kemeny’s visualisation of corporatism plays a key role in this attempt. The problematic relationship between housing and government policy does not mean that governments do not have an important role to play in the housing market. On the contrary, despite the fact that exact definitions are difficult to formulate, almost all governments in the Western world have formulated general policy goals to establish enough affordable housing of good quality in the right place. Governments can hardly accept a full intro duction of the iron law of the housing market which states that those with the lowest incomes have to live in the least attractive houses (Doling, 1997; Priemus, 1978). After establishing the more general policy goals for housing by the government, the question arises as to what extent the government itself has to intervene actively in the housing market. The government has a choice of the following six policy options: doing nothing, exhortation, regulation, taxation, subsidisation, and self-realisation (Doling, 1997: 42). Only when using the last three instru ments does the government actively step in and become, together with households and housing suppliers, a direct player on the housing market. In this article, we first elaborate on the development of theories about housing and the welfare state. Since the 1970s, different theoretical frameworks have been devel oped to explain and describe this complicated relationship. In the second part of the article, we next focus on Esping-Andersen’s welfare state theory. His theory and typology have attracted considerable attention in international comparative housing research. Various researchers have discussed the position of housing within
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the welfare state in general and within Esping-Andersen’s framework in particular (see Boelhouwer and Van der Heijden, 1992; Brandsen, 2001; Doling, 1999; Harloe, 1995; Kemeny, 1992, 1995, 2001, 2006; Kemeny and Lowe, 1998; Kleinman, 1996; Matznetter, 2002). Most of the debate, however, has been at a conceptual or theoret ical level. Esping-Andersen’s work has rarely been tested, or directly related to housing practices. One exception is the study by Barlow and Duncan (1994), who relate the Esping-Andersen typology to housing production in the United Kingdom, France, and Sweden. Another excep tion is the research of Domburg-De Rooij and Musterd (2002) investigating the relationship between welfare state regimes (The typology of welfare states used by Domburg-De Rooij and Musterd differs from that of Esping-Andersen.) and segregation. And finally, Hoekstra tested the connection between welfare state regimes and dwelling type (Hoekstra, 2005). On the basis of an analysis of the conceptual framework of Esping-Andersen, the last section will present a modifi cation of his welfare state typology.
Theories of the Development of Welfare States and Housing The way the government chooses to play a role in the housing market has a central position in research on the development of housing systems and their relations to the development of welfare systems. This research discipline commenced towards the end of the 1970s and was dominated by convergence theories. Wilensky et al. (1987) showed that social and economic convergence theories had dominated decades of research into the development and functioning of the welfare state. This enduring paradigm presumes a relationship between the level of economic development and the level of public expenditure on welfare, such as social security, housing, and education. Notwithstanding the differences in cul tural and social characteristics of different countries or societies, economic progress undermines the traditional structure of care, including assistance offered by families, the private sector, and charitable institutions. This process is also explained by the development of a complex post industrial society. Much of this comparative research on housing can be traced back to the work of Donnison, and in particular his 1967 book, The Government of Housing. His central idea is that housing policy also converges because of an increasing correspondence between economic and demographic developments in countries despite partypolitical, ideological, and/or institutional differences between countries. In 1982, Donnison and Ungerson pub lished a modified version of this important book. In this book, they distinguish between a marginal and an institu tionalised housing policy. The former seeks to ensure a
basic level of housing quality and concentrates on helping the weakest in society. The authors argue that this form of housing policy is principally followed by moderately developed industrial societies. As industrial growth con tinues, housing policy also takes on a more institutional form. The government then develops a complex policy directed not only to the construction of housing but also to the distribution and the management of the dwelling stock. In order to achieve this, an extensive set of policy instruments is developed. These are designed to ensure a degree of equity, an increase in the quality of housing, and a reasonable distribution of expenditure on housing. Despite clear differences in the political backgrounds of the respective governments, the increase in the scope of government activity has been both quantitative (involve ments in more fields of policy) and qualitative (more farreaching policy aims). This increase is related to the rising expectations of a postindustrial society. During the last few decades, several critical remarks have been made on the convergence theory. First, there is little empirical support for the principles on which the theory is based. The theory itself has led to hypotheses and a number of descriptive studies. Another problem with the convergence theory is the scale at which it can be applied (see also Doling, 1990). The theory was originally formulated to describe the development of a society in broad terms. In order to test such theories, it often