European best practice: Euro stars

Polska/Poland
The years since the end of communist rule have seen Poland gradually withdraw from social housing. Blocks have been sold to tenants at nominal rates and pre-war homes "restituted" to their original owners. Since 1996, municipal stock and some owned by arm's-length, state-controlled "cooperatives" has transferred to a new type of not-for-profit housing association called a Towarzystwo Budownictwa Spo ecznego (or TBS for short).

TBSs are similar to our own arm's length management organisations and are designed to upgrade stock in poor condition by side-stepping local authority borrowing restrictions. Fully owned by the municipality they operate in, TBSs focus on construction. In Szczecin, for instance, half the homes built this year will be for the Szczecin TBS. Their rents are regulated by government and they provide management and repairs services to blocks that transferred to communal ownership.

Development funding comes from the National Housing Fund, a state-owned bank that makes soft loans. TBSs can borrow up to 70% of capital costs, with the rest usually provided by the municipality as land or subsidy in exchange for nomination rights.

As an alternative, some TBSs have pioneered a shared-ownership model where a person provides a third of the development cost of a flat. When this person moves, their equity share must be sold to someone else on a list.

TBSs are also obliged to improve on the energy-efficiency targets in Poland's building regulations. "Better insulation is great for low-income tenants and the market provides enough critical mass to interest manufacturers of high-insulation glazing," says Hans van der Sanden, a consultant working with Szczecin TBS.

Nederland/Netherlands
Like the UK, the Netherlands has a social rented sector larger than the private rented sector, pockets of high density caused by a shortage of land and a legacy of mass developments in the 1960s that present a pressing regeneration agenda.

One subject that has attracted interest from other countries is the Netherland's recent "reconciliation" process. In 1995, the government wrote off housing associations' outstanding state loans in exchange for relinquishing future grants. In most cases, housing associations began new lives as independent commercial enterprises with a one-off state "dowry".

In theory, they traded subsidies for independence. But in practice, regulation and state rent control limit their freedom.

Individual housing associations raise finance backed by the guarantees of the whole sector, which is a bit like the National Housing Federation having its own bond rating for the sector. A self-policing system avoids the risk of one financially ailing association blackening the reputation of the entire sector as more robust associations scoop up struggling or vulnerable associations in mergers.

Economic and community development is not seen as a priority among housing providers. "They are more focused on their core business of producing and managing social housing," says Ken Walker, housing consultant and coordinator of knowledge-sharing group Euro-HP. Dutch housing associations develop sheltered or specialist housing, but leave the management and letting to others.

Good design, high-quality interior finishes and environmental excellence are a priority for Dutch housing providers; building regulations are stringent and space norms are generous. However, Robert Maas, head of the policy department at Patrimonium, one of the Netherland's largest associations, says that although architectural aspiration has raised standards, it has made developments more costly. "The more participants you have, the longer the list of demands and the more difficult it gets," he says.

In another parallel with the UK, the Dutch housing sector is concerned about its image. Associations there ran a national TV advertising campaign a few years ago to promote social housing. However, the campaign was pulled after proving too successful: landlords were flooded with more enquiries than they could cope with.

La France/France
French social landlords come in two flavours: municipal "habitation loyés modérés" (homes at low rents) linked to councils and similar to our arm's-length management organisations, and private HLMs, which are more like our housing associations but with shareholders. The latter rebranded themselves and their trade body last year as "Entreprises Sociales pour l'Habitat" stressing their role as social businesses.

HLMs operating in the sprawling suburbs face a regeneration challenge but their response is hampered by regulatory constraints. However, the picture is slowly changing: the ESH is lobbying the government for more freedom to assemble sites and undertake commercial projects in exchange for losing favourable tax status in regeneration areas.

In high-density urban areas, stock also tends to be fragmented among several HLMs, a hangover from the 1960s and 1970s when HLMs were given land parcels and invited to develop. Today, there is a drive to merge and rationalise to create economies of scale. Stephen Hall, a researcher from Birmingham University involved in a project on French low demand, has found that landlords are skilled at gathering research data. They tap into a system run by public-sector partnerships in each conurbation and, says Hall, "share quite sensitive information on void levels, turnover and rents".

ESH consultant Pierre Sudont says private HLMs are about to enter a period of upheaval.

A government policy decentralisation will move power from Paris towards regional public sector partnerships and changes to governance rules will affect the make-up of HLM boards and their shareholders.

ESH members, adds Sudont, are not currently making high architectural input to developments a priority, being more concerned with construction quality and durability.

Sverige/Sweden
Swedish housing associations are akin to the UK's arm's-length management organisations: limited companies managing municipal stock with links to the local authorities that appoint their boards. Although notionally independent, they are vulnerable to changes of political control, and there is often a high turnover of directors. As a result, Swedish housing associations tend to keep their eyes on medium-term goals rather than long-term strategies.

In the past four years, municipal housing company Stockholmshelm has seen one in 10 of its inner-city homes disappear into private hands. At the moment, it is under instruction to build 500 replacement apartments on infill sites to address acute housing need, but site assembly and planning is expected to take two to three years.

Outside the city centre, Stockholmshelm is also involved in major regeneration projects on ex-industrial and port sites owned by the city. In areas such as Hammarby Sjostad, several housing associations and private developers build to a masterplan developed by the city with no differentiation in the visual quality or design standards of the blocks.

Political direction from councillors inhibits the ability of Swedish housing associations to function as flexible "social businesses", they say. "We are almost only focusing on housing. We are helping on the edge, but social exclusion is not a major task," says Bjorn Lindstaf, a researcher at Stockholmshelm. Provision of suitable homes and support for special attention groups varies considerably from one municipality to another, depending on local economic and political circumstances.

Unlike the UK, housing companies let right across the income spectrum. "We have homes for everyone, we don't care how rich they are," says Lindstaf. However, new-build properties – with build costs of up to £1800/m2 – are too expensive for low-income tenants, who tend to be concentrated in older properties. Immigrant communities are generally priced out of the inner city and into the outlying suburbs.

Rents are relatively high, and tenants expect high standards of cleaning and maintenance. Choice-based lettings system are common, giving tenants the right to move to a better flat or more desirable location after 10-15 years.

The principal cities of Stockholm, Gothenburg and Malmö are currently experiencing strong demand – but further north, low demand is a problem in the underpopulated rural areas. There, vacancy rates can run as high as 30%.