FRANCE HAS A national mandate that all cities include 25% social housing in their building plans, while California lawmakers are struggling to push local governments to build their fair share of affordable units. France has built over 1 million units in the past 25 years. California has produced half that much.
What does France do differently that has made it a leader in European housing? A conversation comparing the urban planning of France and California took place this month at the San Francisco Bay Area Planning and Urban Research Association. It was led by French urban planner Magda Maaoui, who is now an assistant professor at Harvard University’s Graduate School of Design.
France and California are comparable in terms of land mass and population. Sixty percent of people in France own their own households, comparable to 56% in California, and most of the homes in both places are single-family units.
French citizens earn considerably less money than Californians, with a median household income of about $30,000 compared to $90,000 in California. Yet most French citizens enjoy a fairly good quality of life, eating buttered baguettes in diverse middle-class neighborhoods.
California’s statewide planning and zoning law was expanded in 2022 and established a goal to build 2.5 million new homes by 2030. No less than 1 million of those homes had to meet the needs of lower-income households.
“California has the largest homeless population of any state,” said California Attorney General Rob Bonta at a press event last April in Oakland, advocating for stiffer penalties against jurisdictions that don’t comply with the state housing element law.

“More than half of families who rent their homes spend more than a third of their income on rent. Two hundred and ten cities across the state of California have a median home price over $1 million,” Bonta said.
“Forty-three percent of renters live in social housing in France,” said Maaoui, adding that number constitutes 17% of all households. “We’re not talking about just the lowest income categories. This is social housing for everybody — firefighters, teachers, nurses, you name it. A huge part of the population is eligible for social housing. It’s not a social status disqualifying thing.”
Meeting in the middle
France’s large middle class also lessens the social friction between the haves and have nots. There are more mixed-income neighborhoods.
France has 4.5 million social housing units, which come in three categories.
The lowest income category of social housing accounts for about 50%. These developments look like the kind of mid-20th century housing projects we might see in the U.S., Maaoui said. The next category of residents is still low-income but starts to tip into middle income. They constitute about a quarter of the population in social housing. The last quarter may be people who are just priced out of market rate housing, like young families with kids, who are not upper-middle income but doing OK.
“I also think it’s a matter of just having public infrastructure and public land available for housing to be provided,” Maaoui said.
France has a land bank program where the state acquires land at a cheaper price to offer low-cost regional investment opportunities to developers. The land banks are multi-jurisdictional, not subscribed within territorial limits, but span borders.

“You can have less of a NIMBY effect,” she said, referring to homeowners taking a not-in-my-backyard attitude of resistance. “You can wield more power. We’ve been able to do a lot of interesting work at a regional level or even an intermunicipal level. Thinking of housing as only one element of public infrastructure, private capital gets channeled through these projects.”
According to Maaoui, in France, 52% of new affordable units are produced through public-private partnerships through a state program. In the U.S., she said, one out of a thousand developers will undertake an affordable housing project.
Maaoui cautioned that France is far from perfect. There are many high-income French cities that push back against building affordable homes. She said French mayors have different powers than in the U.S.
“We have mayors that pass laws to try to ban construction trucks from entering the city,” she said.
She traced it back to the French Revolution in 1789, when France was broken down from one big kingdom, with no equality or citizen input, to about 36,000 municipalities. Decade after decade, the mayoral administrations were given authority to decide what gets built.
“Seventy-one percent of the municipalities that are non-compliant have a mayoral administration that’s from the right or the extreme right,” she said. “This is not a French tale of the all-powerful state mandating local municipalities, it’s really a never-ending battle.”
Leveraging social housing
She told a story about one mayor whose city had a lower-class immigrant population. It sat in the way of the construction of the 2024 Olympics aquatics center and transportation corridor. The mayor used that leverage to demand a large social housing development and won a 36-acre “eco district,” an environmentally sustainable public-private development with nearly 2,000 housing units, 25% set aside for the lowest-income households, including community gardens and a swimming center.
“The mayor has the prerogative; they are the person that decides what gets built and how it gets built. And that’s the nature of urbanism in France,” said Maaoui.
A private partner injected capital, she said, and the mayor shaped the project the way she wanted it.
In addition to the national mandate for 25% social housing, Maaoui said mayors, like Paris’s Anne Hidalgo, have found pockets for infill developments and adaptive reuse of older buildings.
“The mayor has the prerogative; they are the person that decides what gets built and how it gets built. And that’s the nature of urbanism in France.” Magda Maaoui, Harvard Graduate School of Design
One example was 12 rue Jean-Bart, Paris, a converted police station that was turned into an affordable housing development. It was converted quietly, slipped between market rate apartments. It was done through a public-private partnership where the developer had limited agency in what could be built.
“Hidalgo was not scared of exclusionary districts pushing back against any type of housing development,” Maaoui said. “I think that’s key to why it was Paris set a goal of reaching 32% social housing by 2030 and 40% by 2035, in a city more built-up than San Francisco and as dense as Calcutta.”
She said affordable housing does not have to be a huge masterplan development, it can work at the scale of a tiny street, conversions of offices, or acquisitors of private market units.
“It was really knitting or weaving work, street by street and building by building,” she said.
Maaoui said French people trust of the government more, even in times of crisis. Fellow panelist and planner Alex Schafran, who used to live in France said trust is a big factor.
“The French may hate each other, but they don’t hate the state. They fight for control of the state. In America, the right wing hates the government. The French can hate immigrants, they hate poor people. There is a lot of hate, but they want the state, and they want it to deliver things,” Schafran said.
He remembered in rural communities, where the government is at the most local level, representatives just showed up and did things their constituents wanted. It felt productive.
“They are facing similar problems, gentrification and people fighting over housing. So, we’re really in the same trouble,” he said. “But at the same time, there is trust.”
