Zoning systems are common across the US, though due to its federal and highly devolved government their zoning systems vary significantly, even within the same state. In general, housing is more affordable across the US. Despite higher GDP per capita and bigger houses than the UK, the median house price is cheaper than in England.
However, similar to the UK, this national average hides large differences in housing costs and inequality between cities. A cheap, downtown, one-bed apartment in Detroit will set you back £15,000 – a similar flat in downtown San Francisco will cost £380,000. These housing shortages are local because, like the UK, their planning systems have disconnected local housing supply from the demand for new homes driven by urban labour markets.
This is mainly because their zoning systems have replicated many of the problems of the English discretionary planning system. Although there is a greater supply of land for development, the suburbs of American cities are dormant and in the same way that the suburbs of cities in England and Wales see no development.
The culprit here lies in the diversity of zoning systems across the US. Cities and local governments will usually write their own zoning code. They are both “referees” and “players” in their housing market, and so therefore write and apply inflexible codes which block new development and protect high house prices for existing homeowners. “Single-family zoning” which only allows massive, detached houses to be a built is a major problem across America, and economic and racial inequality is deepened by a tendency towards discriminatory “exclusionary zoning”.
Recent years have though seen the emergence of a strong “Yimby” movement which seeks to overcome these barriers and make their zoning systems more flexible. Minneapolis and Oregon have both formally abolished single-family zoning and other places are following suit, with reformers focusing on the state and the federal level.
In terms of lessons for reform in the UK, the American experience shows how important it is to have a flexible zoning code, and to maintain a strong role for an upper jurisdiction such as the UK or devolved government to write and oversee the implementation of the code. It is not centralisation or anti-localism to for national government to have a clear role as a referee of the planning system. For devolution to succeed, the right responsibilities must sit at the right level.