Socially oriented cooperative housing as alternative to housing speculation

Delft University of Technology Socially oriented cooperative housing as alternative to housing speculation Public policies and societal dynamics in Denmark, the Netherlands and Spain Ahedo, Manuel; Hoekstra, J.S.C.M.; Extezarreta, Aitziber DOI 10.1080/00346764.2021.1917646 Publication date 2021 Document Version Final published version Published in Review of Social Economy Citation (APA) Ahedo, M., Hoekstra, J. S. C. M., & Extezarreta, A. (2021). Socially oriented cooperative housing as alternative to housing speculation: Public policies and societal dynamics in Denmark, the Netherlands and Spain.Review of Social Economy. https://doi.org/10.1080/00346764.2021.1917646 Important note To cite this publication, please use the final published version (if applicable). Please check the document version above. Copyright Other than for strictly personal use, it is not permitted to download, forward or distribute the text or part of it, without the consent of the author(s) and/or copyright holder(s), unless the work is under an open content license such as Creative Commons. Takedown policy Please contact us and provide details if you believe this document breaches copyrights. We will remove access to the work immediately and investigate your claim. This work is downloaded from Delft University of Technology. For technical reasons the number of authors shown on this cover page is limited to a maximum of 10. Green Open Access added to TU Delft Institutional Repository 'You share, we take care!' - Taverne project https://www.openaccess.nl/en/you-share-we-take-care Otherwise as indicated in the copyright section: the publisher is the copyright holder of this work and the author uses the Dutch legislation to make this work public.

Full Terms & Conditions of access and use can be found at https://www.tandfonline.com/action/journalInformation?journalCode=rrse20 Review of Social Economy ISSN: (Print) (Online) Journal homepage: https://www.tandfonline.com/loi/rrse20 Socially oriented cooperative housing as alternative to housing speculation. Public policies and societal dynamics in Denmark, the Netherlands and Spain Manuel Ahedo, Joris Hoekstra & Aitziber Etxezarreta To cite this article: Manuel Ahedo, Joris Hoekstra & Aitziber Etxezarreta (2021): Socially oriented cooperative housing as alternative to housing speculation. Public policies and societal dynamics in Denmark, the Netherlands and Spain, Review of Social Economy, DOI: 10.1080/00346764.2021.1917646 To link to this article: https://doi.org/10.1080/00346764.2021.1917646 Published online: 02 May 2021. Submit your article to this journal Article views: 36 View related articles View Crossmark data REVIEW OF SOCIAL ECONOMY https://doi.org/10.1080/00346764.2021.1917646 Socially oriented cooperative housing as alternative to housing speculation. Public policies and societal dynamics in Denmark, the Netherlands and Spain Manuel Ahedo a , Joris Hoekstra b and Aitziber Etxezarreta c a University of Copenhagen, Denmark; b Faculty of Architecture and the Built Environment, Delft University of Technology, Delft, Netherlands; c Faculty of Economy and Business, University of the Basque Country, Donostia, Spain ABSTRACT National housing systems increasingly combine three main types of housing: the private property sector (home ownership and private rental), social and public rental (public and non-profit sectors) and cooperative (social or civil economy). The dominant private type has facilitated housing speculation, which in many countries has become a critical source of economic inequality and instability.

The cooperative housing type can be a viable alternative with a socio-spatial cohe- sion effect. This article compares the phenomena of socially oriented cooperative housing in three European countries (Denmark, The Netherlands and Spain). The analytical focus is on the public policies and regulations, and the societal and collective action factors that foster the development of housing cooperatives. The three cases present different institutional settings and ways to develop a socially oriented cooperative housing sector. The research findings contribute to mutual learning processes in searching alternatives to the commercial and very expensive private urban housing provision. ARTICLE HISTORY Received 15 November 2019; Accepted 4 April 2021 KEYWORDS Comparative housing systems; cooperatives; housing policies; collective action; regulations 1. Introduction In latest neoliberal and financial global capitalism, housing markets have been prone to speculation and bubbles. This was one of the causes of the 2008 Global Financial Crisis (GFC) in many North-Atlantic countries. A considerable number of banks developed high levels of risks when investing in housing mortgages, which the regulatory and supervision institutions could not con- trol. In recent years we have witnessed a renewed tendency to housing spec- ulation in many European cities, led by international vulture funds (Fields & CONTACT Manuel Ahedo manu.ahedo@gmail.com © 2021 The Association for Social Economics 2 M. AHEDO ET AL. Hodkinson, 2018). Housing politics and policies have become central issues in current capitalist economies. To limit and control the possibilities of urban housing speculation and bub- bles two conditions are considered necessary: just policies and regulation of housing markets and systems, and alternatives to private property housing.

Just housing policies and regulations should focus on limiting inequality and speculation in the private housing market and its corresponding rental sys- tem. The most prominent alternatives to private property housing are social rental housing and socially oriented cooperative housing. Social rental and public housing fall within the public economy domain. Cooperative housing falls within the domain of the social and civil economy; economic collective goods produced and distributed by organized citizens in associative organiza- tions. In this contribution, the focus is on socially oriented cooperative housing; cooperative housing that is accessible and affordable for a broad spectrum of the population. Such a type of housing can counterbalance the negative effects of market-driven private property housing, especially in the urban areas. There- fore, it can be a solution to market failure and lay the foundation for a novel and effective housing policy. Cooperative housing has a long tradition in the Scandinavian countries, but interest and policy attention has risen in other countries as well, mainly in West- ern and Southern Europe. How can this housing model be further developed in countries with limited experience with cooperative housing? To answer that question, developed cases can be compared with emerging cases, with an analytical focus on two central factors: regulations and public policies, and soci- etal dynamics for collective action and mobilization. In that way, knowledge is produced about how cooperative housing can be properly regulated and promoted, and how societal-civil actors interact effectively with public institu- tions. A comparison of Denmark, The Netherlands and Spain provides insights into how different nation-state institutional traditions construct alternatives to private property housing. The article is structured as follows.

