Housing and the Home, a comparative policy analysis of home ownership policy supports in Ireland and Norway
Ireland and Norway are two small countries on the periphery of Europe, with comparable populations, but which are frequently categorised as having largely divergent social welfare systems, and are rarely seen as being historically similar in their approach to social welfare provision and their approach to housing, with Norway adopting a social democratic social welfare model in line with its Scandinavian peer countries, and Ireland instead opting for a more liberal system which has been strongly influenced by developments in the UK (Esping-Andersen, 1990). However while the approaches are typically seen as quite divergent, they have nevertheless both experienced and supported a large share of owner-occupation.
Owner Occupation in Ireland
Ireland has a long and complicated history with housing and the concept of the home, indeed the concept of home ownership was one which was highly pertinent in the early stages of the foundation of the state (Norris, 2015). It has been this historical experience of land seizures and weak property rights for many in Ireland that has been seen as a driving force in the development of a state-supported policy of promoting home ownership (National Economic and Social Council, 2014). There is seen to be a strong impact of the agrarian nature of Ireland’s economy until relatively recently on owner-occupation rates (Norris, 2015). However, generally speaking, the Irish approach to housing was until the late 1800’s and early 1900’s comparable to the housing system utilised across the rest of Britain at the time (Norris & Fahey, 2011) with charities largely providing social housing and the state being relatively absent from shaping the housing market. However, when one looks at the Irish experience post independence we can see a widespread state-led support for owner-occupation.
The supports which were provided included grants for first time buyers, tenant purchase schemes and tax relief on mortgage interest (Norris, Coates & Kane, 2007). This was part of a dominant policy framework that was supported through a number of policy interventions that encouraged home ownership. However, beginning in the 1970’s / 1980’s we began to see a reversal in this trend, and, while gradual, it has remained consistent and with the impact of the global financial crisis in 2008 we have seen an acceleration of this trend of a decline in home ownership and central government support for home ownership.
Table 1. Households By Tenure Type – Source (Central Statistics Office, n.d.).
Indeed an evaluation of the growth and decline of home ownership within Ireland can be understood as part of a broader lens through which to evaluate the Irish economy and society writ large, with much of the early growth of home ownership being an implicit tradition of asset-based welfare (Norris & Fahey, 2011). This is a form of social protection which takes the provision of an asset as a paramount form of social welfare, in lieu of conventional services and benefits.
The concept of asset-based welfare is one which has been used to explain the unique housing model used in Ireland when compared to peer countries in Europe (Norris & Fahey, 2011). A key structure of the way in which asset-based welfare is seen to function is where the subsidisation and development of owner-occupied housing have been key elements of socio-economic development and consolidation of the authority of the state.
In the case of Ireland which still remains relatively rural by comparison to other European countries, this model of state support for asset-based welfare developed from this agrarian rural focus and the focus of “government intervention in Ireland has traditionally prioritised enabling low income rural households to buy farms and their urban counterparts to purchase dwellings, rather than conventional social security provision.” (Norris, Coates & Kane, 2007), and a comparable model such as that seen across many European countries was hindered due to the relatively weak labour and social democratic influences on state housing policies (a factor which had a particularly large influence in the case of Norway)
. It was the support from an early stage of the state’s foundation for tenants to be allowed to purchase their social housing at subsidised rates which led to a significant expansion in owner-occupation in Ireland (Norris, 2015) and typifies an understanding of asset-based welfare as a key consideration for evaluating the growth in owner-occupation in Ireland.
The context for Owner-Occupation in Ireland
With Ireland being relatively underdeveloped with regards to industrial development, as compared to many peer countries across Europe, the demands in relation to housing were quite different, with a large focus on the agricultural sector, much of the focus has been on ownership of land as an inroad to economic security.
In the late 1800’s we can see this particular factor becoming more pronounced throughout the land wars which led to a strong focus on home ownership and access to land for farmers. In the comparatively small urban space around the same time, we could see a reliance on private rented housing, however this was of incredibly poor standard when compared with housing across Europe, and led to the rise of ‘tenement housing’ as more and more people were forced into exceptionally poor housing as a way to meet their housing needs. However, with only 10% of the Irish population living in cities in the early 1900’s the supports available were not targeted towards alleviating the housing issues within cities.
