European policy debates often become Americanized because of the American domination of social media. This tends to be troublesome, leading Europeans to see their policy problems through frames into which they do not really fit. But it seems to me that the housing debate in Europe, and especially in continental Europe, might actually be improved by borrowing some ideas from the Americans. 

Here are some claims that many Americans agree on. They agree that their country has a housing shortage; they agree that it is caused mostly by land-use restrictions, especially zoning, which bans additional housing from being built in suburbs; and they agree that the main cause of these restrictions is suburban NIMBYism. They also think that burdening development with expensive environmental and social obligations often stops them from happening at all by making them economically unviable (they even have a catchy name for this, an ‘everything bagel’).  All these claims are, in my view, broadly true. 

A huge movement, known as YIMBYism (YIMBY stands for 'Yes In My Backyard'), has developed around these ideas. It includes great scholars like Chris Elmendorf and Ed Glaeser, remarkable campaigners and thinkers like Brian Hanlon, Alex Armlovich, Nolan Gray, Sonja Trauss, Mike Kingsella, Annie Fryman, Emily Hamilton, Salim Furth and Matthew Yglesias, and a forest of organizations like California YIMBY, the Welcoming Neighbors Network, Abundant Housing Massachusetts, Open New York and YIMBY Action. I was once invited to ‘YIMBYtown’, a national conference of YIMBYs, and watched with astonishment as a huge auditorium filled with delegations representing YIMBY organizations from across the republic.

An increasing number of British people think that these claims are also true of Britain, with a few provisos to which I will return below. But I have repeatedly been struck by how rare the corresponding views are in continental Europe. Continental Europeans are aware of high housing costs, but they are much less likely to discuss a housing shortage, and even if they do, land-use rules are rarely discussed as its primary cause. There is near-total silence on the question of suburban zoning. YIMBYism is virtually nonexistent in continental Europe. When Europeans do debate housing, they tend to argue about rent controls, expropriation, public housing, and environmental regulations.

It is natural to assume that this is because Europe’s housing shortages are much less bad, and hence that Europeans can afford to focus on questions of distribution and quality instead. But this just isn’t true. In fact, European housing shortages are generally worse than America’s. You can see this in the great dataset assembled by Katharina Knoll and her collaborators, of which we have reproduced a selection above. European house prices were roughly flat in the nineteenth and early twentieth century, but they have risen steadily since the Second World War. They are now much higher than American house prices, which remained remarkably stable until recently, and which have only risen rather modestly in the last quarter of a century, though of course much more steeply in a few urban centers like San Francisco and Manhattan. Knoll found that about 80 percent of this increase is attributable to regulatory restrictions on housebuilding.

What restrictions are these, exactly? Cities can grow upwards or outwards. Historically they did both: most housing demand has generally been met through outward expansion, but cities have also densified when geographical constraints, fortifications, or transport limitations have constrained outward growth.

One possibility is that European housing shortages are caused by constraints on outward expansion, being in this respect unlike American ones, where most cities have been allowed to sprawl with little restraint. To some extent, this is certainly true. As British readers will know, England is the pre-eminent example of this. Since the 1950s England has had a system of ‘green belts’, areas around cities where building is forbidden. Many English cities are not really larger today, in terms of spatial area, than they were in 1945. 

Many continental cities have constraints on outward growth too, but not to the same extent as Britain. In fact, most European cities have grown a lot since 1945. In the image above, a map of Paris from the 1930s is inset in a satellite image of the city today at the same scale. As you can see, the city’s surface area has grown severalfold. Other European capitals like Rome and Madrid have seen similar or greater expansion. 

Even where constraints on outward expansion are tight, however, they cannot be the whole story behind the housing shortage. As is sometimes pointed out in Britain, if densification were allowed, then the great majority of the housing prevented by green belts would be delivered by densification instead. Housing is somewhat more costly to build at high densities than at low ones, so there is some deadweight loss in housebuilding if outward expansion is constrained while densification is permitted. But this effect is far too small to explain the increase in house prices in Europe since 1914, when, after all, most urban continental Europeans lived in flats. So although outward expansion of cities often is more constrained in Europe than it is in America, restrictions on zoning remain of decisive importance. Without densification restrictions, housing shortages will only ever be serious in cities where land is really intensely scarce, as in Hong Kong.

Now, some European countries do not really have low-density suburbia in the American manner. This is especially true of Spain, and it is somewhat true of Italy, Portugal and Greece. Density restrictions will still play a role in these places, since virtually all Mediterranean cities have strict mid-rise height limits across most of their urban areas, but they have a rather different character to those of the United States. In France, Germany, Austria, Switzerland, the Low Countries, Ireland and Scandinavia, however, extensive low-density suburbs exist, very much as they do in the USA. French or Norwegian or Irish urbanism since the 1950s has not been so wildly different in character to American, a fact which people only fail to notice because a greater share of the build stock dates from earlier times.

