LEARNING FROM TENURE: AN INTERNA TIONAL COMPARISON

ON THE MEANING OF TENURE IN NINE EUROPEAN COUNTRES -

EAST AND WEST.

OLA SIKSIO

INTRODUCTION

Tenure is a concept widely used and abused in research on housing.

The connotation and understanding of the concept varies and so does the use of the different specifications of tenure. That is as we use them in discussions of the situation in our different national housing markets i.e. talking about owner-occupation, cooperative housing, private rental market and of course public or social housing. The confusement is great.

What does it mean to be an owner-occupier in CSSR? Is it the same as in Poland, Hungary and DDR or is it more like or more different from Owner- occupiers in western countries as UK, Sweden and Norway? Because, if there are differences then may be the discussion carried out on the basis of more formal labeling leads wrong. May be beeing a shareholder in a small building specific association in the Netherlands is more like the situation

for the tenant as a cooperative tenant-owner in Sweden and less like the situation for a household which is a shareholder in Norway! The insecurity in discussions and presentations on tenure caused by these similarities and differences ought to be straightened out.

The work within CIB W69 has offered a possibility for such a clarification. Thanks to our colleagues M. Bouillon, Iskra Dandolova, Lubomir Kotacka, Ivan Tosics, Rolv Lian, Halina Myszkovska, Come Huisman and Stuart Lowe a contribution adressing specifically the question what it means to live in a certain tenure in a specific country could be written. At least for nine countries in Eastern- and Western Europe. You have it in your hand!

The history. The history of this paper is a long one. Even in the context of international projects on comparison. It dates back to 1982 and the CIBW69 meeting in Oslo, where we, after having discussed the book of Jim Kemeny: The Myth of homeownership - decided to enter the difficult road of comparative studies. Jim K and myself took on the task to design a questionnaire that should be distributed among the members of theSworking group and help us to understand and go behind the head-lines if the different tenures that existed in the different member countries. Thus we also should be able to gain a better understanding not only of the terminology, but also gain an insight into the meaning, possibilities and constraints of beeing in a certain tenure and by that it should also give an opening for making the same analysis and comments on similarities between tenures in different coun- tries belonging to the same .<formal tenureD and even and may be most interesting differences between tenures in the same .<formal>> tenure category or similarities and resemblances between catego- ries of tenure belonging to different .<formal>> ones.

The approach. So much for the history. What we needed to highlight as a result of our study was eight dimensions of decisive importance for discussing and understanding tenure. They were:

1. Security/Permanence

2. Access

3. Freedomlright to exchange

4. Right to sell/restrictions on sale

5. Responsibility for maintenance and repair

6. Possibility of using housing as an investment i.e. making a profit

7. If a certain tenure leads to compulsory organization of some sort

8. Rent policy and/or restrictions.

There are of course other dimensions of importance for tenure and housing. That is e.g. the system for housing finance, the mode of and system for housing production and housing supply. Of course they influence the size and existence of different tenures in different countries but they are not so crucial as they use to be in housing analysis when it comes to the meaning of different tenures.

The material for presentation and analysis was collected by a questionnaire containing 15 questions covering the eight dimensions. The questionnaire appears in Appendix 1. This presentation should not be considered as a final one but rather as a description with an explorative purpose which could give information and ideas and form a basis in our discussions about the direction of our possible future efforts in exploring tenure in a comparative way.

Presentation of the material We have information from nine countries. They are: Belgium, Bulgaria, CSSR, Hungary, Norway, Poland, Sweden, the Netherlands and United Kingdom.

According to the approach choosen the task is to describe similarities and differences within and between tenures according to the eight dimensions earlier mentioned. The questions in the questionnaire have for every main- group of tenure been put back to these dimensions respectively and under these headlines there is a presentation in a simple cross-table of every relevant variable by country. This way of handling and presenting the material makes it easy to notice the dominating pattern and also find the <<out-layers.. i.e. countries which don't adapt to a dominating pattern within a specific tenure.

We have four main-groups of tenure: Owner-occupation, Cooperative, Private rental and Public rental. Owner-occupation and Public rental housing respectively have a number of subgroups in a few countries as they have defined them in the questionnaires. The differences between them are connected to differences in the level of state subventions as in Holland or in differences in access and distribution as in Hungary and Belgium.

The point in this context is the fact that the results make you conscious about that there exist differences both within and between countries if you

discuss housing policy and tenure only at the highest level i.e. as owner- occupation, public housing or private rental housing sectors. As a consequence of this the situation for the owner or tenant also is different when it comes to the meaning of living in or trying to get access to or leave a certain tenure form in a specific country. There is the base for fortcoming work in this field of interest.