suffices to refer to aggregate data on government expenditures for core activities and other general macroeconomic and dem ographic trends. However, expenditure levels and policy goals may fluctuate widely by sector and through time. A third point of criticism concerns the supposed outcome of the housing systems. In contrast to Donnison’s position, government may be said to retreat rather than expand as the level of affluence rises. When housing-market shortages ease up, government supposedly retreats from housing, giving market forces more leeway. An alternative approach to research in the tradition of convergence theory, which has proved its value in com parative housing research since the mid-1970s, is the ‘structure of housing provision’ (SHP). This approach distinguishes social groups that can influence the way in which the provision of housing and housing services comes about. The relationships between these groups must be defined in order to investigate many issues asso ciated with housing. This approach explicitly recognizes that processes of change take place. As a result, the inves tigation of institutional changes forms a key empirical question for housing-related research (Ball and Harloe, 1990: 1). The context in which housing-market processes operate is subject to continual change. To understand the changes in the provision of housing and housing services, it is precisely these institutional changes that have to be recognised.
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The SHP approach analyses the relations of consump tion and production, as well as those of exchange. The SHP approach is explicitly not presented as a theory of housing. It provides a context within which many hous ing-related issues can be examined. It certainly does not specify what theoretical approach should be adopted in explaining the differences observed. For this, one has to rely on existing explanatory models, such as those based on neoclassical, Weberian, or neo-Marxist theories. Harloe and Martens (1987) also subscribe to the prop osition that housing-market processes in every country are a product of the specific interaction between political, economic, and ideological factors. For instance, the size of the owner-occupied sector cannot be explained by the mere fact that a country supports a policy of privatisation. In practice, the owner-occupied sector in the underde veloped regions of France fulfils a completely different function than it does in, say, the southeast of England. Furthermore, countries organise their nonprofit rented housing sector very differently. As a result, public-sector rented housing in, for example, Great Britain is much more vulnerable to policies of privatisation than in the Netherlands or Denmark. As noted above, those subscribing to the SHP approach argue that it is important to describe and account for institutional structures in order to provide a satisfactory explanation of housing-market processes. Among these structures, they include the different financial mecha nisms, the development of the construction industry, and the government’s land-use policy. Of course, these structures have their origins in past ideological, political, and economic developments. As a reaction to these quite mechanistic convergence theories in which ‘politics doesn’t matter’ forms a key element, a new group of divergence theories became popular in the 1990s. These theories pay more attention to country- and region-specific cultural processes and actors. The view that institutionalised relationships and structures within the housing system themselves become formative of new structures over time has led to the proposition that housing and welfare systems more gen erally may be expected to diverge to an increasing extent (Milligan, 2003: 37). These theories are some times addressed as middle-range theories (Kemeny and Lowe, 1998). These authors stress the specific political, ideological, and cultural differences to explain the differ entiation between housing systems (see also Mandic and Clapham, 1996; Merton, 1957). To help explain the perpetuation of different national characteristics in housing systems, a number of researchers have intro duced the concept of ‘path dependency’ (Boelhouwer and van der Heijden, 1992; Kleinman, 1996: 15). This concept refers to the tendency for solutions to problems or policy decisions, whether accidental or deliberately chosen, to become locked in through institutional and
ideological processes and, subsequently, difficult to change (Kleinman, 1996: 15). One of the most influential scholars of the divergence approach is Jim Kemeny. Kemeny distinguishes a direct relation between the development of housing systems and the social structure of a society which in his terms is strongly influenced by the dominant ideologies. For Kemeny, it is the wider social arrangement and ideolog ical dispositions in different countries, not the economic logic of capital or particular configurations of political power, which better explain how the choices of policy strategies come about and are maintained. Essentially, in his view, societies are either more collectivised in their social consciousness or more privatised. The continuum between privatisation and collectivism is presented in two different models: home-owning societies against costrental societies (Kemeny, 1995). Anglo-Saxon countries are defined as home-owning societies and are character ised by a dual rental market. Against a large owneroccupied sector, a small social rented sector is placed which is only accessible for low-income groups and which is highly segmented. Rent setting is organised by the private rented sector. The State stimulates by man agement of speech and direct and indirect subsidies the growth of homeownership. In the continent of Europe, more cost rental societies can be seen. The rental sector is well developed and the rents are based on the cost price and not on the market value. The division between the private and social rented sector is small and