All of these suburbs are protected by zoning. In fact, zoning was invented in Europe, in Germany and Austria-Hungary, in the late nineteenth century. Here is the zoning scheme for Berlin in about 1905. German cities had a very sharp division at that time between rich suburbs called villa colonies, mostly along the railway lines going west from the city, and the dense and socially mixed urban core. I have marked with ‘V’s all the villa colonies on this map. You will see they all fall into the green-color zoning district, which basically prohibited anything except two-storey detached or semi-detached houses. These plans functioned from the start to protect the rich Berliners who lived in these villa colonies from disruption and loss of social exclusivity.

A hundred and twenty years later, and Berlin’s zoning plan is still doing basically the same thing. The villa colonies are now marked as ‘Wohnbaufläche mit landschaftlicher Prägung’, meaning ‘Residential areas with landscape character’. This zoning district entails much the same restrictions as the green marking did on the 1905 plan. Similar stories could be told for most other European cities.

Are these restrictions caused by NIMBYism? Europeans are often a bit nonplussed if they are asked this. They have never heard of NIMBY resistance to suburban densification: the villains of YIMBY discourse in the USA are never mentioned in European media or politics. It seems that there is no resistance to densification in Europe, and in a sense this is true. But maybe there is no resistance to densification only because there is no political pressure for it, meaning that the issue never arises and active resistance is superfluous. 

This is vividly apparent to me from the case of Britain. There is political conflict about development in Britain, but it is focused, not unnaturally, on the kinds of development that actually happen sometimes: building on fields, public housing regeneration, and urban brownfield sites. Nobody ever talks about suburban densification because it just doesn’t take place. There was a debate about suburban densification when the government briefly enabled more of it in the 2000s (‘garden grabbing’ was the buzz phrase), but after the NIMBYs decisively won, most people forgot the issue, and the NIMBYs went back to being politically inactive members of the public. 

I suspect the same is often true in the rest of Europe: NIMBYism is the ultimate reason why the French and German states don’t solve their housing shortages through unbanning densification, but since the claims of the NIMBYs have been preemptively conceded by everyone, NIMBYism has basically remained latent. That doesn’t mean that NIMBYism is the source of all restrictive land-use rules in Europe – when I visited Madrid recently, I got a strong impression that the city’s outward growth is constrained less by NIMBYism than by sheer bureaucratic sclerosis – but it is probably the key factor behind restrictions on densification.

So European cities have housing shortages, and they have zoning designed to prevent more housebuilding in existing suburban areas, and NIMBYism is plausibly the ultimate motivation behind this system. The situation is not really so different to the situation in America. Why don’t Europeans talk about it?

I don’t know the answer to this, but here are a couple of ideas. One possibility is that suburbs are not so dominant in European identity, and so they tend to fly under the radar of European political discourse. This is partly because lots of socially elite Europeans still live in city centers, and partly because of the historical and cultural significance of these areas. I have been particularly struck by this in Paris. Paris has vast modern suburbs of low-density, owner-occupier, single-family houses. Some of these are very wealthy, like Le Vésinet or Vaucresson. But very little has been written about their history or urbanism (even in French), they rarely feature in French literature or film, and Parisians often seem barely aware that they exist. Suburbs are central to modern French life, but their role in modern French identity is incomparably smaller than is the case in the United States.

Another possibility is that European zoning lacks the politically inflamed origins of American zoning. Early American zoning is generally thought to have been motivated partly by racism, when suburban white Americans sought to exclude poorer non-white Americans from their neighborhoods by banning the only kinds of housing that non-white Americans could afford. This brings zoning into direct relation with the most intensely charged issue in American politics. By contrast, European zoning has generally been seen as a technical issue with little emotional valence. (In Britain, indeed, the planning system is left-coded, partly because key elements of it were introduced by the 1945-51 socialist government.) 

Those are just conjectures. But whatever the cause of European indifference to zoning reform may be, it might need to change. Europe’s housing shortages are getting worse, and it is unlikely that all European cities will be able to solve them entirely through outward expansion. If Europeans want to meet their housing needs, they will probably have to revisit their zoning systems, just like Americans. If we look at Europe’s housing problems through American eyes, we see them more clearly than we do through our own. The standard critiques made of the Americanization of European policy debates are all generally true. But it seems that housing is an exception.