RESULTS AND COMMENTS

General information As already mentioned we have information from nine countries. Altogether these nine countries have a represenation of 42 kinds of tenures. The most common is to have the usual four but e.g. Norway has presented six, Poland five and the Netherlands seven kinds of tenure. The four tenures described from Hungary contains three types of owner-occupation and the remaining goes for public rental housing. As said we have 42 reported tenures in the nine countries. The most common is owner-occupation which is reported 16 times. Second comes public rental and private rental with 10 respectively 11 times each. Third comes cooperative forms of tenure which is not represented in all countries so it only appears five times. As a kind of compensation for this Poland has two forms of cooperative housing.

In the presentations of the content for the eight different dimensions within every of the four main tenures I refer to a specific number of table. All tables will not be presented in this report, mainly becuause of an agreed size of the contributions and there are 55 tables connected to the presentation. Instead the basic detailed representation for the content of every tenure by country is shown in Appendix 2 to this report. A full set of tables is available by the author and will be conveyed to the interested reader on request.

As a service to the discussion but also to the contributors I have also made country specific presentations of tables. In these lists all questions are crosstabulated by the more detailed specification of the main-tenures as they have been reported from the different countries. They also could be conveyed on request.

In total there are 16 tenures in the nine countries which are reported as owner-occupation in the meaning that people in these forms own their dwellings. As can be seen from Table 1. there are different numbers and types of owner-occupation in a number of countries.

Hungary has got three types of owner-occupation. General owner-oc- cupation mainly single-family housing, owner-occupation built by the Savings Bank and sold to i.e. distributed to families by the local authorities and owner-occupation built by the Savings Bank and sold to owners on auction i.e distributed by the market.

The Netherlands is represented by four kinds of owner-occupation. Three of them differentiates in kind or level of state subsidies and the remaning type of owner-occupation is to be a share-owner in the building where your dwelling is situated. Subsidy of type A and B means that the price of newly build houses may not exceed US$ 77.000 and US$ 94.000 respectively. According to information received from Holland, the subvention of type B was abolished in the middle of the 1980's.

Belgium and Norway has reported two kinds of owner-occupation each. The atypical ones are in the case of Norway shareholding and in Belgium it is owner-occupation built and distributed by public local council.

This dimension was represented by the questions 11 and 12.

Question 11. -Is there an indefinite contract as long as the loan or the rent B p a i d ? ~ Table 2.

Generally the security in owner-occupation seems to be high in all countries. For Belgium there is no answer and in the case of no from Norway it concerns the shareholders. In the case of Hungary it concerns the two forms built by the Savings bank and may be there is no formal contract since you buy it from the bank. The atypical answer from Poland may be rests on the same ground that if you are an owner-occupation you don't have a formal contract on your dwelling.

Question 12. +Can the occupier be evicted on one or more of the following reasons?.. Table 3.

Generally speaking the secure situation in owner-occupation is only threatened by not paying mortgage and interest rates to the banks. This is even valid for owner-occupation in single family housing in Hungary while for the two types of owner-occupation created by the Savings bank we have

no information. In Poland owner-occupation in single family housing are only at the risk to be evicted if there occurs changes in land-use and planning.

Access to owner occupation (Questions 1,2,3,5,6,7.)

Question I . -Is access to dwellings limited to certain categories of income or need of applicant?>> Table 3.

For the majority there are no specific rules for entering owner-occupation. For the four countries which have answered that there are rules connected to income it concerns the ability to obtain mortgage finance. In the case of U.K. the maximum is three times the earnings, in Hungary it exists minimilevel of earnings for publicly distributed owner-occupation (higher than the corresponding rule for public rental). In Holland there are maximum-levels of income for the two types of subsidies. Type A allows for not more than US$23.000 a year and type B for a maximum of 38.000 per annum. In Belgium it concerns the owner-occupation distributed by the public sector and even here it is household with low incomes which have the chance of entering the sector.

In Bulgaria there are rules for entering owner-occupation based on need expressed as a match between family-size and dwelling-size.

Question 2. -Is there a waiting list for access?.. Table 4

Waiting lists for access doesn't seem to be the rule in owner-occupation, but it still exists for one third of this kind of tenure and generally the existence of waiting lists are connected to the kind of owner-occupation that have access rules. In Belgium it is the owner-occupation publicly distributed type. In CSSR there are list for families wanting an owner- occupation flat in multifamily housing but not for owner-occupation single family housing and in Hungary it is the typeof owner-occupation sold by the local authorities that have waiting lists. In the Netherlands, finally, there are waiting lists for owner-occupation within the two types of owner- occupation represented by the limited form of subvention.

In Sweden there are municipal waiting lists for new production of owner- occupation single-family housing. For the older stock there is not.

Question 3. -Is access gained by purchasing ownership ?U Table 5.

Question 4 MIS the whole dwellingpurchased.>> Table 6.

Question 6. *Can all purchase price be borrowed in the form of a longterm loan secured against the dwelling as col lateral?>> Table Z

In all countries and all types people are buying themselves into owner- occupation.

With the exception for the tenure in the Netherlands that is owner- occupation by shareholding or associations owner-occupation means that the whole dwelling is purchased in all countries. For shareholding in Holland the corresponding figure is said to be 90-95 % because in this kind of tenure common space is joint property in the company or association.