Section 2 establishes the theoretical and methodological foundations. Section 3 offers an evolutionary description of the three cases. Section 4 provides the substantial analysis, focusing on the latest regulations and social-collective dynamics behind the development of housing cooperatives in each country. Section 5 presents the main conclusions, and it identifies the differences and commonalities, thereby providing building blocks for mutual learning processes. 2. Theory and methodology Against the recurrent crises of private-market dynamics, actual and potential alternatives are necessary, especially from the state-political side and the civil society and local communities. In our view, governments need to improve REVIEW OF SOCIAL ECONOMY 3 the regulation of markets, following the principles of legitimacy, effectiveness and general-collective welfare. Housing policies are normatively expected to lead to more just socio-spatial dynamics and to a better balance and more equity between centres and peripheries. Civil society, communities and the third sector can promote civic initiatives in the space between states and mar- kets, producing collective solidary goods (Amin, 2013). Within an adequate democratic regulatory framework, and a broad moral-based civil economy (Bruyn, 1999), people gathered in open associations can cooperatively agree on mutually favourable and solidary goods. In the European context, Tummers (2017) talks about co-housing, and Lang et al. (2018) about collaborative housing to include the new wave of collectively self-organized forms of housing provision, both prior and after the 2008–2009 crisis. In Europe, according to a report by Cooperative Europe with figures from 2010–2014, 1 there are about 37,000 cooperative housing associations with more than 11 million members.

2 We think that shared, collaborative or coop- erative housing represent models of housing with many positive aspects, such as solidarity and social equality (Lang & Novy, 2014). In our analysis, we use the term cooperative housing, which includes co-ownership, co-decision and civil associationism. The social orientation of the cooperative housing is very important. It has two dimensions or solidarities, as most social formations (Barnes, 1995). The internal solidarity is based on associatively organized cooperation between cit- izens, and it usually comes from shared understandings and identities that ulti- mately derive from organized and ritualistic interactions. In urban cooperative housing, internal collective solidarity is especially vulnerable to individualist exit. The external solidarity with outsider and other groups is intermediated by public regulations and embedded within national sociocultural structures. In practice, tensions may exist between internal and external solidarity. In the Nordic cooperative housing, there has been a long discussion about whether the internal solidarity of cooperative housing (solidarity between insiders) ade- quately translates itself into external solidarity (solidarity with outsiders) as well (Sørvoll & Bengtsson, 2018). While new dynamics and data point in various directions in these countries, in other countries the debate is only theoretical or even non-existing due their short experience in cooperative housing. In our definition, socially oriented cooperative housing should be open, accessible, and affordable for both lower and middle-income groups, thereby, combining the two solidarities. 1 “The power of cooperation, Cooperatives in Europe, Key figures 2015” by Cooperatives Europe (https://coopseurope.coop/resources/projects/power-cooperation-cooperatives-europe-key-figures- 2015).

2 The European Federation of Public, Cooperative & Social Housing represents 37,570 cooperative enter- prises and 11,189,933 members. 4 M. AHEDO ET AL. Our international comparison of socially oriented cooperative housing is based on two dimensions: public policies and regulations, and societal-civil dynamics and mobilization. Other relevant factors such as the financial system in relation to housing and mortgages, the sociodemographic tendencies and the urban and spatial planning, are included in the analysis when necessary. Public policies and regulations are conceived as results of two broad factors: socioeconomic interests (both established and emerging collective interests, in various forms of political representation and influence, collective action, and mobilization) and ideational factors (from economic ideologies to socio- scientific ideas and arguments). In Europe, in the second part of the twentieth century, these factors led to cross-country differences in housing policies and regulations (Allen, 2006). Nevertheless, in the last three decades there have been two parallel tendencies. First, housing markets have been liberalized, giving more space to private parties and less protection to vulnerable house- holds. Consequently, housing has become a source of both economic growth and inequality. Second, national institutional traditions have evolved towards higher internal heterogeneity within nation-states, depending on their size, level of decentralization, and structural differences (see also Hoekstra, 2020). With respect to housing systems, national models have moved towards new combinations of housing types (private, social, public, collaborative, coopera- tives, etc.). In all cases, government action is needed to counteract the negative effects of market failures, and to promote a combination of housing types oriented to social equity.

Policies and regulations to promote cooperative housing are technically complex and with uncertain effectiveness. Therefore, a comparative approach may have a considerable added value and lead to mutual learning processes between countries. Second, the collective organization of social groups shapes housing pol- icy and regulations and can promote socially oriented housing (Mullins & Moore, 2018). Which are the collective action dynamics behind the develop- ment of socially oriented cooperative housing? Policy-related collective action and mobilization respond internally to the logic of collective interest, whereas externally they are embedded in systems of public policy and regulations that may either enable or constrain the collective organization of interests. In many European countries various types of societal and state-based (neo)corporatism were developed in the second half of the twentieth century. With respect to housing, in general, the collective action of owners and tenants have tended to have a higher policy relevance, whereas housing cooperatives’ collective voice has been marginal and difficult to be organized. The three selected countries have different welfare state regimes and hous- ing models. In this contribution, our aim is not to comprehensively compare representative models in Europe. Our focus is on evolutionary patterns and new and emerging dynamics in the field of cooperative housing. Public and policy institutions tend to be resilient to change, but they also evolve and REVIEW OF SOCIAL ECONOMY 5 transform as an effect of both domestic or international problems, crises and debates, and as a result of external pressures and learning. We think that, within the European comparativist tradition, the comparison of the three selected countries offers possibilities for mutual societal and policy learning.

