However, LR is not free of limitations. In many cases, potential development options may not match the preferences of existing residential property owners making it hard to achieve consensus. Another limitation is that LR requires a strong legislative framework to support its implementation and this may require a lengthy political process. LR is takes time, both in terms of implementation (e.g. title swapping is time consuming) as well as in terms of investment recovering (land owners will only recover their investments after several years). Finally, the process of determining land values and land contributions is controversial; however this is not unique to LR but is a problem common to all land-based instruments. Most importantly, the weaknesses of LR can be reduced if the right institutions are in place.

The following outlines the case of Germany as the most prominent example of contemporary LR and examines comparative cases in Asia that developed from the German model. The cases of Japan, South Korea and Taiwan, China are also described. They are considered as a single case as these three Asian countries implemented the German model with little variation among them. Then, we describe the case of Australia as an example of implementation of LR in a large federal country. Finally, we include the China case, to highlight is particularity. Additional cases are summarized in Table A1 in the Annex. The objective of these cases is to illustrate the relative successes and challenges of LR within different country contexts and point at key considerations and institutional requirements as LR implementation is underway.

# GERMANY

Germany provides one of the oldest and most oft-cited examples of land readjustment (LR)— known as Umlegung—in the international literature on land management. The influence of Germany’s LR model is so pervasive that Japan adopted it in the early 1900s and Japan now serves as Asia’s leading example of urban development using LR. The success and acceptability of Germany’s model for LR is a result of a number of factors, including: 1) its long-standing history of well stablished property rights; 2) its streamlined and transparent evaluation and implementation process; and 3) the strong judicial system in place to address public claims.

Germany’s model provides considerable insight into establishing institutions and processes to carry out land redevelopment, recognizing their own legal framework. While many countries may not have the institutional structures to carry out LR, lessons from Germany on land valuation techniques and the evolution of price data management instruct others on how to construct a sound foundation on which to develop a comprehensive land management strategy. Adopting Germany’s model requires a cognizance of the country specific challenges related to the extent of democracy in public process, legal framework and institutional strength and technical know-how of local bodies.

One particular process that should be highlighted in the German LR process is the method of land valuation. Land valuation processes in Germany are relatively well managed and transparent (Kertscher 2004 and Seidel 2006). In Germany, land valuation processes are defined by the law. The law mandates the setting up of valuation committees, the definition of standardized market values, and the method for collecting purchase price data.

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