Given the UKs emphasis on regeneration in London as the main mechanism of densification policy (through OAs and other mechanisms), London itself might also be considered something of a test-bed for national strategy. The London Plan has been the site of experimentation (e.g. removal and reintroduction of affordable housing targets within densification frameworks), which are then in national strategies such as the 2016 Estate Regeneration National Strategy. This line of enquiry requires further analysis, however.

It therefore remains something of an open question the extent to which there is space for the continued development of alternative approaches and tools for densification that might foster the decommoification of land and housing, at the regional, and/or local level.

## Key actors and institutions

<table><thead><tr><th>Institution type</th><th>Name</th><th>role</th></tr></thead><tbody><tr><td rowspan="5">Central Government</td><td>Office of the Deputy Prime Minister (ODPM 2001 – 2006)</td><td>Ministerial department responsible for housing, communities and local government.</td></tr><tr><td>Department for Communities and Local Government (DCLG 2006 – 2018)</td><td>Design of UK policy strategy relating to densification, e.g. Estate Regeneration National Strategy (2016).</td></tr><tr><td>Ministry of Housing, Communities and Local Government (MHCLG 2018 – 2021)</td><td rowspan="3">Produces the The National Planning Policy Framework (NPPF), and the The Planning and Compulsory Purchase Act 2004, which sets the framework allowing S106 agreements to be negotiated between local planning authorities and persons interested in land, determining contributions, arrangements and restrictions as planning agreements or planning obligations.</td></tr><tr><td>Department for Levelling Up, Housing and Communities (DLUHC 2021 – 2024)</td></tr><tr><td>Ministry of Housing, Communities and Local Government (MHCLG 2024 –)</td></tr><tr><td rowspan="3">Local and regional governments</td><td>GLA</td><td>The Mayor of London leads the GLA and is responsible for the strategic governance of Greater London. Sets out the spatial development strategy for London to be followed by local authorities in the London Plan, including strategic initiatives such as Opportunity Areas and Housing Zones. Provides affordable housing grant from the Mayor's affordable housing grant, e.g. providing £83.7million of funding to Peabody housing association for the acquisition of the former Ford Stampint Plant site in Dagenham for mixed tenure housing delivery (50% 'affordable' tenures including for owner occupation).</td></tr><tr><td>Local authorities (numerous)</td><td>Coordinate planning strategies, permissions and land release e.g.: prepare local housing needs assessments and design local development plans, bringing land forward for development; form development agreements with private developers over the transfer of public land</td></tr></tbody></table>
<table><caption>Table UK20. Key institutions involved in the policy cycle for densification</caption><tr><td></td><td></td><td>(including single-tenure social housing estates) for densification; negotiate S106 agreements with developers, including for the provision of social and affordable housing; partner with non-profit and for-profit housing providers and developers e.g. to submit applications to designate areas of majority brownfield land as Housing Zones. Would previously partner with construction companies and private developers to coordinate delivery of densification projects (1st generation densification); currently play a more enabling role, with non-profit housing providers performing this coordinating role (2nd generation densification).</td></tr><tr><td>Non-profit sector developers and housing providers</td><td>e.g. Peabody housing association</td><td>Currently the main actor coordinating densification projects. For example:<br>Peabody as formed a strategic partnership with the GLA for the delivery of regeneration and densification projects, to deliver housing (including up to 7,000 'affordable' tenure homes in e.g. Thamesmead, Daggenham Green, and the former Holloway Prison in Islington).<br>Peabody works in partnership with private construction companies (e.g. The Hill Group) to deliver masterplanning and housing at these sites.<br>As the owner of densification sites (e.g. having purchased the site at Daggenham Green in partnership with Dagenham Dock Ltd), Peabody acs as the client coordinating development and acquiring services related to sustainability, social value advice, town planning, architectural design, masterplanning, landscape design, public realm design, structural engineering, civil engineering, access and inclusivity consultancy, sales and capital markets consultancy.</td></tr><tr><td>Private sector construction companies, developers and housing providers</td><td>e.g. The Hill Group, British Land (a UK 'developer and asset manager') or Lendlease (an Australian multinational construction and real estate company)</td><td>With local authorities playing an enabling role to ensure land release for densification projects, private developers provide the capital required for design, construction, and delivery of new housing. These actors therefore ensure such schemes are 'commercially viable'. Often work in partnership with local authorities or non-profit housing providers in the interest of public benefit (e.g. provision of affordable housing), nevertheless there are trade-offs due to these companies' profit requirements, and planning structures (e.g. S106, affordable housing targets, local authority capacity) which have weakened the leverage of the public interest.</td></tr></table>
6.5 Achievements, assessments, and challenge

UK densification strategy has encouraged the gentrification of areas designated for regeneration through the residualisation of the social housing stock and extension of owner occupation and private rental tenures.