It is only in Belgium and Holland possible to borrow all purchase price. In the other countries it is possible to borrow a smaller or greater part of the sum needed for buying yourself into owner-occupation. Even here there is the exception of CSSR where you cant get any loan for this purpose. In the other countries the level varies between 30% (Poland) and 80% (U.K.) and 95% (Sweden). These latter countries top the league for the Western countries and for the Eastern representation the same goes for Bulgaria with 70% and Hungary with 60% for the two types of owner-occupation supplied by the Savings Bank. The financial and subvention situation for entering owner-occupation clearly varies between the countries beeing most modest in the East and highest but may be not best in the West.

With the exception for Hungary the countries of Eastern Europe have no income related credit ratings for loans for owner-occupation housing. The contrary is true for all Western countries which have rules for borrowing money related to minimi income levels. The exception in this case is Holland. Here they have special rules <<..complicated system with specific requirements on national and on local level*.

FreedomIRight to exchange (Question 13 a-d.) Table 8.

Question 13. <<Does the occupier have unrestricted right to exchange the dwelling ?-

Beeing an owner-occupier gives you a rather unlimited possibility to handle your property and for example swap or exchange your dwelling as you like. Again the exception here is Bulgaria where you need the permission from local authorities both for the exchange as well as with whom you may swap. In this country the probing-stone for approval of exchange is the size of family compared to dwelling size.

The same goes for the two kind of owner-occupation in Holland. In the one called Subvention type A (the cheapest one) you are not allowed to exchange your dwelling freely because of the rules for access to this kind of owner-occupation. The new owner must also meet the criteria on maximiincome. The other owner-occupation in Holland with limitations for

exchange is the shareholder-type where you may be allowed to sell your shares to an accepted person. For the two types of owner-occupation in Holland which are called Subvention B and Non-subsidy owner-occupation there is no such restrictions.

In the other countries there are no such limitation on to whom an owner- occupier may exchange his property.

Right to seU/Restriction on sale (Questions 5 and 14.) Table 9, 10.

Question 14 *Can the occupier sell the dwelling?*

Question 5 <Is the purchase price controlled in any way?.

Twelve out of the reported 16 types of owner-occupation can be sold by the owner without restrictions of any kind. The exceptions are represented in both East and West and really limitations for selling freely is most frequent in the West! We find the exceptions in these countries with more than one form of owner-occupation as Holland and Belgium. In the latter country the publicly provided owner-occupation have limitations in the owners right to sell and they are farreaching as long as they go for both price, time for resale and buyer i.e. to whom you might sell. The last limitation is also valid for shareowners in Holland and in this country restrictions for owners of dwellings subsidized according to type B have restrictions on time for resale and on buyer but not on price.

In Sweden there is a timelimit for resale to a market price for owner- occupied single family dwellings less than three years old.

In Bulgaria there are restrictions on price and buyer within the owner- occupation tenure.

But with these four examples of limitations we can conclude that it is possible to sell your owner-occupied dwelling in all the represented countries.

Responsabilities/Repair, maintenance and rentpaying (Questions 10 and 8) Table 11,12.

Question 10.-Are a N repair and maintenance costs paid for by the occupier personally (2.e. not in a rent) ?>>

Question 8. *Does the occupierpay a rent distinct from loan repayments?.

If you have the right to deal with your property as an owner-occupier it also seems to be the fact that you have full respon-sibility. In 14 of the 16 reported tenures of owner-occupation the owners have full cost

responsibility for all repairs and maintenance. The exceptions are shareowners in Norway and Holland. In the former country the occupier then have responsibility only for interior decorating while the responsibilities in this form of tenure in the Netherlands is more far- reaching and contains both interior decorating and equipment. Still these are exceptions from a comprehensive responsibility for maintenance as an owner-occupation regardless if it is in the East or West.

As an owner-occupation it is only as a shareholder in Norway that you are paying any rent distinct from loan repayments for using your owned property*

Compulsory organization (Question 15). Table 13.

Question 15. *Must occupiers be members of compulsory organization?..

Beeing an owner-occupier seems to be rather free from ideas of compulsory organizations in most of the represented countries. I think the same goes for the two forms of owner-occupation produced by the Savings Bank in Hungary even if we haven't got any specific information on this question.

It is again shareowners in Norway and Holland which have to be members in their companies or associations. In Bulgaria it varies because sometimes owner-occupiers creates a kind of association or cooperative during the construction phase of the building and as a presumptive owner-occupier you have to join this association but it has no function for maintenance etc after the building or dwelling has been finished.

Rent policy and restrictions (Question 9.) Table 14.

Question 9. What capital costs does the gross rent seek to cover?>>

Most common among owner-occupation tenure is that the cost you have for beeing in this tenure is connected to the original construction costs for a dwelling of this type. Market rents are in Nonvay paid for the type of owner-occupation that is connected to shareholding so even if you have got shares you have to pay for the use of the dwelling.