both are subject to the same legislation. Kemeny’s approach provides a theoretical basis (the maturation process) for explaining the potential for differ ences in housing outcomes to arise from long-term differences in housing policy strategies. With maturation, Kemeny is referring to the growing difference between the debt per house for the existing stock and for newly built houses. The way the maturation process is developed determines the position of the social rented sector on the housing market. If the government allows the introduction of the principle of rent pooling, a high maturation will also be reflected in the rent level of the social rented sector. The impact of the social sector increases, and gives the organisations the possibility to become an important player at different policy arenas. In those systems, it is also the social rented sector which is in charge of rent setting and not the private rented sector (Kemeny, 1995). According to Kemeny, because of the central position of housing in the welfare state, the choice for a unitary or dual rented system also has consequences for other policy areas. A dual rental system often corresponds with a social security system that is based on a safety net for the most vulnerable households in society. In such a model, the housing allowances often have residual characteristics. A society which is based on a safety net for the most vulnerable households has also some correspondence with
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another type of welfare system: the ‘asset-based’ or ‘prop erty-based’ welfare system (Doling and Ronald, 2010; Elsinga et al., 2007; Horsewood and Neuteboom, 2006; Ronald, 2008). The principle underlying an asset-based approach to welfare is that, rather than relying on Statemanaged social transfers to counter the risks of poverty, individuals accept greater responsibility for their own wel fare needs by investing in financial products and property assets which augment in value over time (Doling and Ronald, 2010). These can, at least in theory, later be tapped to supplement consumption and welfare needs when income is reduced. The potential wealth tied up in owner-occupied housing has been considered, more or less explicitly, to be a solution to the fiscal difficulties involved in the maintenance of welfare commitments, and through that, the asset in asset-based welfare has frequently become property or housing assets (Doling and Ford, 2007). The above sections have summarised several methods and approaches employed in international comparative housing research. Given the vehement polemics that occasionally erupt among exponents of these approaches, both in the literature and at conferences, it would seem that the differences between these approaches are unbridgeable. In practice, though, this is not the case. In several publications, these authors acknowledge that each of the methods contains valuable features that sometimes complement each other (see Lundqvist, 1991; Oxley, 1990). In addition, these approaches do not purport to employ a universal explanatory model. Rather, they sug gest methods and techniques which seem to provide insight into housing-market processes. For an explanation of these developments, it is often necessary to revert to more general theories, such as neoclassical, Weberian, and neo-Marxist explanatory models. Exponents of the various approaches tend to agree on the subjects and aspects that comparative research should treat. All these different approaches recognise the importance of factors outside the sphere of housing. It is only in terms of actual interpretation that they differ from one another. According to convergence theory, these factors explain the differences between housing systems. Other approaches regard these factors more as the context within which housing processes take place. But all of these approaches devote attention to how adaptation to changing circumstances takes place. This can occur as the result of government policies (policy-oriented approach) or through activities of various social groups that influ ence the provision of housing and housing services (provision-oriented and institutional approaches). As mentioned in the introduction, in the next part of this article, we will again discuss in general the complex relationship between the development of welfare states and housing. Esping-Andersen argues that welfare states can be reduced to three ideal typical welfare state regimes, which differ fundamentally from
each other. This has resulted in his well-known and widely used typology of welfare state regimes. In his theory of welfare state regimes, EspingAndersen explains how the differences between the three welfare regime types came about. Three factors were of particular importance: the way in which the mobilisation of the working class took place; the coalitions between the political parties; popular support for the conservation and expansion of the welfare state (EspingAndersen, 1990). It is important to recognise that the Esping-Andersen typology is of ideal typical nature. Most countries will only to some extent correspond to the welfare regime they are classified in (see, e.g., Kvist, 1999). Therefore, the typology should not be seen as an exhaustive classification system. Rather, it is an analytical device that can be used to interpret differences in welfare systems between countries. The section ‘The Theory and Typology of Esping-Andersen’ gives a brief explanation of Esping-Andersen’s welfare state theory. An application of his theory for housing is presented in the section ‘The Welfare State Typology Applied to Housing’. The result ing scheme of analysis shows how the three welfare state regimes differ on some important aspects of the housing system. As a result of this analysis, the section ‘The Relation between the Modified Theoretical Framework and the Development of Social Housing in Europe’ gives a short elaboration of how this theory could be connected to the development of social housing in Europe.