This can be seen in early housing supports and in particular the reduction in land annuities due serves as an early illustration of the ways in which rural tenants would be enabled to become owner-occupiers, this was a policy advanced by the new Fianna Fail government in 1933/1934, following on from this the process of owning one’s home was accelerated with the 1936 labourers act affording rural social tenants the same opportunity, with the gradual reduction in the percentage of pre-purchase rents to mortgage payments being capped, we could see greater uptake (Norris, 2015).
Home ownership policies in Norway are quite distinct from the Irish experience in that they did not largely stem from the experiences of famine, evictions and land wars relating to ownership, however, they have remained unusually high by comparison to other European countries generally and Scandinavian peer countries in particular (Ruonavaara, 2008). The Norwegian experience in home ownership, and indeed its large growth since the foundation of the Norwegian state in 1905 owes much of its development to the social democratic, universalist system which has underpinned the dominant view and indeed structure of the housing market and its role within society (Ruonavaara, 2008).
The Norwegian state support for home ownership, which has broadly stayed above 80% in recent years, has been largely influenced by the dominant social democratic vision of housing as a social commodity which was essential for equitable participation in society and the favourable view afforded to co-operative housing in particular. Co-operative housing or part ownership is a point of considerable difference between Ireland and Norway.
Whilst there have been recent challenges and indeed large scale changes to this system since new public management reforms were introduced in the 1980’s (Sandlie & Gulbrandsen, 2017), these reforms have particularly been seen in relation to price controls being removed and the gradual move from a universalist system to a more selective model focused on targeting supports to vulnerable individuals.
This is a common change which can be seen in a number of European countries, in Ireland the move from universal supports towards targeted supports towards removal of supports is seen to follow the paths outlined within (Bengtsson, 2008). In the case of Norway there is an increased concern that targeted supports will be removed to allow Norway to move to amarketised system, similar to that which can be seen in Ireland.
In the context of a comparison between two similar countries, who enjoyed similarly high levels of home ownership, it is quite difficult to separate the development of Irish home ownership patterns, from the unique Irish historical experience, and the impact of culture on the development and indeed widespread state support for increasing the percentage of homes which are owner-occupied.
Indeed (Norris, 2015) builds on the ways in which this governmental support was at its pinnacle in that there was a “phase when government involvement in property redistribution was radically extended…” This expansion was very much targeted through a multitude of policy interventions at firstly removing people from living in tenement housing, but also in supporting the large scale building of social housing units, and supporting, typically rural home ownership in the early stages of the new state’s involvement in the Irish housing market.
The Irish experience of evictions and historical ownership of Irish land by absentee landlords led many Irish people to see home ownership as the most secure form of tenure. Indeed until quite recently we could see remnants of this strain of thinking within Irish governmental policy documents taking account of the fact that many still viewed home ownership as the most preferred form of tenure “Government Policy seeks to promote home ownership, not only because it is the preferred form of tenure for most people” – (Department of the Environment, Heritage and Local Government, 1995).
This Norwegian experience of promotion of housing co-operatives stems largely from the egalitarian social democratic vision promoted by the Norwegian labour party, which governed in various forms largely during the period 1935 – 1981 (Sørvoll, 2017). This experience of co-operative or indirect ownership is only parallel by Sweden which has an estimated 18% of total housing stock within co-operatives or shared ownership housing (Yip & Dalholm, 2006).
A key driver behind home ownership in Ireland was, and until quite recently continued to be the building of housing units by local authorities which were then sold on to the tenants of local authorities also known as tenant purchase. This has happened for two key reasons, the providing of government grants as opposed to loans ensured that local authorities who sold local authority housing were not left having to service the losses from discounts provided, alongside the system of differential rents generally meant that higher income tenants had an incentive to opt for a mortgage as opposed to continuing to pay rent as the costs of servicing a mortgage could be lower than the amount required to pay differential rents (Norris, 2015, Blackwell, 1988).
We can see this particular pathway firstly supporting the argument proposed by (Norris, 2015) that the model which was striven for was one in which welfare provision was largely met through provision of an asset, but secondly we can now begin to observe the distributional effects that this model of promoting home ownership has led too. (Norris & Hayden, 2018) highlight the damaging medium and long term effects of tenant purchasing of local authority housing at below market rates.