More significantly, densification has been used to recommodify the land and housing supply system, progressively weakening the role and power of public institutions in these processes, and transferring land, responsibility and revenue streams to the private sector, including to large international organisations. This opens the door for the financialisation of land for densification and the management of these projects, with huge implications for residential inequalities, not least curbing the redistributive role that local authority direct delivery can play in housing provision.

In place of central government finance, the hard regeneration projects detailed above have depended on bringing forward the value inherent in public land (including single tenure social housing estates) and transfering this to the private sector. This means that provision of affordable housing under this densification agenda relies on cross-subsidising social provision with the provision of private tenure owner occupied or rental homes (as negotiated under S106 agreements between local authorities and the developers who take ownership of densification projects). The National Housing Federation suggests that cross-subsidy models of housing delivery result in a net decline in social housing on all estate regeneration projects, alongside an increase in private tenure housing (Riding 2024b). This is supported by Penney (2024) Who illustrates the extent of social housing loss using examples from the Heygate and Aylesbury Estate Regeneration programmes in the London Borough of Southwark: „On these two estates, 3,971 homes, including 3,435 council homes, will have been demolished by 2035. In their place, a total of 6,979 homes (1.76x density) have been built or planned: 1,897 (27%) will be social homes, 1,017 (15%) will be intermediate homes, and 4,065 (58%) will be market homes. This represents a net loss of 1,538 truly affordable homes. Additionally, the replacement social rented homes are being provided with less secure Assured Tenancies and with £107.51 higher average per week social housing costs“.

Constraints

The transfer of public land to private ownership, encouraged under the regeneration agenda, constrains direct delivery of social housing by local authorities. This has an impact for any future programmes to expand the decommodified housing stock, as land price cannot be controlled or constrained, meaning it will cost far more to deliver public services (including housing provision) on private land. As an additional concern, since industrial areas have also been targeted for release to private housing developers, there is a risk that many SMEs will be relocated, undermining ‘blue-collar’ employment opportunities and substituting these for predominantly owner occupier and private rental tenure housing.

Opportunities

We have pointed to various innovative programmes of the GLA intended to support local authority housing delivery. This includes the Council-led Hosuing Network, the Housing Development Academy, and the £4 million Land for Council Homes Revenue Fund. The
removal of the HRA borrowing cap in 2018 increased local authority access to finance, and some local authorities have created ‘local housing companies’ for direct delivery. While these initiatives are unlikely to reach scale while local authorities are not sufficiently supported by central government grant, they at least offer opportunities for more direct delivery, and indicate the significance of the local level for reducing housing inequalities in the face of the densification agenda.

The previous points are summarised in the table below, with further insights drawn from Policy Lab workshop #1, held in London.