The Theory and Typology of Esping-Andersen Three Welfare State Regimes The typology of Esping-Andersen makes a distinction between the three welfare state regimes. The most impor tant characteristics of these three regime types are briefly discussed below. We identify some countries belonging to each of the regime types. In social-democratic welfare state regimes, the provi sion of welfare services is dominated by the State. There are universal welfare services of a high level, to which a large proportion of the population has access. As a result of the redistributive effects of the welfare state, income differences are relatively low. Sweden is the classic exam ple of a social-democratic welfare state, although other Scandinavian countries also belong to this regime type. In corporatist welfare state regimes, the State is fairly active in the provision of welfare services. However, this does not lead to income redistribution, since preservation of the existing hierarchy in society is the starting-point for welfare polices at State level. Consequently, the welfare provision is segmented; different groups are entitled to different welfare services; and the traditional family is often explicitly favoured. Furthermore, the State is
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definitely not the only provider of welfare services. In this respect, the family and private nonprofit organisations (churches, trade unions, and so forth) also play an important part. Austria, Germany, Italy, and Belgium are representa tive corporatist welfare state regimes. In this article, like Esping-Andersen (1999: 4), we also treat the Mediterranean welfare state regime as part of the corporatist welfare state. The liberal welfare state regime is characterised by little State interference and a strong market orientation. Private companies are responsible for the majority of the welfare services. The State only provides help for a limited group of people with really low incomes (safety net). As a result, the society is characterised by dualism. There is equality (but also poverty) among the recipients of state welfare, while there is differentiation in income in the rest of the society. The United States, Australia and, to a lesser extent, the United Kingdom and Ireland represent liberal welfare state regimes, although the United Kingdom is sometimes seen as a mixed regime with both social democratic and liberal elements, though per haps moving more towards the latter.
The Welfare State Typology Applied to Housing Esping-Andersen discriminates between the three welfare state regimes on the basis of three (strongly interrelated) criteria: decommodification; stratification; the arrangements between the State, market, and family. These three cri teria are applied to housing and translated into four specific housing aspects, which are expected to cover an important part of the housing system. Figure 1
shows the relationship between Esping-Andersen’s three criteria and the four aspects of the housing system to which they have been converted.
Decommodification When applied to housing, decommodification can be defined as the extent to which households can provide their own housing, independent of the income they acquire on the labour market. Thus, governmental inter ference (It should be noted that the State is not the only actor responsible for decommodification, since the family can also have decommodifying effects. However, follow ing Esping-Andersen, we focus on the decommodification caused by the State.) is involved with the price of housing and with household incomes. The welfare state can decommodify housing not only via price regulation and production subsidies (affecting the price of housing), but also via subject or to the household directed subsidisation, which influences the household income (Lundqvist, 1991). The latter can involve both general income support (pensions, unemployment benefits) and subject subsidies that are specific to the field of housing. In this article, we have restricted ourselves to the last category. Thus, the decommodification is translated into the following two housing aspects: housing subsidisation (both object and subject subsidies), and price regulation.
Stratification The welfare state is a system of stratification; the way in which the welfare state distributes welfare services has
Arrangement between the State, markets and family
Stratification
Decommodification
Subsidisation
Price fixing and price regulation
Organisation production newly built houses
Housing allocation
Relation Translation Figure 1 The three criteria of Esping-Andersen applied to housing.
Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology.
Housing Theory and Society 20(2): 58–71.
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consequences for the hierarchy in society. In this respect, a distinction can be drawn between economic stratifica tion and social stratification. Economic stratification refers to income distribution within a society, whereas social stratification is related to differences in social status. Social stratification can be related to economic factors (income), as also to noneconomic factors such as ancestry, or occupation. In the field of housing, stratification is reflected in the process of housing allocation. Without State interference, housing allocation could be expected to be a direct reflection of the economic stratification in a society; households with the most resources would obtain the best and most expensive houses. However, the State is able to regulate the housing allocation process. Certain groups can be favoured by applying allocation rules. These State interventions can have different objectives. They can aim not only at increasing the choice for lowincome groups, but also at the preservation of status differentials.
The housing associations in the different European coun tries are a good example of such institutions. The relationships between the State, market, and fam ily determine which welfare services are provided, how they are distributed, and for which groups they are des tined. In other words, the mix between the State, market, and family is decisive for the decommodification and stratification in a country. Although Esping-Andersen is not explicit on this matter, we assume that the mix between the State, market, and family is superior to decommodification and the stratification. The specific configuration between the State, market, and family in a certain society then represents the essence of the welfare state. The implication is that the criteria discussed earlier in this section are in fact all influenced by this configu ration. The most direct influence can be seen in the organisation of the production of newly built dwellings and the way in which actors from the public, market, and household sectors participate in this process. Towards a Scheme of Analysis
The State, Market, and Family Mix Welfare services can be provided by the State (or public sector), as also by the market or the family (or household sector). The differences between the State, market, and family are connected with the so-called ‘decision units’ and the way the decisions are coordinated (Priemus, 1983). For the State, the decision units are public bodies; for the market, suppliers and buyers; and for the house hold sector, small groups (households, families, friends, and associations). Every sector is characterised by a spe cific kind of coordination of decisions. Public bodies are responsible for the decisions that are taken in the public sector (supported by laws or regulations), while the coor dination of decisions in the market sector takes place on the basis of the ‘market-mechanism’ (with the price as an important point of orientation). In the household sector, the coordination of decisions occurs without financial transactions and prices, often on the basis of reciprocity. It has to be noted, however, that the above-mentioned trichotomy between the State, market, and family refers to an ideal typical situation. In reality, there are many graduations and mixes, both with regard to the decision units and the coordination of decisions. First of all, it is obvious that the decision units in the State and the house hold sector frequently enter the market (mostly as buyers, but sometimes also as suppliers). On the other hand, nowhere in the world is a market totally free; every market is subject to government regulations and has some informal aspects. Eventually, it is important to real ise that there are decision units that do not properly fit within one of the three sectors. In virtually every country, there are institutions that combine private (household sector and market) and public (state) interests and tasks.
