How far does this notion of ‘regimes’ carry over into the planning sphere? It is certainly clear from the selection of national examples presented in this book that planning systems and their policy framing vary widely between countries. We can readily see that path-dependence is a strong feature of planning, not least because planning is inherently longer term in its focus and embedded in relatively durable legal structures about governance and land. Whilst there are many detailed ways in which national planning systems may differ, at the same time there are some broad distinctions, or dimensions of difference, which help to define different styles of planning and also help to explain or predict how different systems are likely to perform. In the context of this book, we are most interested in the nature and effectiveness of the system’s response to the overall housing supply problem—enabling the building of enough housing, without encouraging speculative excess, and enabling the provision of affordable housing in sustainable, balanced communities.
We would argue that the key differences between planning systems from this point of view fall into three main categories:
- • whether permission to develop on land allocated or zoned for housing is given as of right or as a matter of discretion, on the merits of the case in terms of multiple criteria (‘zoning versus discretion’)
- • whether land used for development is predominantly in public or private ownership at the stage of initiation
- • whether the governance of planning is predominantly localised or centralised (including strong metropolitan regional planning).
It should also be emphasised that system outcomes will be influenced as well by the basic physical geography of a country or region—the more total land area and the less physical constraints on urban development, the easier it is to increase general housing supply. Thus, one might expect that the USA, Australia or France would find it easier to build a lot of housing than countries such as England, the Netherlands or Hong Kong, which have much less land area relative to population.