The case for Belgium is still unclear but I suspect it to be a difference according to level of state subsidies between ordinary owner-occupation and the kind of publicly provided owner-occupation which they have in this country.

In the case of Bulgaria the principle of setting costs for owner-occupied housing is referred to as a complicated system ...very difficult to explain*.

May be the colleagues from Bulgaria will be able to expand on the matter in Lausame.

COOPERATIVE HOUSING.

General information In total there are five tenures in the nine countries reported as cooperative housing. This means that this kind of tenure is not present in all countries and it is only four CSSR, Norway, Poland and Sweden which have it. Poland has two forms of cooperative housing with collective and individual ownership respectively. The difference between these Polish forms will become clearer in the presentation below. To my knowledge there exists forms of cooperative housing also in Hungary with different forms of state subvention. In some respects though some of them turn into owner- occupation after a number of years and remain only cooperative in a common resonsibility for maintenance after that basic change. Anyhow among the questionnaires from Hungary there is none dealing with cooperative housing.

Securitylpermanence (Question 11,12) Table 15,16.

Question 11. "Is there an indefinite contract as long as the loan or the rent ispaid?.. Table 15.

Cooperative tenure is a regulated one in the meaning that all reported forms contain a contract and a right to indefinite use of the dwelling in all four countries.

Question 12. -Can the occupier be evicted on one or more of the following reasons?.. Table 16

When it comes to reasons for eviction the picture is more variegated.

In CSSR and Norway the occupier can be evicted on social reasons but only that. In Poland the cooperative association in the individually owned form can cause eviction. In the collective owned form in Poland the occupier can be evicted on initiative from both the association and neighbours (social reasons). In Sweden association and neighbours are less powerful and it is only if you don't take care of your payments to the association that you can be a case for eviction. Then your cooperative property after a rather long process is sold on executive auction.

Access to Coop-housing (Questions 1,2,3,5,6,7.)

Question I . 4 s access to dwellings limited to certain categories of income or need of applicant?.. Table 17

There are no reported special rules for access to coop-housing in any of the represented countries. In this respect coops are rather like owner- occupation and this similarity rests of course on the fact that in most countries you have to pay for entering this kind of tenure.

Question 2. d s there a waiting list for access?.. Table 18

For a majority of the forms of Coop reported there are formally waiting lists for access. This is valid for CSSR and for both forms of Coops in Poland. In Sweden it varies according to the age of the cooperatives. For dwellings in new-constructed coop-housing there are waiting lists in conjunction with a personal saving-scheme. If you want to enter the coop sector by buying you into an already existing coop-building you act on the market and there are no waiting lists.

Question 3. d s access gained by purchasing o wnershb?.. . Table I 9

In Norway, Sweden and Poland (the individually owned coop-form) you buy yourself into the tenure. In the case of CSSR and for the collective owned coop-form in Poland this is not the case according to the answers to the questionnaire. This difference needs a further clarification.

Question 4. 4 s the whole dwellingpurchased.>> Table 20

In Poland individually owned coop dwellings are bought in full. Even in this respect this form seems to be rather like the owner-occupation tenure. In Norway and Sweden you are not the owner of a coop-dwelling but you pay for the right to use a specific dwelling in the cooperatively owned building or estate. In both cases you purchase 5-10% of the dwelling value. The remaining parts are covered by state subsidies and loans to the coop association.

Question 6. *Can all purchase price be borrowed in the form of a longterm loan secured against the dwelling as collateral?>> Table 21

There is no country in which it is possible to borrow all purchase price for a coop-dwelling. The percentage possible to borrow varies between 20% for the individually owned Coop dwellings in Poland, 75% in Norway and 98% in Sweden.

In Norway and Sweden there are obstacles for getting a loan for the purpose of entering the coop sector. In reality this concerns minimum level

of income and the banks and association checks your credit rating. Such rules is not reported to be present in the Polish case.

Freedodright to exchange (Question 13 a-d.) Table 22

Question 13. ..Does the occupier have unrestricted right to exchange the dwelling ?*

Beeing a cooperative tenant owner you don't have unrestricted right to exchange the dwelling in any of the presented countries. But you have the right in all forms after the permission of the coop-association. In this meaning there is rather farreaching possibilities of handling coop-dwellings as property alike owner-occupation.

In Poland (the individually owned coop) and Sweden this permission also includes restrictions on whom you can exchange the dwelling. In Sweden the new cooperative owner has formally to be approved by the local board of the association. Generally this is no problem but there has been cases where the board has considered a buyer <<persona non grataB as a member of the assocation and so refused to approve the exchange.

In CSSR, Norway and the collective coop form in Poland there is no restrictions on person in connection with exchanges. In CSSR though there is a rule saying that the right to exchange is limited according to whom by the fact that the dwelling-size in a swap must conform to the family-size of the new occupier.