We hypothesised that the four housing aspects in Figure 1 differentiate between the three welfare state regimes. The hypothesis led to the scheme of analysis (see Table 1), which could be applied to the housing system of a specific country. The scheme of analysis was deductively constructed on the basis of the welfare state typology of Esping-Andersen. A more detailed underpin ning of this deductive process can be found in Hoekstra and Reitsma (2002). This implies that the scheme is of an ideal typical nature; when constructing the scheme, developments that are specific for a particular country were not taken into account. Accordingly, the scheme should be considered as a mere analytical device that can be used to make sense of empirical country data on housing. The scheme solely applies to the national level. It does not take into account territorial differences within countries. Kemeny’s View of Corporatism According to Kemeny (1995), Esping-Andersen uses an unusual definition of corporatism, since he clearly relates this concept to conservative elements, like the preservation of status differentials in society and the preferential treatment of the traditional family. In the political sciences, the definition of corporatism is more neutral: there, corporatism is a system of cooper ation and compromise between capital and labour, coordinated by the State. Following this line of thought, Kemeny comes to the following working definition of corporatism: A system of institutionalised political rep resentation of different interest groups that is essentially founded on compromise, and accommodation between
Housing and the State in Western Europe 369 Table 1 Differences between the housing systems of the three welfare state regimes Criterion
Social-democratic
Corporatist
Liberal
Decommodification Stratification Mix of the State, market, and family
�
Large Relatively low � Dominant position of the State
� �
�
State regulation
�
Quite large High, mainly based on social status � Important position for the family � Considerable influence for private nonprofit organisations � Functional decentralisation, incremental, problem-solving policies � Preservation of the social stratification in society � Preferential treatment of the traditional family � Stimulation of households and other private actors to take initiatives on the housing market � Segmented subsidies; specific arrangements for specific groups
�
�
Moderate State influence State regulation of prices to correct negative effects of the market � State intervention to correct the market � Certain groups may be favoured in the allocation process
� Market determination of house prices
General housing policy objectives
Subsidisation
Price setting and price regulation Housing allocation
Strong central government influence � Guaranteed universal high level of housing quality
Large-scale production subsidies � Subject subsidies for large target groups � Strong State influence on price setting and price regulation � Allocation on the basis of need �
�
Low High, mainly based on income � Dominant position of market parties
Relatively little State regulation (at both central and local levels) � Dominant position for the market � State only supports marginal groups �
� �
Means-tested subject subsidies Few production subsidies
�
Market determination of housing allocation in a large part of the housing stock � Regulated allocation in a small part of the housing stock (reserved for lowincome groups) �
Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71.
conflicting power groupings – whether these be based on class, religion, or ethnicity (Kemeny, 1995: 65–66). Kemeny asserts that, when so defined, corporatism applies to corporatist as well as social-democratic wel fare state regimes. He argues that both the continental European countries (corporatist welfare state regimes) and the Scandinavian countries (social-democratic welfare state regimes) are characterised by a political structure that is based on corporatism (in the political science definition). In the Anglo-Saxon countries on the other hand, there is little political corporatism and often a dual political system (two main parties). According to Kemeny, the Scandinavian and continen tal European countries differ from each other in one important aspect: the influence of the labour movement in a historical perspective. In Scandinavia, the strong position of the labour movement has resulted in a welfare state in which the central government has a dominant position and social equality is of great importance. Kemeny refers to this as labour-led corporatism, where the workers have a relatively strong position (Kemeny, 2006: 8). In continental Europe, however, the labour movement was less strong. As a result, private nonprofit organisations played an important part in the provision of welfare services in continental Europe, and the ability to cope on one’s own was strongly stimulated. Kemeny
refers to welfare states of this kind by the term ‘capital led corporatism’ (Kemeny, 2001: 62). A Proposed Modification of the Theoretical Framework Kemeny’s ideas suggest that the political structure criterion should have an important position in the theoretical framework. Kemeny’s distinction drawn between liberal and corporatist (labour-led and capitalled corporatism) welfare states is made principally on the basis of this criterion. On the basis of the changing role of the central government in many Western European countries in the 1990s, we subdivide Kemeny’s capital-led corporatism into two types: con servative corporatism and modern corporatism. Conservative corporatism corresponds with corporatism as defined by Esping-Andersen, whereas modern corpo ratism refers to a style of governance whereby the central government switches to a more indirect mode of governance, by defining the policy frameworks within which the local authorities and the private actors operate (see Hoekstra, 2003, for an elaboration for the Dutch housing market). Thus, next to liberalism, we distinguish three different kinds of corporatism: labour-led, conser vative, and modern. In short, we have arrived at a
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modified theoretical framework that differs from the original framework (see section ‘The Theory and Typology of Esping-Andersen’, Table 1) on the follow ing three points: political structure criterion has been added to the • The criteria listed in Table 1. The social-democratic welfare state regime is consid • ered to be a specific form of the corporatist welfare
•
state regime: labour-led corporatism. The corporatist welfare state regime of EspingAndersen is subdivided into two types: a conserva tive corporatist welfare state regime (coinciding with Esping-Andersen’s original corporatist welfare state regime) and a modern corporatist welfare state regime.