This has led to a significant decline in the resources available within local authorities to be able to meet replenishment rates necessary to ensure that local authority housing can continue to develop. While achieved differently we can see a similar model of development being promoted in Norway, with local authorities being financed through central financial institutions such as Husbank (Sandlie & Gulbrandsen, 2017) providing finance to local authorities and individuals to build housing units, and was a key factor in the growth of owner-occupation. However in Ireland the efficacy of schemes targeted towards those with a lower income is challenged in the work of (Norris, Coates & Kane, 2007) which highlight that when evaluating take-up of the schemes targeted towards those with lower incomes that widespread mortgage arrears really challenge the sustainability of the schemes, and cast doubt on the ability for these schemes to deliver unless there are material changes in those with lower incomes conditions.
The movement from a socialised towards a more marketised home ownership policy in Ireland as outlined within (Norris, 2015) coincides broadly with similar (albeit less pronounced) trends taking place within Norway during roughly the same period. The movement from broad-based and universalist approaches to promoting home ownership, towards more targeted subsidies to disadvantaged groups from the 1970’s / 1980’s and indeed to near total abolishment of such policies onwards has led to a decline in owner-occupied housing taking place within both countries. Indeed the rate and pace of this change in Ireland has been particularly rapid in the reduction of owner-occupation and in a global context is particularly unique (Norris, 2015). Building on the work of Norris and contextualizing much of the work that been done to explain the motivation for why such broad-basedsupports were provided at the policy level.
Through building on the work of (O’Connell, 2007) we can contextualise the growth and policy support for home ownership with Ireland, and indeed place the ongoing retrenchment of owner-occupation in the context of the global financial crisis and its impact on the Irish housing market. Indeed the work of (O’Connell, 2007) provides a good typology in which to build on a more contemporary policy. We have seen a long-lasting effect of the financial crisis being seen on owner-occupier trends in Ireland It is difficult when evaluating recent Irish policy responses to overstate the impact the financial crisis has had, and housing serves as a key factor in the development of the conditions that led to Ireland experiencing one of the most severe economic contractions in the world.
Financing Owner-Occupation & Financial Crisis
The financial crisis can be viewed as a watershed moment with regards to the relationship between Ireland and home ownership, whilst we are still in many cases reeling from the aftermath of the financial crisis, and many contemporary issues with regards to housing can trace their origin to the effects of the financial crisis. Indeed the current owner-occupation rates have not been seen in Ireland since 1971, and continue to decline (Central Statistics Office, n.d.).
The Irish experience through the global financial crisis was a particularly severe one, with GNP declining by 20.2 %, employment contracted by 8.25% and the rate of unemployment jumped from 6.4% in 2008 to 14.7% by 2012. The impact of the financial crisis was felt across the Irish economy. Housing was an area which felt the impact of the financial crisis, and many would say led to the crisis being as bad as it was, there was a 30% drop in house prices from their 2007 peak to 2011 (Norris, 2015) alongside a significant and long-lasting drop in housing output.
Banks and financial institutions which were particularly affected by the financial crisis also significantly reduced their level of borrowing. The impact of the squeeze within access to banking credit alongside a drop in the government’s ability to provide supports for home-owners let to a significant decline the rate of home ownership within Ireland, that was particularly accelerated from the gradual decline experienced since reforms in the 1980’s.
Home ownership fell from 77.2% of households in 2006 to 70.1% in 2011 (Norris, 2015) (the most recent rate is 67.6% in 2016) (Central Statistics Office, n.d.). The decline in house prices was particularly perilous, as the approach of asset-based welfare can be incredibly damaging during a period of significant decline in the price or value of the asset on which the welfare system has been predicated. We are also seeing the long-term effects of changing central bank rules on credit supply and increased eligibility requirements within the Irish mortgage market.
With regards to the financing of the Norwegian housing system since the end of the second world war, we have seen an incredibly large role being played by Husbank (which have financed an estimated half of all Norwegian house builds since the organisation’s establishment in 1946) (Gulbrandsen, 2004).
This large role played by a state provider of financial resources, alongside the universalist and egalitarian vision of housing, led to a system which focused strongly on ensuring a high degree of ownership of state-supported housing developments, especially when compared to Nordic peer countries (Ruonavaara, 2008). The reason for this widespread support for housing through Husbank was primarily due to “Any applicant making an application conforming to Husbank criteria was eligible to a subsidised housing loan. This meant that no means testing was applied to individual applicants.” (Sandlie & Gulbrandsen, 2017, Husbanken, 2018).