In CSSR, Norway and the collective form in Poland exchanges can formally take place with no money changing hands. In the Polish case this possibility is limited by the demand that such a swap must contain dwellings of the same size. In the other form in Poland and in Sweden exchanges normally includes money.

Right to seWrestrictions on sale (Questions 5 and 14.) Table 22, 23.

Question 14 ((Can the occupier sell the dwelling?.

Question 5 4 s the purchase price controlled in any way?*

When it comes to the interesting question of the right to sell and restrictions on price for the coop-dwelling the results show some interesting differences between and within the countries. First it can be stated that beeing a coop tenant owner does not in any form or country give you unrestricted rights to sell your dwelling.

In CSSR and Norway we find the most far-reaching restrictions on the possibility of making a profit on this kind of housing. Here we find restrictions on both price, time and buyer. In Poland there is a difference between the two reported forms saying that coop-collective form you'have no right to sell the dwelling ( you havent paid for beeing there) while in the coop individually owned case you have the right but with restrictions on time for resale and buyer. Probably all these limitations has the goal to counteract speculation with coop-housing. This is also the case in Sweden where you have to wait for resale of a new-constructed coop-dwelling at least a year if you want to trade it at a market price. Within the time period of one year in Sweden you have to sell it at a fixed price close to the level of your own purchase price. For coop dwellings more than one year there are no such restrictions.

Responsabilities/repair, maintenance and rentpaying (Questions 10 and 8) Table 24,25.

Question 10..A1-e all repair and maintenance costspaid for by the occupier personally (i.e. not in a rent) ?- a

For all five forms of coop tenure the occupier has some responsibilities concerning maintenance and repair. This responsibility is obvios less compared to owner-occupation but greater than the rental forms of housing. Coming down to the hard facts this responsibility differs between CSSR, Norway and Sweden on the one hand and Poland with its two forms of Coop on the other. In the former countries the occupier is responsible for internal decoration (wall-paper, painting) while this responsibility for the latter two forms also includes equipment. Here we have a clear difference compared to owner-occupation where the responsibility for maintenance and repair contains even major repairs and structural maintenance. Of course this responsibility also means possibilities of influencing design and impression of your dwelling.

Question 8. -Does the occupierpay a rent distinct from loan repayments?.

Beeing a coop tenant owner also means that you pay a rent distinct from the repayment on your loans. In all cases this rent is used for maintenance and in the case of sweden and Norway it also includes repayment on existing loans in the associations.

Compulsory organization (Question 15). Table 26.

Question 15. ~ M w t occupiers be members of compulsor?, organization?-

Beeing a coop tenant owner in all five forms and all four countries also means that you have to be a member of some kind of cooperative association. It can be said to belong to the very nature of this tenure and the responsibilities camed out by the association concerns maintenance and decisions concerning the cooperative joint property. In this respect coop tenure is the only one reported that generally also means some form of compulsory organization.

Rent policy and restrictions (Question 9.) Table 27.

Question 9. *What capital costs does the gross rent seek to cover?,

As already mentioned all forms of coop tenure contains paying a rent for using the dwelling. In CSSR, Norway and Sweden the rent is calculated on the repayment of the original construction costs for the specific coop buildingdwelling paired with maintenance and running costs. This means that the rent varies between different objects and is highly dependant on age of building. In Poland the rents in individually owned coops rests on pooled costs for all dwellings in the coop including maintenance while it in the case of cooperative owned coops the rent covers maintenance and administration costs and thus varies widely between different cooperatives.

PRIVATE RENTAL HOUSING

General information In total there are 10 forms of tenure in the nine countries which are reported as private rental housing. All countries, except Hungary, are represented with this form of tenure and Norway and Holland have reported two kind of private rental tenure each. In the second case of Norway it concerns a small proportion, 4%, of the housing stock consisting of private rental service-dwellings. In the case of Holland the two forms of private rental relates to the presence of subsidies or not in the tenure form. The remaining forms in all countries private-rental refers to a tenure which means an agreement between an owner and a tenandoccupier.

Security/permanence (Question 1 1,12) Table 28,29

Question 11. ~ 1 s there an indefinite contract as long as the loan or the rent is paid?* Table 28

It seems to be the fact that private rental (PrR) is the most insecure form of tenure represented in the study. It is only in Holland and Sweden an occupier in this tenure regularly has an indefinite contract as long as he pays the rent. In Bulgaria, Poland, UK and Norway in the case of private- rental service dwellings, it is not the usual case of having a contract. But it depends obviously very much on the private landlord if there is a contract or not. With this clarification the result is showing the same for private- rental in CSSR, Belgium and ordinary private-rental in Norway.

Question 12. .Can the occupier be evicted on one or more of the following reasons?>> Table 29

The insecurity of private-rental is reflected in the answers given on this question. It is only in Poland a private renter can't be evicted. In Belgium, Holland and United Kingdom a private tenant have the weakest position and can be evicted on landlords request, because of social reasons or if not paying the rent. In Bulgaria and CSSR the landlord and the neighbours also have a strong position against the tenant while in Sweden not paying the rent and social reasons (disturbing behaviour etc) is considered as legal causes for eviction.