<table><thead><tr><td>Hypothesis: impacts on housing inequalities</td><td>Further insights, drawn from Policy Lab workshop #1 (WP7)</td></tr></thead><tbody><tr><td>Densification encourages the gentrification of areas designated for regeneration</td><td>Not necessarily. Yes, in relation to first-generation densification, based on public-private partnerships, but local authorities are learning from past mistakes. Public sector participants do not regard densification/regeneration as a driver of gentrification in the latest regeneration programmes. Some see the process as 'good gentrification' when the concentration of deprivation of the estate and surrounding area is very high, or when the existing estate is not demolished (as in most recent regeneration programmes).</td></tr><tr><td>Densification as implemented in the UK transfers the value inherent in public land (including social housing estates) to the private sector.</td><td>Yes, particularly in 1st generation regeneration (public-private partnerships) with the selling of public land to private developers and demolition of council estates. But in the last decade this transfer to the private sector is not so direct, with a change in the governance of regeneration to non-profit-private joint venture (2nd generation), and more GLA funds/loans for acquisition of land (to local authorities and non-profit housing providers), and changing approach to demolition of council estates.</td></tr><tr><td>Densification limits the possibility of direct delivery of housing by local authorities.</td><td>Yes, due to how the planning system and housing supply system is organised. However, there are signs of growing direct delivery from local authorities in recent years, with introduction of council-owned regeneration companies and housing companies.</td></tr><tr><td>Social housing delivery relies on cross-subsidy from private tenure production (Section 106) and results in a net decline in social homes.</td><td>Yes. Section 106 is an issue: housing provision by the private sector does not ensure reaching affordable housing targets or good quality homes, so local authorities need vehicles to build better / build themselves (like council-owned regeneration companies)</td></tr><tr><td>Opportunities: various innovative programmes of the GLA intended to</td><td>Yes. More recently there are signs of a paradigm shift (towards direct delivery), stopping the decline of social housing delivery.</td></tr></tbody></table>
<table><caption>Table UK21. Summary table</caption>
   <tr>
    <td>
     support local authority housing delivery.
    </td>
    <td>
    </td>
   </tr>
   <tr>
    <td>
     Opportunities: removal of the Housing Revenue Account (HRA) borrowing cap in 2018 increased local authority access to finance, some have created ‘local housing companies’ for direct delivery.
    </td>
    <td>
     Yes, there are signs of a shift towards new vehicles for local authority direct provision (see above), but it may be too early to see the benefit of lifting the borrowing cap, as local authorities still have difficulty in borrowing due to the high rise in interest rates (and high cost of construction).
    </td>
   </tr>
   <tr>
    <td>
     The impact of crises: rising construction costs (alongside stagnant house price rises) means housing developers engaged in densification have increasingly narrow profit margins. This falling viability can compell developers to reduce Section 106 contributions, affordable housing delivery and other ‘negotiable’ aspects (including net-zero construction targets) where possible.
    </td>
    <td>
     Higher cost of regeneration (particularly green regeneration) for private, public and non-profit sector, due to raised interest rates, rising construction costs, and Brexit. Brexit in particular made procurement for construction more challenging.
     <br/>
     Housing associations also struggle with the increased costs of production and raised interest rates. The non-profit sector is changing: housing associations are getting larger by merging, but some are having financial difficulties.
    </td>
   </tr>
   <tr>
    <td>
     Where we need to improve: coordination
    </td>
    <td>
     Holistic thinking about budgets at national level for more long-term funding.
     <br/>
     The planning system is precedent-led, and things are reviewed because of objections, ratgher than being set against criteria, measurements or data.
    </td>
   </tr>
  </table>
# 7 Summary and discussion of results

## 7.1 Summary of changes in EEP

In the UK, retrofitting, urban greening, and densification are replicating many of the residential inequalities that are already produced by the UK housing system. This is because of a broader contextual historical shift in UK governance structures, that has occured over several decades. The governance structures determining how these environmental initiatives are rolled out, are underpinned by the same logic that governs the existing housing system: a preference by UK policymakers to catalyse economic activity through the commodification of public goods.

The underlying macroeconomic conditions of this policy preference have deep roots. From the 1960s onwards, attempts have been made to reduce government intervention in the economy, to liberate the supply side (production and provision) of public goods 176 from state control, alongside tax reductions implemented with the aim of increasing personal consumption and the declining productivity of British industry. These shifts were turbo-charged during the Thatcher era, and increase as Britain shifts increasingly towards a services dominated economy.

This means that while national policy for EEPs is set by national government, these policies are designed so that responsibility for implementation falls to private, public and non-profit housing providers. In this context, public and non-profit institutions are usually left to rely on the private sector to fund implementation. Some funding, guidance and support is available from the national level, but this is usually not sufficient to extend retrofitting, NBS delivery or densification at scale. Rather, national-level funds and support are usually intended as a 'pump-priming' exercise, to stimulate activity at lower scales of governance and market operation. Ultimately, this means that the costs of implementing EEPs are usually shouldered by the private sector, and therefore 'shunted-on' from housing providers to end users, ultimately increasing housing inequalities.

## 7.2 Relations and trade-offs between EEPs and housing policies

In the UK, environmental debate and the green policy initiatives—such as retrofitting, NBS, and densification—have developed largely in isolation from the housing affordability debate. The housing affordability debate predates the decarbonisation and sustainability debate, and the links between these areas are not part of the current political agenda. Their nexus also remains underexplored in academic circles due to disciplinary silos, although some synergies are gathering momentum.

<footnote n="176">176 We define public goods as goods and services the provision of which benefits all members of society, being non-excludable and non-rival. This includes the availability of affordable housing and the creation of a sustainable and net-zero economy, both of which provide benefit at a societal level that individuals cannot be excluded from. These specific public goods cannot be reduced to (for example) individually owned homes or individually owned green space, but extend to the benefit felt by society at large in their wider provision and availability.</footnote>
Our view however, and as stated above, the governance structures determining how these three green initiatives are rolled out, are underpinned by the same logic that governs the existing housing system: a preference by UK policymakers to catalyse economic activity through the commodification of public goods. These EEPs are public goods that are manifested through the built environment, and as such their design follows the same logic as the UK housing system, and replicates many of the mechanisms whereby housing inequalities are created.