Methodologically, both the case descriptions and the comparison are based on review of empirical literature, secondary and official data sources, and an analysis of policy discourses and documents. Between the cases, there are differences in the type of housing cooperatives and policy regulations. There- fore, each case has been allowed the necessary methodological and analyti- cal autonomy, within the common comparative frame in order to know the different ways by which socially oriented cooperative housing emerges and develops. 3. The three cases: national systems and institutional evolution 3.1. Denmark In Denmark, cooperative housing is called andelsbolig. One acquires an andel (a share in a cooperative, tied to a dwelling) that gives the exclusive right to use the respective dwelling. The full ownership of a housing complex belongs to a cooperative called andelsboligforening (housing cooperative association). About 75% of the cooperative housing stock concerns apartments. Currently, cooperative housing involves about 7–8% of the housing stock in the country. Private ownership has a share of about 70–71%, out of which 19–20% is rented out within municipal regulations and standard price ceilings (private rental sec- tor). Social rental housing involves 21–22% of the national housing stock. Most social rental dwellings are owned by non-profit housing fund-associations that are the ultimate decision-makers while tenants may have little influence. According to the official data, 3 the number of housing cooperative associa- tions has increased from about 100,000 in 1990 to about 200,000 in 2010 and close to 210,000 in 2018. In terms of housing stock, the cooperative sector grew from 4% in 1990 to 6.5% in 2000 and about 7–8% since 2010.

The majority of cooperative housing is located in the capital area, such as the municipalities of Copenhagen and Frederiksberg that represent two thirds of the country’s total of cooperative housing. In Denmark’s capital area, cooperative housing represents a third of the local housing stock. Previous analyses of Danish coop- erative housing have focused on the cultural-historical context (Leach, 2016), and their role in housing policies (Nielsen, 2010). Housing-related collective interests became organized throughout the twentieth century. Private owners were first organized in 1907 by the national federation of landowners. In 1977 the national association of single-family standing houses was created, and in 1996 the association of hosuing renter 3 Mainly official statistics (Danmarks Statistik), Erhverbestyrelse (2006) and Kristensen (2011). 6 M. AHEDO ET AL. landlords. In 1998, a new federation (Ejendom Danmark) aimed at integrating various private housing groups. The national federation of social tenant asso- ciations (Danmarks Almeneboliger) was created in 1919, having in 2019 about 530 members representing 560,000 dwellings. Private tenants began to orga- nize in the late 1920s, within the federation LLO (Lejernes Landorganisation), organized in local sections. Cooperative housing interests became organized later in the 1970s. In the country’s societal democratic corporatism, a certain level of policy participation of collective interests is usually expected. Financially, Denmark has developed a sustainable mortgage model that responded relatively effectively to the GFC (Chong, 2010), based on the bal- ance principle (the terms of payments to holders of mortgage bonds match the terms of the mortgages that the bonds fund). This rule was developed by the real credit societies during the last two centuries, and later it turned into law.

In the 1970s, new legislation fostered integration of credit societies into the association Council of Mortgage Finance (Realkreditråd). Since the mid-2010s there are only six large real credit societies; three are linked to large commercial banks, while the others keep their associational membership. Commercial banks can also lend mortgages. There is participation of the labour unions in various Danish banks. The mortgage-finance system has been rather supportive of the cooperative housing sector. There are three main types of housing cooperatives: (a) the traditional ones (70%) from before 1981, where tenants bought the apartments and established themselves as association; (b) the publicly supported ones (21%), established with public aid between 1981 and 2004; and (c) the non-supported ones (9%), usually new constructions after 2004. Their evolution consists of three stages. First stage (1960–1980): first steps and regulations. Since the early 1960s, social democrat led governments and the union movement became the key drivers of society. In Copenhagen, associations of co-owners of apartments emerged, when a majority of the tenants bought their rented apartments coor- dinated by an association. In 1974, 69 housing cooperative associations created a federation (ABF) to oppose a coming housing law that could have nega- tive effects for them. The law-proposal was withdrawn, and ABF continued to lobby for better policies, and to help members to organize, manage and improve their associations. 4 In 1976 a new law gave tenants a priority right to buy their apartment against a regulated price, which facilitated the expansion of cooperative housing. Second stage (1980–2000): public aid and growth. In 1981 public aid schemes were established to help new housing cooperatives. These consisted of indexed loans with long-term non-convertible fixed interest rates.

Between 1982 and 1998, the indexed credit rate provided by the Danish association of housing credit institutions was fixed non-changeable at 4.85%, with some 4 https://www.abf-rep.dk/om-abf/formaal-og-vision/about-abf/ REVIEW OF SOCIAL ECONOMY 7 modification according to inflation. This aid became a problem when the credit rate since the late 1990s decreased to 2%. Up to the 2008 crisis the interest rate was low and inflation high, which caused financial problems for this group of housing cooperatives. Thus, well-intended public aid turned overtime into a problem. Third stage (2000–2018): liberalization and urban housing crisis. In 2001, the new liberal-conservative government eliminated the Ministry of Housing, and the housing market was increasingly deregulated which led to a growing pri- vate and speculative logic. The public aid to housing cooperatives was reduced in 2000 and eliminated in 2004. In 2000 a law change allowed the possibility of a public municipal guarantee for new cooperative buildings. Housing needs in the urban areas evolved towards smaller spaces for singles, couples, small families, etc. and housing cooperatives became attractive for this target group. The GCF crisis affected the cooperative sector. The housing cooperatives cre- ated between 2004 and 2008 took out expensive and risky loan contracts (such as swap loans), and some have had problems to pay back. In 2013, the asso- ciation of housing cooperatives in crisis was created (http://ab-i-krise.dk). In 2016 the largest housing cooperative, created in 2007 in Frederiksberg, went bankrupt and the credit institution sold it to a private Swedish housing fund (Heimstaden).

