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assistance from international organizations greatly influenced the development of
market-based housing finance and boosted housing market activity in developing
countries. 5 Despite some diversity in housing policy experience, most countries
opted for promoting housing markets and individual homeownership, privatizing
social housing programmes and deregulating housing finance markets.
5.
In some countries, selling publicly owned houses to tenants has been seen as a
way to increase homeownership while diminishing State expenditure. 6 Privatization was
also supported by increased stigmatization of public housing as centres of extreme
poverty, crime and segregation. In Europe and North America, the privatization of
public housing has taken various forms, including the sale to sitting tenants of public
rented housing through right-to-buy policies (e.g. the United Kingdom), property
transfers to not-for-profit actors (e.g. the Netherlands) and, in some cases, to profitmaximizing actors (e.g. Germany 7 and the United States of America 8).
6.
During the 1990s, most formerly planned economies also embarked on
projects of large-scale privatization of public housing through “right to buy”
programmes, resulting, in some cases, in the almost complete eradication of public
housing. In most countries, 9 this process led to radical changes in tenure structure;
in many formerly planned economies owner-occupied housing now forms more than
90 per cent of the housing stock (e.g. 96 per cent in Estonia, 77 per cent in
Slovenia 10 and more than 80 per cent in China).
7.
Even in countries where massive privatization did not take place, the
ideological transfer of responsibility for provision of housing to the market has been
accompanied by the view that homeownership is the best tenure option, to be placed
at the centre of all housing policies. This process has overshadowed other wellestablished or alternative tenures, such as rental housing (public and private) and
different forms of cooperative and collective ownership, among others. 11
Consequently, since the end of the Second World War homeownership rates have
been constantly climbing 12 and by mid-2000 had reached more than 50 per cent in
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5
6
7
8
9
10
11
12
4
ECE, Housing Finance Systems for Countries in Transition, p. 7; World Bank, The Emerging
Role of Housing Finance (Washington, D.C., 1988).
United Nations Human Settlements Programme (UN-Habitat), Affordable Land and Housing in
Europe and North America (Nairobi, 2011), p. 9.
K. Scanlon and C. Whitehead, “Le logement social en Europe: tendances communes et diversités
persistantes”, in C. Lévy-Vroelant and C. Tutin, eds., Le logement social en Europe au début du
XXIe siècle: la revision générale (Rennes, France, Presses Universitaires de Rennes, 2010),
p. 24.
In the United States, the Housing and Community and Development Act of 1974 ended most
new construction of public housing and initiated the Housing Choice Voucher Program (Section
8), shifting funds from public housing authorities to the private sector, which was to construct
low-income housing. These “affordable” houses were eventually too costly for many public
housing tenants (A/HRC/13/20/Add.4, paras. 10, and 25).
Only a few countries did not adopt the “right to buy” for tenants (e.g. the Czech Republic and
Poland).
Replies from Estonia and Slovenia to the questionnaire sent by the Special Rapporteur to
Member States on 5 April 2012 (hereafter “the questionnaire”) .
Julie Lawson, Tony Gilmour and Vivienne Milligan, International Measures to Channel
Investment towards Affordable Rental Housing (Australian Housing and Urban Research
Institute, 2010); Fée, p. 80.
Mikael Atterhög and Han-Suck Song, “A Survey of Policies that May Increase Access to Home
Ownership for Low-Income Households”, Housing Theory and Society, vol. 26, No. 4 (2009),
pp. 248-249.
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