Access to private rental sector (Questions 1,2,3,5,6,7.)

Question 1. .Is access to dwellings limited to certain categories of income or need of applicant?>- Table 30

Access to private rental tenure seems not to be attached to any specific rules. It is only in the case of the private-rental service dwellings in Norway where distribution is according to need i.e. old age and/or physical handicap and in the Dutch subsidized private rental sector where access is limited to people with the lowest incomes, we find any rules for access.

Question 2. 4 s there a waiting list for access?>> Table 31

Consequently the presence of waiting lists for entering the private rental sector is very rare. It is again in the Dutch subsidized part of private rental sector that we have waiting lists generally. In Sweden it varies according to the year of construction. In new constructed private rental housing generally all dwellings are distributed by the local municipal housing agency but for the older stock of private rental housing normally is accessed a one side of any lists. C.f. the study of the private rental sector of the inner-city of Stockholm (Siksio & Borgegird 1989). In the case of private-rental non subsidized sector in Holland a comment is made saying that the rents are so high that no lists are necessary.

Question 3. -Is access gained bypurchasing ownership?.. Table 32

Question 4. -Is the whole dwellingpurchased.~ Table 33

Question 6. -Can all purchase price be homo wed in the form of a longtenn loan secured against the dwefling as col [ateral?~ Table 34

Access to private-rental tenure is normally not gained by purchase. The material shows although two rather mysterious exceptions. It is in Belgium and Poland where it is stated that access is bought and that the whole dwelling is purchased. It seems a little bit odd and needs some more clarification. It is also stated for those two countries that in Belgium you are able to borrow all the money needed if you have a certain minimiincome while in the case of Poland you are not entitled to borrow anything with the private-rental dwelling as collateral.

Freedom/right to exchange (Question 13 a-d.) Table 35

Question 13. does the occupier have unrestricted right to ex change the dwelling ?>>

Considering the weak and insecure position as a private renter it may be astonishing that practically all forms reported includes the right to exchange the dwelling with the landlords permission. The exception are service dwellings in Norway where the tenant normally has no right to exchange. In all contries except CSSR and Poland the new tenant as a result of the exchange must be approved by the landlord and there are no other restrictions for exchange ordinary private rental in Bulgaria, Norway, Poland, Sweden and Holland (the non-subsidised part). In four countries there are a set of further restrictions for exchange of private rental dwellings. In Norway service-dwellings are generally not allowed for exchange but if it occures the new tenant must conform to the same rules for need of this type of dwelling as the former tenant did originally. In CSSR the exchange with a private-rental dwelling must contain a match be tween the dwelling-size and the family-size of the new tenant. In Holland the new tenant after an exchange with a subsidised dwelling must have permit to enter this sector (low income) and in the U.K. the landlord has the possibility of preventing exchanges if he wants to.

Right to sell/restriction on sale (Questions 5 and 14.) Table 36,37

Question 14 .Can the occupier sell the dwelling?>>

Question 5 -1s the purchase price controlled in any way?>>

Private rental dwellings can formally and legally not be sold by the tenants. This is the same in East and West and conforms rather well to the idea of private property in this case the landlord.

Responsabilities/Repair, maintenance and rentpaying (Questions 10 and 8) Table 38,39.

Question 10.-Are all repair and maintenance costspaid for by the occupier personally (i.e. not in a rent)?,

Beeing a tenant in the private rental sector means in Bulgaria, Norway, Sweden and U.K. that you are free from responsibilities concerning maintenance and repair. This is paid for in the rent and taken care of by the landlord. At least formally.

For the five remaning countries a private tenant has a limited responsibility for maintaining the dwelling. In CSSR, Norway and Holland this means to take care of interior decoration while in Belgium and Poland this responsibility is extended to include even equipment in the dwelling. The picture of maintenance responsibility is thus very variegated and ther is no systematic difference between East and West.

Question 8. <<Does the occupierpay a rent distinct from loan repayments?>>

In all forms of private rental tenure in all eight countries the tenant pay a rent for the use of the dwelling. As shall be seen below the system for setting the rent varies widely.

Compulsory organization (Question 1 5). Table 40.

Question 15. -Must occupiers be members of compulsory organization?.

If you live in a private rental dwelling you are as we have seen in a rather weak position in relation to landlord and neighbours. On the other hand you are completely free from any form of compulsory organization in the capacity of beeing a private tenant. Even if the situation described seems to point in the direction that the weak position should really need some kind of joint activities. In Bulgaria it doesn't even exist any association for private tenants. In many of the other countries you have them but on a volountarily basis.

Rent policy and restriction (Question 9.) Table 41.