Through the support of Husbank the Norwegian government similarly sought to promote individual and co-operative home ownership largely through production subsidies which firstly sought to improve the volume of Norwegian housing stock, but also through strict price regulation and legislation which sought to dampen the ability to speculate on co-operative housing developments and ensure housing remained affordable in the second-hand market too.
This approach to housing speaks to the nature and vision of how housing is viewed through the dominant policy paradigm, in that as stated by (Sandlie & Gulbrandsen, 2017) that the motivation for promotion of home ownership was “anti-business and anti-landlord sentiment within the labour movement” speaks to the importance of the labour movement in promoting individual and collective home ownership.
We can see this development of the model applied to housing changing significantly in recent years, although relatively insulated from the effects of the global financial crisis (and significantly less affected than the Irish experience through the global financial crisis), Norway has, however, begun to change its approach to housing in line with broader trends in altering the universalist nature of the Norwegian social welfare system.
This can be seen, as illustrated in (Sandlie & Gulbrandsen, 2017) where increasingly stringent deposit requirements implemented by the financial supervisory authority of Norway (Sandlie & Gulbrandsen, 2017, Finanstilsynet, 2012), there have also been concerns that more targeted supports may lead many to rely more on families in reaching required deposit rates, this can lead to an exasperation of social inequalities and reduced access to owner occupation.
Both countries have historically had high levels of government intervention in the mortgage markets (Fahey & Norris, 2009, Gulbrandsen, 2004). As mentioned above the case of Norway saw a large percentage of the financing coming through the state acting in a role as a direct lender, this was the role which was largely managed through Husbank and local municipalities (Gulbrandsen, 2004).
The state’s housing bank, which describes its role “to provide central and local government support for reconstruction and new building.” (Husbanken, 2018) Since its foundation, Husbank has remained the Norwegian government’s most important tool to implement its housing policy and has played a crucial role in the development of the Norwegian welfare state (Husbanken, 2018).
However, in the case of Ireland this was instead achieved through mortgage provision through local authorities which had increased levels of home ownership as an objective. However during the transition of the housing system from a socialised system to a marketised system, the mortgage lending system was privatised and then deregulated, signalling an end to the government serving as a developer / enabler of owner-occupation (Norris, 2015) .
This trend can serve as a microcosm to highlight the overall decline in the universalist and egalitarian nature of post second world war Norwegian housing policy, and the impact which the adoption of new public management policy reforms have had on the nature and makeup of the housing market in Norway. It is for this reason that whilst examining headline figures may indicate there is little comparative relevance between Ireland and Norway, when we look at a like-for-like comparison of freeholder owners we can see a similar market, albeit built with differing motivations.
Owner-Occupation Policy Context.
Whilst we can see that in the context of Norway the social democratic, labour and union support for owner-occupation led to the development of a model focused on ensuring a high degree of home ownership, this is particularly noticeable when we look at the large adoption of part ownership or co-operative housing in the context of Norway.
When we look at Ireland we can see a key driver behind such large owner-occupation figures historically can be attributed to the early adoption in both rural and urban areas, of local authorities selling on social housing stock to tenants, as outlined in (Norris & Fahey, 2011). This accounted for two-thirds of the dwellings built by local authorities had been sold to tenants and they accounted for a quarter of the owner-occupied stock by the 1980’s. This policy of encouraging tenant purchase in Ireland enjoyed widespread political support and served as a central policy framework that was supported by both the centre left and centre right, and was not viewed through the neoliberal model of privatisation of housing stock but instead as a way to achieve welfare objectives.
However, with regards to viewing the headline figures of owner-occupation in Norway, it’s essential to take account of the impacts of co-operatives. As can be seen below in the work of (Ruonavaara, 2008) and recent data collected from (Statistisk sentralbyrå, 2019) which highlights the vital role indirect ownership (or housing co-operatives) play in Norwegian owner-occupation figures.
By using Statistics Norway figures we can take recent years as an example as to how home-ownership figures in Norway could be understood as inflated when compared to Irish home ownership figures, however, the impact of co-operatives is an important constituent part of Norwegian housing policy geared towards owner-occupation (Statistisk sentralbyrå, 2019).
|Persons Per Cent.|
Table 2 (Statistisk sentralbyrå, 2019)
As can be seen in table 2, there is a great deal of similarity in recent Norwegian figures for freeholder ownership, indeed the figure of 70.6% in Norway to the Irish most recent figure of 67.6% is quite comparable, it’s the unique Norwegian experience of promoting ownership co-operatives that leads to a significant difference to appear between the countries with regards to home ownership rates.