In 2013 the centre-left government imposed stricter conditions on the functioning and creation of housing cooperatives, and in 2017 the lib- eral government tightened the rules in order to better control their financial situation. 3.2. Netherlands The Netherlands is characterized by a housing and housing policy system in which higher income groups tend to be housed in the home ownership sector, and lower income groups in the social rental sector (Hoekstra & Boel- houwer, 2014). The social rental sector has a share of more than 30% and is dominated by so-called housing associations: private organizations with a non- profit objective. The home ownership sector and the private rental sector have shares of 58% and 12% respectively. Despite a growing interest in this type of tenure, the share of the cooperative sector is negligible. The interests of the various stakeholders in the Dutch housing systems are organized in a patchwork of umbrella organizations. There are umbrella orga- nizations for homeowners (Vereniging Eigen Huis), housing associations (Aedes), institutional private rental landlords (IVBN), individual private rental landlords (Vastgoedbelang) and tenants (Woonbond). Since 2020, the association COOP- link was established to serve the interests of (would be) housing cooperatives and to support them with further developing their initiatives. Notwithstanding its small current share, cooperative housing has some tra- dition and historical references in the Netherlands. In the second half of the 8 M. AHEDO ET AL. nineteenth century, housing appeared on the societal agenda in this coun- try. As a result of urbanization and industrialization, housing shortages and unhygienic circumstances prevailed in the cities. Labourers were predom- inantly housed in overcrowded, small and unhealthy private rental sector dwellings.

This led to risks of social uprisings and contagious diseases. In response to this, entrepreneurs and so-called philanthropic capitalists took the initiative to construct affordable rental dwellings with the aim of housing the labour force in more healthy and human conditions (Hoekstra, 2017). In several instances, labourers also took initiatives themselves, sometimes with help from the elite, and started so-called building cooperatives. In 1876, the government facilitated this by recognizing the cooperative association as a separate legal unit (Beekers, 2012). Building co-operatives collected and saved capital among their members for the construction of dwellings. Although different variants were possible, many cooperatives had the ultimate aim of making their participants home- owners. In 1899, there were 112 housing cooperatives that owned a total of 7750 dwellings. This number implies that the quantitative importance of the housing cooperatives remained limited compared to countries such as Ger- many and France (Beekers, 2012). After 1900, the importance of cooperative housing would further decline. The housing act of 1901 left little room for the co-operative housing model. The fact that members of housing co-operatives could possibly receive profits and would eventually become home-owners was at odds with the intentions and (subsidy) requirements of this act (Beekers, 2012). Today, only two housing cooperatives that date back to the nineteenth century still exist (van der Meer, 2015). Particularly in the second half of the twentieth century, home ownership (for the middle and higher income groups) and social renting (increasingly focusing on the lower income groups) developed into the two key pillars of the Dutch housing system.

The government strongly contributed to this devel- opment by providing fiscal incentives for home ownership (mortgage interest deduction) and subsidies for social renting. In the 1990s and onwards, the Dutch social rental sector became subject of a process of privatization, dereg- ulation and decentralization. The financial position of the housing associations quickly grew stronger as a result of low interest rates and rising house prices. In response to their growing wealth, the housing associations broadened their activities and increasingly invested in social projects, public-purpose build- ings and commercial real estate (Hoekstra, 2017). Initially, these initiatives were applauded by the policy makers and the general public, but in the course of time, various cases of fraud and mismanagement came to the surface. Due to these developments, but also as a result of a long running policy discussion, the Dutch housing act was eventually renewed in 2015. The renewed hous- ing act limits the freedom for housing associations and strengthens the central government’s supervision (Hoekstra, 2017). Interestingly, the new housing REVIEW OF SOCIAL ECONOMY 9 act also leaves room for co-operative housing. After many years of lobbying – particularly by the social-democratic (former) member of parliament Adri Duyvestein who wanted to break the institutional power and monopoly of the housing associations, cooperative housing was re-introduced as a relevant concept in Dutch housing law and policy. 3.3. Spain Spain, despite its high structural inequality, is culturally self-defined as a nation of owners and rentiers, with a culture that prioritizes individual ownership.

According to the population and housing census (Instituto Nacional de Estadís- tica), home ownership had a share of 78.9% in 2011 (with some decrease since 2001), private rental housing had a share of 13.5%, and the share of the public or social housing stock was around 2.5% (the remaining 5% was categorized as ‘other’). Public or social housing, via publicly protected housing such as VPO (Vivienda de Protección Oficial-Officially Protected Housing) has been substantial in the home ownership sector (see also Hoekstra et al., 2010), but marginal in the rented sector. The private rental housing, after five decades of continuous decline, has grown in Spain in the decade after the GFC, although with some interregional heterogeneity (Botelo-Azevedo et al., 2019). Three factors play a role here: the small percentage of the public or social rental sector, the increas- ingly strict credit restrictions for vulnerable groups after the crisis, and public policy’s conditional aid to private landlords which rent their houses against below market prices to eligible applicants (Pareja & Sanchez-Martínez, 2017a). Structurally and culturally home-ownership and private renting have fea- tured as the dominant institutional logic, without real competition of other models or dynamics. Historically, home ownership is seen as a guarantee for family well-being. For many people a house is their main and/or only patri- mony. Over time, housing policies have been governed more by criteria to stimulate economic activity than by social policy criteria. In the 1920s and 1930s in some industrial areas, tenants began to orga- nize and mobilize. After recovery of democracy, and more intensively since the 1990s, the sector of private housing has gradually collectively organized (tenants in ASVAL, estate agencies in AIC, professionals in FIACBI, large firms in FADEI).

Housing-related financial services and banking have been domi- nated by private commercial banks, within a structural logic of large capital’s interests. The small sector of cooperative housing has not developed policy- oriented collective action. Historically, the idea of cooperative housing has mainly been applied in the process of development and construction of subsidized houses or build- ings. The purpose was essentially to offer home ownership at a lower cost. That is, once the construction was over and the houses had been allocated, the cooperative disappeared. Thus, the majority of cooperatives were purely 10 M. AHEDO ET AL. transitory legal tools, designed to build officially protected state subsidized housing (Etxezarreta & Merino, 2013). The first cases of cooperative housing took place in the late nineteenth century, somehow related to the movement of consumer cooperatives. In the 1920s, housing cooperatives were developed under incentive of the Leyes de Casas Baratas y Económicas (Laws for Affordable and Economic Hous- ing). In 1942, legislation defined housing cooperatives as a specific legal entity (Merino, 2018). The 1954 Law on limited income housing promoted some cooperative-based construction of housing for home ownership, led by companies, unions and popular associations. In the late 1950s and early 1960s, the first associations for housing construction cooperatives arose in provinces, such as Valencia and Madrid, and they institutionalized the model of construction-based cooperatives. In the 1980s, this model was given new impetus to meet new needs. In the late twentieth century and early twenty- first century, this cooperative sector took a downward turn, because of scarce supply of land, increased production costs, and the economic crisis in general (Salinas & Sanz (dir.), 2003; Merino, 2018).

