The lack of affordable housing in the United States has policymakers looking beyond American borders for innovative solutions. At a congressional hearing last week, Urban Institute Senior Fellow Susan Popkin told the House Subcommittee on Housing and Insurance that we could learn from the United Kingdom by treating housing as an entitlement and devoting more funding to revitalizing and expanding the affordable housing stock.

Both countries face similar challenges of rising rents and an aging stock of subsidized housing, said Popkin, director of Urban’s Neighborhoods and Youth Development initiative. However, in the United Kingdom, housing is an entitlement and an essential part of the safety net.

The problem of housing affordability in the United States is primarily the result of widening income inequality, Popkin said. “The gap between the ability to pay and rents in the marketplace are particularly acute for the poorest households.”

Additionally, the availability of federal rental assistance falls far short of needs. For every 100 extremely low income renter households in the country, there are only 28 affordable and available rental units; without housing assistance, that number falls to just 1 affordable unit for every 100 renters.

“The public and assisted housing sector in the US is just under 2 percent of total housing stock, while in the UK, that figure is 16 percent,” said panelist Harris Beider, professor in community cohesion at Coventry University’s Centre for Trust, Peace and Social Relations.

Another fundamental difference between the two countries is that the United Kingdom does not have the same legacy of racial segregation and discrimination as the United States.

“Much federally subsidized housing stock is located in predominantly minority, chronically disadvantaged high-crime neighborhoods,” Popkin said. In contrast, as Popkin and Beider’s research describes, the United Kingdom is less racially diverse, and the majority of their public housing residents are white. Housing policies may have contributed to ethnically segregated neighborhoods but not to the degree seen in the United States.

The US Department of Housing and Urban Development has attempted to revitalize public housing through HOPE VI and Choice Neighborhoods. Popkin’s research indicates that many residents in the HOPE VI initiative moved to improved housing in less-poor neighborhoods, but the program produced fewer new public housing units than the number that were torn down.

Both the US and UK governments have pivoted to the private sector for solutions. In the 1980s, the United Kingdom introduced the Right to Buy policy, an attempt to deregulate and privatize the affordable housing sector. Bieder said evidence indicates the policy contributed to a crisis when housing units were not replaced and rents increased. Currently, the United States uses a toolkit of programs that engage the private sector, including housing choice vouchers, project-based rental assistance, and the Low-Income Housing Tax Credit.

“I do have concerns that public housing rights are at risk in privatization,” said panelist Jaime Lee, assistant professor of law and director of the Community Development Clinic at the University of Baltimore School of Law. “I’m also concerned that there are certain legal tools that can be used in privatization that can harm affordability and also restrict access to public housing.”

Popkin agreed, stating in her testimony that we need further investment in affordable housing to meet the nation’s needs: “Privatization will not solve the fundamental challenge in the United States.”