Table 2 shows how the various welfare state regimes of the modified theoretical framework differ with respect to these characteristics. Figure 2 shows the same information in the form of a diagram, based on Evers’ State–market–family triangle (1988).
The Relation between the Modified Theoretical Framework and the Development of Social Housing in Europe The modification of the theoretical framework in the previous section was constructed inductively. Adaptations were partly derived from concepts defined by Kemeny. The modified theoretical framework could be used as a basis for the interpretation of the develop ments within country-specific housing systems. In this
article, we will connect in short, the new theoretical framework to the development of social rented housing in Europe. The development of the social rented sector in Europe has been described by several authors in the past (Boelhouwer and van der Heijden, 1992; Danermark and Elander, 1994; Harloe, 1992, 1994; Murie, 1992). As noted by many of these authors before (see Danermark and Elander, 1992: 2 for an overview), the concept of social housing, although used as if its meaning was selfevidently clear, takes on different meanings in various national contexts. Sometimes it is connected to council housing (like in the United Kingdom), sometimes as pub licly subsidised housing, irrespective of ownership (like in Germany), sometimes as intermediate housing (like in the Netherlands), or as an umbrella concept, covering various types of housing in terms of ownership and tenure. Nevertheless, despite these and other differences, histor ically, the term social housing has been ascribed some dimensions that are quite similar from country to country, thus making comparative discussions meaningful (Danermark and Elander, 1992: 2). As summarised by Harloe (1992), social rented housing can be very broadly characterised as having three major characteristics: First, it is provided by landlords at a price which is not primarily determined by considerations of profit. Second, it is administratively allocated according to some concep tion of ‘need’. Thirdly, government control over social rented housing is extensive and has become more over time. With regard to this last characteristic, things have changed in the last decade. Social landlords, for instance, in the Netherlands are much more independent of the government than they were before.
Table 2 Main characteristics of the four welfare state regimes according to the modified theoretical framework
Decommodification Influence of central government Degree of political corporatism Fragmentation in the provision of welfare services Treatment of the traditional family in welfare policies Role of the State, market, and family in the provision of welfare services
Labour-led corporatist
Conservativecorporatist
Modern corporatist
Liberal
High High and direct
Relatively high Quite high and often indirect Many corporatist structures and processes Fragmentation on the basis of occupation and/or social status
Relatively high Quite high and often indirect Many corporatist structures and processes Fragmentation on the basis of measurable criteria
Low Low
Preferential treatment for the traditional family Important (if not dominant) position of the family
No preferential treatment for the traditional family Welfare services are provided by both market and the State
Many corporatist structures and processes Fragmentation on the basis of measurable criteria No preferential treatment for the traditional family Dominant position of the State
Few corporatist structures and processes Fragmentation on the basis of measurable criteria No preferential treatment for the traditional family Dominant position of the market
Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71.
Housing and the State in Western Europe 371
Conservative corporatism
Traditional family privileged
Fragmentation to maintain stratification
Family
State
Market Traditional family not privileged
Liberalism
Few corporatist structures and processes Few and direct state interference
Modern corporatism
Labour-led Fragmentation on corporatism objective grounds
Corporatist political structures processes Moderate and indirect state interference
Low decommodification
Many and direct state interference High decommodification
Figure 2 A proposed new conceptual model for the welfare state. Adapted from Hoekstra J (2003) Housing and the welfare state in the Netherlands. An application of Esping-Andersen’s typology. Housing Theory and Society 20(2): 58–71.