The dominant private housing model of the last decades has roots in decades of property friendly measures such as tax incentives and land liberal- ization. Promotion of private construction substituted industrial policies, and affordable housing policy focused on the limited construction of officially pro- tected housing. The 2008–2010 financial crisis had devastating consequences in terms of foreclosures and evictions (695,121 foreclosures between 2008 and 2016). Since then, transnational investors have acquired a great number of dwellings, mainly two types: dwellings whose former owners have been evicted as a result of non-payment of loans, and public or social housing, as for example in Madrid (Janoschka, et.al., 2019). Policies and regulations are unable to limit and control speculative dynamics, and arguably the foundation for the next housing crisis is currently being laid. 4. Recent developments: policies and regulations, and societal dynamics 4.1. Denmark: changing regulations and socio-political aspects The general law on housing cooperative associations is basic and flexible, and it prioritizes the principle of majority decision in members’ assemblies. Poli- cies for the housing cooperatives were rather supportive since the 1970s until the late 1990s, and rather general and regulative since then. As regards socio- political dynamics, three interrelated levels can be distinguished: a micro- internal, an internal-external and a macro-external level. At the micro-internal level, each association has its own statutes, and its functioning is crucial for the quality, improvement and maintenance of the REVIEW OF SOCIAL ECONOMY 11 dwellings. Cooperative housing associations have to find a balance between individual interests and the interests of the collective good.

If individual inter- ests are prioritized, there can be a tendency to low investment in common life quality, and a focus on price increase. The internal-external level and its corresponding relations refer to the social orientation. How socially oriented have the housing cooperatives been? The price question can be a good indicator. There is the annual decision about the square metre price, and about which valuation to use in the maximum price formula that was established in 1976 in order to secure an affordable housing form. The use of such maximum prices makes the Danish cooperative sector different from Sweden and Norway, where market prices prevail. A key input for the maximum price formula is the public valuation of dwellings and proper- ties. Cooperative housing has been valuated in the same group as social rental properties. The public valuation was long criticized, and in 2013 it was tem- porarily suspended. While the new public valuation has been object of political and technical discussions, private valuation has been increasingly deployed. At the time of writing, a new public valuation system is expected to be introduced from 2022 onwards, and for housing cooperatives probably in 2023 or later. In the current situation, associations can choose if they want to keep a social orientation or follow the logic of the private market. In the former case, associ- ations prefer to keep the prices in line with living costs and salaries, based on the existing public valuation. In the latter case, they may determine the price within a value-range suggested by a private valuator and approve high price increases, so that the co-owners can make profits if they sell their dwelling. Which of the two options is dominant?

According to a 2018 report by the offi- cial statistics institute 5 : (a) in 2016 about 60% of housing cooperatives used the 2012 public valuation to determine the price; but ABF has observed a growing tendency to use private valuators; and (b) price increases in the cooperative sector have been lower than average; from 2014 to 2017 prices grew 15%, whereas prices in the homeownership sector increased 30%. In the 2014–2017 period, the cooperative sector’s average actual price was 90% of the maximum price according to the standard maximum price formula based on the public valuation. This report speculates that the price-setting in the cooperative sec- tor evolves slower than in the homeownership sector. In other words, prices in the cooperative sector are still rather socially oriented, but the growing use of private valuation may exert an upward pressure on price levels. This upward pressure might explain part of the stagnation of the cooperative sector in the last decade. With regards the external solidarity of housing cooperatives, some voices have criticized their privileged and closed character. Data from an official report 5 It compares price developments in the private and cooperative sectors: “Hvordan har priserne på andelslejligheder udviklet sig? (How have prices developed in the cooperative sector?)” January 2018, https://www.dst.dk/Site/Dst/Udgivelser/nyt/GetAnalyse.aspx?cid=29821 12 M. AHEDO ET AL. (Erhvervs-og Byggestyrelsen, 2006) indicate, however, that measured in income and education, the people living in cooperative housing belong to a broad urban middle and working-class. The elderly retired group is also well repre- sented. The argument related to their closed character refers to the criteria for getting access to the cooperatives.

Besides the registered waiting-lists, in their statutes, cooperatives can give preference to relatives of the current res- idents, or informally also to friends. In this respect there probably is a high heterogeneity among the associations. The macro-external dimension relates to the policy influence of housing cooperatives. This became more salient since 2019, when the new social demo- cratic government recovered the Housing Ministry. ABF, representing a half of all cooperative associations, made its voice heard in the debates. The most debated issue was the housing regulation law (the paragraph 5.2.). This para- graph, from 1996, makes it possible to increase the value of dwellings in general, and the rental prices in particular, if more than 258,000 Danish crowns (since 2019, 6 in 1996: 170,000) are used to substantially improve the dwelling, especially the sanitary, kitchen and isolation. In all types of housing, also the cooperatives, the paragraph has been deployed in order to increase the value of the dwellings. In the last decade, foreign investment funds have intensively used the paragraph for their speculative rent seeking strategies, which led to a sharp increase in rental prices. In February 2019, the previous govern- ment established an expert group to produce a report about this disputed regulation. In October 2019, the Ministry published the experts’ report, which proposed four different models to reduce or eliminate the negative effects of paragraph 5.2, especially the soaring of the rental prices. In late January 2020, a majoritarian parliament agreement was reached on a transitory period (or quarantine) of five years before improvements can affect the value of the dwelling. In June 2020, the new housing act excepted housing cooperatives from the quarantine, which was ABF’s objective despite internal different posi- tions.