Ireland and Norway both enjoyed broad-based support for home ownership, albeit for largely differing reasons. Through the work of (Norris 2013) we see that even when 15 European countries were embarking on large scale housing building in response to world-war 2, Ireland was providing the highest level of subsidies to housing across these countries and we could really begin to see the emergence of a socialised home ownership policy regime through the 1950’s. This development was broadly similar to the widespread state support as can be seen through Husbank, towards the development of owner-occupation in Norway during the same period.
We have also began to see in both countries a move towards a more regulatory role for the state, with the function in both countries being towards ensuring that there is a “well functioning” housing market (Sandlie & Gulbrandsen, 2017, National Economic and Social Council, 2014). In both countries it has been this climb-down from large state support that coincides with the broad reduction in owner-occupation in both countries to levels which can be seen across much of Europe, and a greater role for social renting and the private rented market in particular.
However, it would be wrong to assume that the declining trends in owner-occupation in both countries is necessarily linear in fashion. While it is true that the decline is continuing mainly in response to a particular policy framework being advanced in both countries, owner-occupation still constitutes the majority of housing stock in both countries, and far above the EU average and as such serves as a deviation from housing models used across Europe.
However as (Norris, 2015) demonstrates the Irish experience of high levels of owner-occupation has been supported to reach what Norris terms a socialised housing system. Norris, 2015 points to the central role in which long-term, universal and large scale government investment had on shaping Irish owner-occupation, indeed Norris points to the flaws in an explanation of categorising Ireland as liberal with regards to housing, as the shape of the model wouldn’t fit with that categorisation. It is this scale and depth of governmental support that highlights the similarities between the Irish experience of owner-occupation and that which we can see in Norway.
Contemporary Owner-Occupation Policy
Indeed in recent years, we’ve seen far-reaching government proposals to tackle the challenges inherent within both the Norwegian and the Irish housing markets. In Norway this is covered under the Housing for Welfare National strategy for Housing and Support Services (2014-2020) (Kommunal- og moderniseringsdepartementet, 2014). This is a governmental strategy document that is much more targeted at assisting what it identifies as those who are disadvantaged within the current housing system.
The policy states the objective is that “150,000 people are regarded as disadvantaged in the housing market. Of these, around 6,200 have no permanent place to live. People who are unable to obtain a home themselves and stay there, will receive the necessary assistance. No one needs to earn or qualify for help” (Kommunal- og moderniseringsdepartementet, 2014). Through this we can see the universalist feature of Norwegian housing policy which has been a feature since the second world war is maintained in character, however when we look at an example of the policy interventions proposed we can see that the objective is much more targeted and in line with common European housing policy interventions.
The focus “on obtaining more rental housing with good design and in living environments that are suited for children, stimulating the private rental market to work better for disadvantaged in the housing market, ensuring more available and adapted information for young people concerning opportunities and rights associated with housing” (Kommunal- og moderniseringsdepartementet, 2014) point towards a greater focus on ensuring a well functioning private rental market and targeted policy interventions, and a move away from the policy framework of promoting home ownership as the dominant form of tenure.
This can be seen even in Husbank’s understanding of the government housing strategy that “From 2014 on The Government wanted The Start-up loan to go to people with long-term difficulties, rather than first time buyers who could obtain loans from private banks.” (Husbanken, 2018) This signals a broader move taking place in Norwegian policy towards housing, and which can be understood as comparable to the Irish experience from the 1980s onwards (Norris, 2015 Husbanken, 2018).
The focus on disadvantaged people within the housing market is a key tenant of the government’s housing strategy. The state has identified; Single people and low-income families, refugees, people with disabilities, people with mental disabilities, people with substance abuse issues and the long term homeless as disadvantaged groups. Whilst the figure of homeless has remained relatively stable since 1996 there has been a 69.75% increase in the number of homeless children (from 400 in 2008 to 679 in 2012). (Kommunal- og moderniseringsdepartementet, 2014).