This policy preference for private provision of public goods, the historical context of which is outlined above, has seen shift from state intervention and investment in the supply side (largely but not limited to central government subsidy) to the demand side (largely but not limited to tax restructuring). This has created decades' worth of housing, fiscal and welfare policy intervention intended to lubricate the flow of private (rather than public) investment into housing, and now into green initiatives. Direct state investment into supply (which was a norm during the postwar de-commodification of the UK housing system) has been replaced by attempts to stimulate privately funded supply by boosting. This logic has been applied both to housing and to green initiatives.

We would add that this is not primarily an issue of environmental policy or governance, but of how the governance of public goods provision works in the UK. By outsourcing the provision of public goods to the private sector, the costs of both housing production and of green interventions will rise, with costs ultimately re-couped from end-users, thereby increasing residential inequalities. These three green initiatives are therefore replicating and amplifying the residential inequalities that are already produced by the UK housing system.

In retrofitting, homeowners and landlords (whether private, public, or non-profit) have struggled to retrofit their properties and are unlikely to do so by 2035-2050 due to prohibitive costs. Similarly, the provision of NBS remains scarce, often off-site, and of poor quality, while densification continues to drive up housing prices, making the delivery of affordable housing increasingly untenable.

Just as the UK housing debate (since 2004 – see Deliverable 4.2) has framed the housing affordability crisis as a supply-side (market failure) problem, the climate and environmental discourse is now expected to follow suit—framing shortfalls in the provision of retrofits, NBS, and densification of housing as a supply-side problem, rather than a problem of state funding, coordination and provision. This narrative risks justifying further demand-side subsidies and deregulation of planning and the housing system to stimulate market-led production of green goods, rather than addressing the complex implications of green interventions for housing affordability and regional or urban inequalities.

Thus, although the housing affordability and environmental debates remain largely disconnected, the systems themselves are deeply intertwined—following similar narratives, governance structures, and policy patterns, albeit with a time lag.

More importantly, the idea that decarbonisation may hinder housing affordability—and in fact make housing less affordable—is largely absent from the UK's national debate. In international academic circles, the green-housing affordability nexus has gained traction through the concept of 'green gentrification' (Anguelovski et al 2022) (environmental initiatives triggering neighbourhood changes which drive green gentrification and displacement). Green gentrification may occur in certain areas (particularly those that are already quite gentrified
such as Woodbury down – see WP2 for more details). However, our hypothesis is that green gentrification is far from being the main mechanism whereby EEPs reinforce housing inequalities in the UK context.

Green initiatives in the UK are impacting housing affordability more fundamentally through the housing provision/production system itself. As the cost of production for green initiatives such as NBS and retrofitting continues to rise, and with minimal direct state intervention and only limited demand-side subsidies, the financial burden of the UK's low-carbon policies is increasingly falling on housing providers rather than the national government. Private developers, non-profit organisations, and local authorities are being tasked with both funding and implementing decarbonisation efforts. Consequently, a portion of these costs is either passed on to tenants and prospective buyers, further exacerbating housing affordability challenges, or re-couped through negotiable aspects of development such as Section 106 contributions and affordable housing unit delivery. As housing providers are increasingly required to deliver green initiatives—whether on-site or off-site—the production and retrofitting of affordable housing is being constrained. Small and medium-sized private and non-profit providers are already struggling to operate under these conditions. At the same time, policies aimed at expanding low-carbon technologies are not improving housing affordability. In fact, green policy instruments and subsidies often raise development costs, indirectly limiting the supply of affordable housing and reinforcing the commodification of the housing system.

Due to the UK's exit from the EU, the scale of public investment in the UK green agenda is significantly smaller than for other EU countries, which benefit from substantial EU subsidies. One issue here is not only the size of these funds, but also how they are distributed. In the UK, the limited availability of grants (for example, local authorities must bid competitively for limited funds to retrofit their social housing stock, meaning many apply for but are left without grant funding) constrains the capacity to support 'green and affordable' housing initiatives effectively.

The UK's environmental agenda is missing a critical opportunity to support the production of affordable housing. Current green policies lack mechanisms to foster the de-commodification of housing, which would mitigate the affordability crisis. This would require, for instance, direct state intervention in the provision of these three green initiatives. Furthermore, green programmes and subsidies to housing providers are not accompanied by regulatory safeguards to prevent rent increases or speculative practices. Nor do they include fiscal tools and land value capture mechanisms that would allow the state to reclaim a portion of the increased land value resulting from public investment (e.g., through improved environmental quality). This gap is rooted in the UK's weakly regulated private rental sector, and in the negotiable nature of planning gain (like Section 106 agreements), which are designed to allow the private sector to retain much of the uplift in value as an incentive to deliver public goods.
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