The law also generalizes legally what has been standard in the majority of the cooperative associations: its dissolution requires 80% of the votes. The application of the law generates ambivalent expectations for housing coop- eratives. One the one hand, the law may have a dampening effect on general house price development, something which is expected by government, banks and experts. One the other hand, since they consist of dwellings without quar- antine requirement, housing cooperatives may become more attractive to private housing funds. In 2018–2020 some banks and credit institutions appeared critical towards housing cooperatives. In the capital area, as more cooperative associations were using the private market valuation model, and prices were rising, a few banks became reluctant to share risks in the cooperative sector. However, most 6 In the standard exchange rate in 2020 this is about 34,000 e. REVIEW OF SOCIAL ECONOMY 13 of the banks and real creditors still operate within the above indicated sus- tainable and risk-balancing mortgage system. Housing cooperatives still have access to finance that is provided within the framework of this system. In summary, since the 1970s the Danish housing cooperatives have been growing, based on civil traditions (associational culture) and public regulations (supportive policies, and policy participation of organized collective actors), within a sustainable mortgage system. They have also shown to be relatively socially oriented, involving a broad middle and working class in the most urbanized areas, and showing a certain level of external solidarity. However, the dominant private housing logics, together with the financial crisis, seem to have put some strain on the further development and the social orientation of the housing cooperative sector. 4.2.

Netherlands: a renewed interest in housing cooperatives In the Netherlands, housing cooperatives refer to a specific form of organi- zation rather than to a specific form of housing. The distinguishing feature is that people join forces in a cooperative legal framework in order to shape their housing situation. Three main types of housing cooperatives can be discerned (van der Meer, 2015): cooperative rental housing in which there is collective ownership of the housing complex; the homeowners’ co-operative (individual home owners organized in a cooperative organization); the management co- operative (dwellings are owned by a housing association but a cooperative of tenants is responsible for their management). None of the above models corre- sponds to the so-called Andel model that is common practice in countries such as Denmark. In the Netherlands, arrangements in which residents buy a share in a housing cooperative in exchange for which they receive the right to use the dwelling are, as far as we know, non-existent. Interest in cooperative housing is clearly on the rise in the Netherlands. This corresponds well with a general societal trend that urges people to take mat- ters into their own hands rather than to rely on the action of public institutions. People may have different motivations for engaging in a housing co-operative. In general, initiators of cooperative housing projects are looking for a more affordable form of housing, social cohesion and/or a more sustainable lifestyle. Given the fact that the Dutch housing cooperative sector is still in its infancy, it is too early to already draw conclusions on the micro-internal and the internal-external relationships. With regard to the macro-external level, the implementation of the renewed housing law of 2015 was of crucial impor- tance.

By reintroducing housing cooperatives as a legal and relevant form of housing, this law formalized and institutionalized the societal interest in coop- erative housing. As a follow-up to the introduction of the renewed housing law, the Dutch government has commissioned Platform 31 – a private non- profit knowledge and network organization in the field of housing and the built 14 M. AHEDO ET AL. environment – to set up an experimentation (2015 and 2016) and action (2017 and 2018) programme. These programmes gave support to civil actors that wanted to start a housing cooperative, for example by publishing guidebooks, guidelines and exemplary legal documents. Furthermore, the developments in the field of cooperative housing were closely monitored and described in professional publications. In addition to the action programme, local authorities sometimes also explicitly support cooperative housing initiatives. For example, the municipal- ity of Amsterdam has reserved three locations for co-operative housebuilding. However, there are also municipalities that are reluctant to sell building land to cooperative builders. This is due to the fact that municipalities generally receive a higher price if they sell the land to commercial developers. Access to finance can also be a problem for housing cooperatives. Many banks see hous- ing cooperatives as complex and risky lenders (see Conijn & Wetzels, 2020 for more details) and are reluctant to provide the finance that these cooperatives need. A specific Dutch variant of cooperative housing concerns the housing coop- eratives that are started by former social rental tenants.

The renewed housing law states that groups of at least five social rental tenants that live in each other’s vicinity, and of which at least half of the tenants have an income that falls within the income limits for social rental housing, are allowed to start a housing cooperative. The housing association is then required to provide financial support (at least 5000 Euro) for the drafting of a financial and orga- nizational plan for the undertaking. Once the plan for the cooperative is ready, it will be discussed with the housing association. The housing association can refuse the plans of the cooperative, but only if it provides a sound motivation for this. If the cooperative does not agree with the given motivation, it can ask the national supervisory body to come to a judgement (van der Meer, 2015). In order to make the realization of housing cooperative financially feasible, spe- cial sale regulations apply. If the housing association decides to sell dwellings to the co-operative, a reduction on the sale price of up to 50% of the mar- ket value may be given (tied to regulations with regard to subsequent sales in order to prevent speculation). The original action and experimentation programme ended in 2018. In their final evaluation, Platform 31 concluded that housing cooperatives satisfy a demand among citizens and can have a substantial added value for society. They observed that the trend towards cooperative housing is growing and gaining momentum. In 2018, there were already more than 100 initiatives in the field of cooperative housing. 7 Most of these initiatives are still in the incuba- tion or initiation phase and only a few cooperatives are already active (Platform 7 See https://www.cooplink.nl/initiatieven for an overview of initiatives that have registered at the knowl- edge network housing cooperatives. REVIEW OF SOCIAL ECONOMY 15 31, 2018).