With our adjusted welfare state typology, it is possi ble to structure the position of the social rented sector more precisely. As explained in the section ‘Theories of the Development of Welfare States and Housing’, Kemeny’s elaboration between home-owning and costrental societies could be the starting point. In his article ‘Corporatism and Housing Regimes’, Kemeny (2006) argues on the basis of a division between capital-led and labour-led corporatism that there is a connection between the specific corporatistic welfare state and the existence of an integrated rental market with a strong social rented sector. Kemeny argues that the corporatist power system indicates the need to achieve compro mises. Corporatist compromise solutions entail a political solution that takes into consideration several different interests. The fragmentation of political parties resulting in coalitions and minority governments being the norm may be part of the explanation for the rise of an integrated market and a strong social rented sector. The latter can take many shapes and forms such as municipality-owned companies, voluntary or charitable societies, trusts, rental cooperatives, and even privately owned nonprofit enterprises (Kemeny, 2006: 12). For right-wing hegemonic coalitions who could be classified as liberal welfare states, it is quite clear that there will be a choice for a dualist rental system where nonprofit activities are restricted and nationalised. Social rented housing is incorporated into a publicly controlled planned economy and shaped into a low-income
housing sector (command economy means-tested public renting). Examples are the United States, Canada, Australia, New Zealand, and, to a lesser degree, the United Kingdom. The corporatist welfare states are more related to an integrated rental market with a specific leading role for the social rented sector (Kemeny, 2006: 13). In conservative corporatist coun tries, we could still observe a strong influence of rightwing parties and a social rented sector which is limited and has a limited impact on the rental market. We also could expect a variety of ownership forms of social rental housing. Examples of these countries are Germany and Switzerland. In the labour-led corporatist countries, we would expect a bigger and more uniform social rented sector and a very small profit rented sector. The social rented sector is then big enough to have a leading position on the rental market. Also, the influence of the tenant and/or the State could be more explicit. Clear examples of these types of corporatist states are Sweden and Denmark. In the modern corpo ratistic welfare state, the role of the State is smaller and the role of the market, also for the social rented sector, is bigger than in the labour-led corporatistic state. A clear example of that is the social rented sector in the Netherlands. With 33% of the housing stock, the social rented sector in the Netherlands still has a dominant position not only in the Dutch rental market, but also in the overall housing market. The State largely confines itself to creating the conditions and to
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formulate the policy frameworks within which local government authorities and private actors operate. This new policy framework brought the housing asso ciations in the Netherlands into a very powerful position. They are financially very strong and are in the bigger cities dominating the local rental market with regard to their housing stock and have a crucial role in urban renewal developments. A relevant question for the future is if more corporatist welfare states will develop in the direction of a modern corporatist welfare state and if the right-wing/conservative parties and the liberal-oriented neoclassical economies will approve such a development. More specifically, the role of the European Commission and the way the policy of free competition is implemented in the near future by spe cific laws from Brussels will probably provide an answer to the question of whether corporatist welfare states in general will have a bright future. See also: Asset-Based Welfare; Economics of Social Housing; Gender and Urban Housing in the Global South; Housing Subsidies and Welfare; Social Housing and Social Problems; Social Theory and Housing.
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Housing and the State in Western Europe 373 Oxley M (1990) The aims and methods of comparative housing research. Paper presented at the International Housing Research Conference ‘Housing debates – Urban Challenges’, Paris, France, 3–6 July. Priemus H (1978) Volkshuisvesting; begrippen problemen en beleid. Alphen aan den Rijn, The Netherlands: Samson Uitgeverij. Priemus H (1983) Volkshuisvesting en woningmarkt [Housing System and Housing Market]. Volkshuisvesting in theorie en praktijk nummer 1. Delft, The Netherlands: Delft University Press. Ronald R (2008) The Ideology of Home Ownership. Basingstoke, UK; New York: Palgrave Macmillan. Torgersen U (1987) Housing: The wobbly pillar under the welfare state. In: Turner B, Kemeny J, and Ludqvist L (eds.) Between State and Market: Housing in the Post-Industrial Era, pp. 116–127. Gavle, Sweden: Almqvist & Wiksell International.
Wilensky HL, Luebbert HL, Hahn GM, et al. (1987) Comparative Policy Research. Berlin: Gower.
Further Reading Boelhouwer PJ (2002) Trends in Dutch housing policy and the shifting position of the social rented sector. Urban Studies 39(2): 219–235. Bourne LS (1981) The Geography of Housing. London: Arnold. Leibfried S (1992) Towards a European welfare state: On integrating poverty regimes into the European Community. In: Ferge Z and Kolberg J (eds.) Social Policy in a Changing Europe, pp. 245–279. Frankfurt, Germany: Campus Verlag.