Question 9. << What capital costs does the gross rent seek to cover?,

The principles for the price you pay i.e. the rent in the capacity of a private tenant seems to a very high degree to be dependent on national conditions. In the nonsubsidised private rental sector in Holland and the private-rental sector in the U.K. rents are unrestricted market rents. In the Dutch subsidised private rental sector rents are based on the original construction costs which are covered by rents and subsidies. For CSSR, Norway, Poland and Sweden other principles, more or less complicated - most often complicated, are used for determining the rent. E.g. in Sweden the rents in the private rental sector is a function of and equal to the negotiated rents in the non-profit public rental sector for dwellings of the same age. The answers demonstrates clearly that here we have a dimension which needs much more detailed information and work to be clarified and really useful.

PUBLIC RENTAL HOUSING.

General information In total we have 11 forms of tenure in the nine countries which are considered to be public-rental (PuR) in the meaning that these kinds of dwellings are produced and provided by the public authorities and financed by governmental or state subsidies. Most often this tenure is also directed to certain economically weak categories or groups with certain needs among the citizen. But as we shall see there is no rule without exception. In this case it is Sweden. In Bulgaria there are two forms of public-rental a more ordinary one and a form of public-renting connected to the enterprise or job body council. The latter could be rented or bought by the occupier. The U.K. also has two forms of public rental housing - council housing and housing associations. We shall also see some differences between these two forms in the light of our eight dimensions investigated. In Norway publicrental is represented by service dwellings with this form of tenure.

SECURITY/PERMANENCE. (Question 1 1,12) Table 42,4 3.

Question 11. <<Is there an indefinite contract as long as the loan or the rent is paid?>> Table 42

Beeing a tenant in the public-rental sector is a secure fonn of housing. In 10 of the 11 reported forms there is an indefinite contract as longa as you pay the rent. The exception is the enterprise housing in Bulgaria where security is closely connected to the work situation.

Question 12. *Can the occupier be evicted on one or more of the following reasons?., Table 43

When it comes to the risk or possibility for beeing evicted we find great similarities with the situation in the private rental sector. Most safe is it to be a public tenant in Norway and Hungary where you in practice can't be evicted from your dwelling. In CSSR the neighburs or other social reason can be the cause for eviction. More insecure is Bulgaria and Poland where the local publiclenterprise authorities together with the opinion of the neighburs can be a threat against the public tenant. Least sense of security you seem to have in Holland and in council housing in the U.K where the housing authorities, together with social reasons and not paying the rent all three can be a threat to your status. In housing associations the correspondent to the landlord has a weaker positions compared to council housing. In Sweden the same rules are valid for both public rental and private rental sectors and social reasons and not paying the rent could be

. causes for eviction.

Access to public rental housing (Questions 1,2,3,5,6,7.) +

Question I . *Is access to dwellings limited to certain categories of income or need of applicant?>> Table 44

As already mentioned public rental housing aims at satisfying the need for housing for the weakest groups in society. So there are rules for access. In Hungary, Poland, Holland and the U.K. council housing, these rules refer to maximum income level. In Bulgaria it is need expressed as the size of the family that makes the formal rule. In Belgium, CSSR, Norway and U.K. the rules for access to public rental housing rests on a combination of need and maximum income. The exception is Sweden where public housing has been determined to be a tenure for all the population and by that there are no economic or social rules for access to public rental dwellings owned by the non-profit public housing companies (alln~ { nnyttiga kommunala bostadsf lretag/SABO)

Question 2. d s there a waiting list for access?- Table 45

In all forms of public rental there are waiting lists for entering the tenure. In Holland it varies according to the situation on the local housing market.

Question 3. -Is access gained by purchasing ownership?>> Table 46

Question 4. -Is the whole d~vellingpurchased.>> Table 47

Question 6. *Can all purchase price be borrolved in the fonn of a longterm loan secured against the dwelling as col lateral?.. Table 48

Normally you don't buy yourself into public rental sector. But even here we find exceptions. It is in Belgium and Bulgaria where you can both buy and borrow the money for entering a career as a public tenant. In both cases you buy the whole dwelling but in enterprise public-rental in Bulgaria this is not the case. In Belgium you can borrow all the money you need after the usual credit rating used for housing loans in this country. In Bulgaria you may borrow 70 % and there are no rules according to income.

Freedomlright to exchange (Question 13 a-d.) Table 49

Question 13. <<Does the occupier have unrestricted right to exchange the dwelling?..

With the exception of public-rental service dwellings in Norway Public rental tenants have the right to exchange the dwelling with the public landlords permission. In all nine countries with the exception for CSSR and Poland there are connected restrictions saying the new tenant must be approved by the landlord. With the exception of Bulgaria an exchange in this public-rental tenure can take place without money changing hands.

There are however a few other restrictions on exchange of public rental dwellings. In CSSR the size of the exchanged dwelling must conform to the family size of the new tenant. The same goes for public-rental in Holland. In the U.K. these complementary restrictions depends on if there are re-lets available in the tenure and the size of the waiting list, especially for housing associations.

For the remaining four countries there are no such extra restrictions and in the case of Sweden and Hungary it is also possible to swap with other tenures on the housing market.