Indeed, setting up a housing cooperative is a very complex and time- consuming process, and many initiatives have stopped somewhere in their journey to completion. This is also related to the fact that many institutional and financial barriers and complexities still remain, and not all stakeholders are aware of the potential added value of housing cooperatives (Platform 31, 2018). In order to further foster the development of Dutch housing cooperatives, a renewed action programme, again coordinated by Platform 31, was started in 2020 and will run until the end of 2021. This action programme consists of a pilot programme (with 10 participating housing cooperatives), support for COOP-link (the umbrella organization for Dutch housing cooperatives, see also Section 3.2) and research into removing the barriers that housing cooperatives face. 4.3. Spain: a new form of housing cooperatives After the 2009 crisis, several aspects of the housing market have evolved. Rent- ing has become more feasible, especially for younger-aged cohorts. Demo- graphic studies forecast that future housing demand will fall, mainly due to an ageing population (Módenes & López-Colas, 2014). New players have appeared on the housing market. Some bankrupted promotion businesses suddenly turn into cooperatives, which can be called fraudulent cooperatives (Otxoa-Errate, 2018). Some banks became managers of huge stocks of dwellings, due to a high number of evictions (Pareja & Sanchez-Martínez, 2017b). Transnational investors are increasingly buying Spanish property (Janoschka et al., 2019). 8 In general, while private and commercial interests remain dominant in the Span- ish housing sector, there is an increasing interest in, and need for, alternatives for the unaffordable private housing sector. Interest in cooperative and collaborative housing has increased in recent years.

Currently, we can find the following types: self-construction under a cooperative model in order to award ownership of houses; cooperatives for rehabilitation; management cooperatives; and transfer-of-use cooperatives, (inspired especially by the Andel model from Denmark and Scandinavia). The cooperatives to award ownership have always been the most common form of cooperative housing in Spain, linked to the promotion and construction of VPO (Vivienda de Protección Oficial – Officially Protected Housing). The cooperatives for rehabilitation are also quite common within contexts of building or condo- minium rehabilitation, promoted recently by public policies. In these cases, the cooperatives are transitory tools that are resolved after the property has been constructed or renovated. 8 The case of Blackstone is relevant in Madrid and Barcelona. 16 M. AHEDO ET AL. Within the transfer-of-use cooperatives two somehow overlapping devel- opments can be distinguished: the andel-like cooperatives that can mostly be found in urban contexts, and the so-called cohousing movement with a broader spatial distribution. Policy and societal dynamics have shaped their development. With respect to policy and regulatory developments, the 1999 legal framework (Article 89.42 of the Ley de Cooperativas Estatal (National Cooperatives Law) 27/1999) allows for a separation between ownership of the dwelling and the right to use it. There are also regional regulatory differences as regards the legal structure of a housing cooperative. For example, in Catalo- nia the 2008 Housing Law was rather general on cooperative housing, whereas the Basque Country’s 2015 Law on Housing regulated the cooperative hous- ing model in great detail, prospected at future application (Basque Housing Observatory, 2015); this was also the case in the Balearic Islands.

Andel-like cooperatives have been promoted by some regional and local public administrations. For example, in Catalonia, new housing laws and poli- cies developed between 2007 and 2009 have promoted this type. In 2016, the Barcelona City Council granted five plots of land for the construction of hous- ing on cession of use: in 2019 the cooperative group La Balma was awarded one of them, and a building project with twenty dwellings was proposed jointly by Sostre Cívic and the Laboqueria cooperative; both are currently in the construction phase. The City Council of Seville in 2020 set up a commis- sion to promote and encourage housing cooperatives based on transfer of use. The Txomin-Enea project in Donostia-San Sebastian, promoted by the Basque government, started developing the tender process for the promo- tion and building phase, assigned to a cooperative of the corporate group of Mondragon Cooperatives. Other public initiatives, however, have been para- lyzed or canceled; the so-called innovative urban model for the construction of affordable apartments in a regime of cession of use promoted in Zaragoza in 2018 did not obtain the expected results, and the City Council turned it into a conventional project, via 64 VPOs. In summary, the necessary public- civil collaboration has slowly emerged, as can be observed in the Barcelona cases. Cohousing or collaborative housing tends to be based on new construc- tions, and a number of them follow the andel-type cooperative model. In general, this type of housing favours community life and there are spaces for collective use (along with spaces for private use). Socially, there are two cohousing dynamics: senior cohousing and inter-generational cohousing, in both cases mostly realized in new constructions.

The senior cohousing is spreading in response to an ageing society and changes in family models, care economy and gender roles. According to data of the MOVICOMA project, 9 in 9 http://movicoma.blogs.uoc.edu/ REVIEW OF SOCIAL ECONOMY 17 early 2020 there are 15 active senior cohousing complexes, and 35 under con- struction. Two waves have been identified in this segment (López & Estrada, 2016). A first wave began in 2000, with the Residencial Santa Clara in the city of Malaga, and quickly spread to other cities. 10 These cooperatives were orga- nized around the need to share care resources. The second wave is mostly driven by building a community life project, based on shared values and a collaborative nature in order to alleviate the negative effects of individualiza- tion in ageing. Various regional and local public administrations have recently supported cohousing projects, in cities (Toledo and Zaragoza) and regions (the Basque Country, etc.). Inter-generational cohousing has had a relatively lower success, although there are interesting examples, such as Entrepatios and Laborda (Cabré & Andrés, 2018). This lower success is due to different factors (Etxezarreta et al., 2018b): (a) financial difficulties related to low income and precarious working conditions for many young people; (b) cultural convictions related to housing as an investment asset and family patrimony; and (c) admin- istrative difficulties when putting the cooperative into operation. Despite these difficulties, according to a collective action platform, 11 currently there are more than 50 intergenerational cohousing projects. Regarding financial aspects, in senior cohousing projects, members usually have property assets that facilitate the provision of loans and other finan- cial support.

In intergenerational initiatives, with less property assets, finan- cial support has often been provided by ethical banks, such as Triodos and Fiare (Etxezarreta et al., 2018a). In recent years there has been an increase of consultancies and small organizations (such as Sostre Civic and Jubilee Association) that assist these projects with advice. Andel-based cooperatives financially and legally depend on collaboration between public institutions and cooperatives or associations, as observed in the cases from Barcelona and Donostia-San Sebastian. In terms of housing policy-related collective action, the most relevant has been the grassroots housing rights mobilization after the 2008 crisis. Cooperative housing has not yet developed organiza- tional dynamics, although it has started to construct collective identity and voice. In summary, in Spain the latest housing trends point to emerging dynamics towards socially oriented housing cooperatives in two forms. The cohousing cooperatives can be considered a bottom-up dynamic of civil mobilization. The andel-like cooperatives are still in the initial steps, as they still need more regulatory development, and clear institutional action to enact the necessary effective public-civil cooperation. While national policies have been lacking, the local and regional public institutions’ policy initiatives have been crucial. 10 Servimayor in Cáceres (2010), Puerto de la Luz in Málaga (2011), Profuturo in Valladolid (2012), La Mural- leta in Tarragona (2013) Trabensol in Madrid (2013), and Convivir, Cuenca and Sol Dorado in Málaga (2015). 11 https://cohousingspain.org/categoria-directorio/en-proceso/ 18 M. AHEDO ET AL. 5. Conclusions: learning from three models in searching alternatives to private urban housing From the international comparison it is possible to observe commonalities and differences.