How the Norwegian government aims to overcome these challenges is through a multi-departmental approach with Husbank, the state housing bank providing support to the municipalities to provide financial support to the disadvantaged (Kommunal- og moderniseringsdepartementet, 2014).
This targeting of policies rather than adopting a more universalist approach signals a key change in home ownership policy supports, with the Norwegian government also seeking to restrict private mortgages to limit the potential for a housing bubble, and with the state bank largely targeting its support to the disadvantaged in society, there is a lot of obstacles which face potential homeowners, which are contrary to the Norwegian experience post World War 2. A key trait of this new lending regimen is that it is required to have 25% deposit of the property value, unless for first time buyers under the age of 34 who may be permitted a minimum deposit of 15% of the value of the property (Finansdepartementet, 2019).
The deregulation with the Norwegian mortgage market as well as a similar move as that which is outlined in (Norris, 2015)’s analysis of the Irish experience of moving from a socialised to a marketised system can be seen taking place with the Norwegian system. We can see echoes of this in the types of policy interventions proposed within the Norwegian government housing strategy, many of which are targeted towards the disadvantaged and away from a universal accessibility, and with many potential owner-occupiers instead being reliant on private banks and financial institutions, an example of which can be seen below;
|Housing allowances||Housing allowances help the disadvantaged obtain and keep a home.|
|Social housing expertise grants.||Will contribute to increasing expertise on housing and support services and social housing policies|
|Grants for repurposing homes||Will contribute toward securing suitable homes for people with disabilities. The grant is financially means-tested.|
|First-home grants||Will contribute to the disadvantaged being able to purchase and keep their own home.|
|Start-up loans||This is a means-tested lending scheme for people with long-term housing and financing issues|
|Grants for social entrepreneurship||Will stimulate the development of social entrepreneurship aimed at combating poverty and social exclusion in Norway.|
We can see in the recent developments in Ireland, a similar policy path being utilised with notable exceptions, the recent development of the Rebuilding Ireland policy framework, and in particular the Rebuilding Ireland Home Loan, serves as an example of continued government support for targeted interventions to support owner-occupation, however there are a number of important points to note with this relatively subdued attempt to encourage home ownership in Ireland, and many of the trends taking place in Norway can similarly be seen in this policy (Rebuilding Ireland, 2019). There is a large volume of requirements, and the policy is tailored towards those who are not served by conventional mortgage associations due in part to the squeeze in access to credit.
However the policy is small in scale, and although there are favourable conditions there have been ongoing concerns with its rollout specifically regarding drawdowns (O’Halloran, 2019) and continued support/funding for the scheme (Byrne & Kenny, 2019).
This is similar in scope and objective to the Start-up loan which is provided through municipalities in Norway and with support from Husbanken, with the Rebuilding Ireland home loan being financed through the Housing Finance Agency.
In recent years we have begun to see both countries move towards a broad policy framework, which is more reliant on private financial institutions, that is more concerned with the rental market and in targeted policy interventions that seek to support those who may be disadvantaged within the housing market.
However, the macro policy requirements are comparable, with Norway under-producing the amount of housing units required (Eiendom Norge, 2019, International Monetary Fund, 2016), a problem which is comparable to the recent Irish experience (Central Statistics Office, n.d, Allied Irish Bank, 2019), alongside the removal or more precise targeting of owner-occupier supports to those who are not served by the private financial market (Sandlie & Gulbrandsen, 2017, Norris, M, 2015).
This move is part of a broader move which began in the 1980s with the incorporation of new public management reforms and the shrinking of the role of the state to build and supply housing units.
In the case of both countries we can also see the retreat from direct builds, and the diminishment of the role of tenant purchase taking place which leads to a more competitive homeowner market and with policy interventions in both countries in recent years that seek to curtail the effects of a housing bubble (borrowing limits, deposit requirements etc).
We can see that whilst the trend is downward, the outcome of greater reliance on the rental market may take a number of years to factor through. (Statistisk sentralbyrå, 2019, Central Statistics Office, n.d.)
Whilst the Irish experience has been one originally supported strongly through an agrarian focus (both countries have seen lower levels of owner occupation in urban environments as compared to rural). The early and wide-reaching support for the co-operative model in Norway has meant that headline owner-occupation figures in Norway are higher, but amongst individual owner-occupiers the rates remain comparable (at 70.6% in Norway and 69.5% in Ireland) in recent years