Right to sell/restrictions on sale (Questions 5 and 14.) Table 50,51

Question 14 <-Can the occupier sell the dwelling?>>

Question 5 *Is the purchase price controlled in any way?.

Generally speaking and according to the answers public rental dwellings are not possible to sell. On the other hand the answers from Belgium and Bulgaria points in direction that it should be possible to do it in these countries. A clue in this direction are the answers given from this countries on question 5 where it is stated that in Belgium there are restrictions on price, time for re-sale and to whom you may sell. In the case of Bulgaria the restrictions concerns price and person.

RESPONSIBILITIES/REPAIR, MAINTENANCE AND RENT- PAYING. (Questions 10 and 8) Table 52,53.

Question 10. are all repair and maintenance costs paid for by the occupier personally (i.e. not in a rent)?.

It is only in Norway, Sweden and the U.K. where you generally have no responsibility for maintenance and repair if you live in the public rental sector. In CSSR, Hungary and the Netherlands you are responsable for the interior of the dwelling. In Belgium, Bulgaria and Poland there is an extended responsibility including even the equipment of the dwelling together with the interior decoration.

Question 8. <Does the occupierpay a rent dktinct from loan repayments?>>

With the exception of Bulgaria all forms of public rental tenure means that you pay a rent to the landlord. In this respect public-rental in Bulgaria reminds more of owner-occupation.

Compulsory organization (Question 15). Table 54.

Question 15. ~ M w t occupiers be members of compulsory organiza tion?>>

In public rental sector in Holland and in housing associations in Britain you have to be a member if you live there. As already said in Bulgaria there is no kind of Tenants associations.

Rent policy and restrictions (Question 9.) Table 55.

Question 9. N What capital costs does the gross rent seek to cover?>>

If the situation according to which principle governs the rentsetting were confusing for the private rental sector this confusion is still greater for the public rental sector. In Holland the rent together with state subsidies should cover the original construction costs. In Sweden and in British council housing there is a principle of pooled costs for this kind of tenure while in the remaining forms of public-rental in all countries there are special rules for determining the rents. Which ones should be clarified and discussed in our meeting.

SHORT CONCLUSION AND IDEAS ON FUTURE WORK

It seems rather obvious from this presentation that the original assumption for our work - that discussions, analyses and comparisons of tenure in different countries could lead astray if it is based only on formal 1abeli.ng of main tenures - seems to be valid.

It has not the same meaning to the household to be a cooperative tenant in different countries e.g. Poland and Sweden. The routes to owner- occupation are clearly different between Eastern and Western European countries when it comes to distribution and access, but when you are in this kind of tenure you seem to be as safe and secure in both and free to handle your dwelling as private property. But not everywhere in the market sense.

Beeing a tenant in public housing also turns out to have a different meaning when it comes down to every-day life in different countries. Especially important it seems to be aware of differences according to distribution, access and exchange within those countries which have more than one form of public rental housing i.e Bulgaria and U.K. In the former <<Public rental tenure>> seems to have many traits in common with what in other countries are labeled as eOwner-occupation>>. Generally public rental seems to be a very secure form of tenure, may be under less favourable physical conditions but the routes for obtaining such a home are edged by a number of different accessrules - generally according to need - and to different degrees it is surrounded by limitations when it comes to right handle it e.g. to exchange it for another dwelling.

These comments are just made to make the reader aware of how the result of this study could be used. First it is a kind of *sensitizing>> information both for discussion and e.g. the study of different kinds of national and international statistics on housing and tenure. Second here is a starting point for focusing further comparative work within one or more of the eight dimensions on which this presentation is based. Comparative studies of the (formal and informal) system of allocation of and access to different tenures under country specific conditions seems to be of immediate interest. Similarities and differences in (formal and informal) financing of owner-occupied and cooperative dwellings and determination of the cost for dwellings in different tenures also seems to be in need of further elaboration and clarification. Third the result of this investigation could be supplemented with statistical evidence like: What is the relative share of the different tenures in the different countries? What is the social composition of the families staying

in the different tenures? What has the development been in these questions over a 25-year period?

Or a more political angle: How are the different parts of the housing market with respect to tenure related to each other in different countries? What kind of tenure($ is at present promoted by housing policy in different countries? By what means? By what arguments and values? Such an information will open up for a kind of prospective evaluation of social development by housing policy through a comparative discussion of what kind of housing-consumers will gain and what kind will loose according to what it means to be in a certain tenure in a specific country when it comes down to such important hard realities as safety and security, access to, right to handle and exchange and distribution of dwellings.

So even if the present work has revealed important and interesting similarities and differences between different tenures it is only a starting point for a better understanding of the meaning of tenure. The table is laid! It is only for us to continue our scientific meal!

REFERENCES

SIKSIO, 0 AND BORGEG~RD, L-E: Private renting in the Ciy: Obtaining a flat in inner Stockholm. Swedish Council for Building Research R 36:1989.