In the three selected countries, cooperative housing is getting a renewed political and institutional momentum and interest, while being in dif- ferent stages of development. Commonalities also relate to the challenge of overcoming private market pressure when providing affordable housing to increasingly heterogeneous populations, particularly in urban contexts. Urban middle and low classes are facing the problems of a highly speculative hous- ing market. Besides better regulations and more social housing, socially ori- ented cooperative housing allows citizens to actively create a viable and social cohesive alternative for private market-oriented housing. In Denmark, democratic corporatism, associational culture and supportive regulations generated in the 1970s and 1980s the emergence and develop- ment path of housing cooperatives, constituted as associations. The cooper- ative housing sector has gradually grown, up to the current 8% of the whole housing stock, constituting a well-developed model of generally affordable cooperative housing. Since 2001 neoliberal regulations and financial and hous- ing speculation have caused some stagnation in the cooperative housing sector. In recent years, the re-established Housing Ministry has initiated some housing policies that intend to make the Danish housing system more just and socially sustainable, especially in the central urban contexts. The scope and effects of these measures for housing cooperatives will be known in the next years. In the Netherlands, the renewed interest in cooperative housing is related to a restructuring of the social rental sector, as well as to broad structural trends. Historically, cooperative housing occupies a marginal position within the Dutch housing system.

However, since the introduction of the renewed housing law in 2015, the national government has started to stimulate housing cooperatives as an alternative affordable form of housing. The greying popula- tion and the affordability problems on the private housing market increasingly make housing cooperatives an attractive option for middle-income groups. In Spain, the traditional housing cooperatives were used to promote subsi- dized homeownership. The Danish andel-like cooperatives did not exist until recently. Indeed, in the aftermath of the Global Financial Crisis, socially ori- ented housing cooperatives are emerging in Spanish urban areas, in some regions within increasing regulatory support by regional governments. They are mostly realized in the form of senior cohousing, which is related to an ageing society, changes in gender roles and the care economy. Nevertheless, inter-generational housing cooperatives are also emerging, although these types of housing cooperatives still face considerable constraints and barriers. Two main conclusions can be drawn. First, the development of cooper- ative housing depends on dialogue and collaboration between local public REVIEW OF SOCIAL ECONOMY 19 institutions and associative civil groups within supporting regulations and poli- cies. Policies and regulations that support cooperative housing are politically sensitive and technically complex, as they overlap with more general policies in the field of housing, urban development, finance, and organizational rules (associations, cooperatives, etc.). In order to overcome these complexities, an iterative and experimentalist approach to policymaking seems to be needed.

Second, the social orientation of housing cooperatives depends on two factors: (a) public policies that stimulate and facilitate it, such as public valuation stan- dards and general organizational rules; and (b) the sense of collective social solidarity and civic morality among the members of the cooperative hous- ing movement which is based on organized social interaction and practices. The Danish case illustrates these two conclusions. The existence of reasonable public valuation standards has long facilitated cooperatives’ socially oriented decisions on annual price increases, and the suspension of these standards in 2013 has fostered private market logics. The federation of cooperative housing (ABF) has played an important role in the dialogue with authorities, political parties and other collectives, thereby promoting the social orientation of the cooperative housing. We hope that the insights of our paper provides a basis for mutual learning, inspiration and complementary developments. As long as the private hous- ing market in our cities continues to lead to inequalities, expensive prices, and speculation, cooperative housing can be a feasible and just alternative, specif- ically if it has an explicit social orientation. Therefore, policies and regulations are needed to foster the growth of the socially oriented cooperative housing sector. These policies can be seen as cost-effective welfare policies as they can reduce other kinds of public expenditures in our ageing societies. We therefore call upon policymakers to fully integrate this form of housing into housing poli- cies and housing market regulation. In this respect, policymakers should work in close dialogue and interaction with relevant representative groups and civic organizations. There are still many issues that require further research.

For example, it remains somewhat unclear whether housing cooperatives mainly cater for middle-income households, or whether they also have the potential to accom- modate the most vulnerable groups (who are currently mainly housed in social and private rental housing). Furthermore, the spatial aspects of the phenomenon require further attention. How does cooperative housing fit in the spatial-economic structure of housing markets? To what extent can it smoothen or mitigate gentrification processes? Disclosure statement No potential conflict of interest was reported by the author(s). 20 M. AHEDO ET AL. Data availability statement Sharing is not applicable to this article as no new data were created or analysed in this study. Notes on contributors Manuel Ahedo is Part-Time Lecturer at the Faculty of Social Sciences in the Univer- sity of Copenhagen (Denmark). He has a PhD in Sociology (2002) from the University of the Basque Country (Spain), and he has published mainly in the fields of sociology of socioeconomic policies, comparative economic sociology, and comparative policy analysis. Joris Hoekstra is Assistant Professor of Housing Studies at the Faculty of Architecture and the Built Environment of Delft University of Technology (The Netherlands). He also holds a position as visiting professor at the University of Free State in Bloemfontein, South Africa. Joris is specialized in comparative housing research, housing policy and social housing. He is particularly interested in the interactions between macro-level trends in the political economy and welfare state, and micro-level developments in the field of housing. Between 2010 and 2017, Joris served as managing Editor of Journal of Housing and the Built Environment.

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