Doing it yourself is hardly unusual in Britain, from home improvement to punk music. But we’re markedly less used to building our own homes than the rest of Europ, despite that predilection for tackling our interiors ourselves. Self-build represents a far smaller proportion of house construction in the UK (about 10 per cent) than in most of Europe (over 50 per cent) or the USA (around 45 per cent).

This isn’t some nebulous trait specific only to us quirky exceptional Brits. After all, we have a history of doing it here: many Georgian, Victorian villas, and most thatched cottages were self-built. Bath’s iconic Royal Crescent was custom-built. One architect designed the frontages, whilst each owner got other architects to design the home behind the façade.

There’s no lack of demand, either. Ipsos MORI has shown that one in seven Britons expect to look into building their own home, a figure of around 7m. Additionally, people are hardly head over heels in love with the housing offered mainly by larger house builders. New builds are not popular with more than twice as many people preferring an older home (49 per cent) to a new build home (19 per cent).

But it’s hard to do. The National Self-Build Association cite the “the availability of land”. The Joseph Rowntree Foundation, the DCLG Select Committee and others agree.

But we at Create Streets think it is a bit more than that and not quite so simple. After all, the amount of land in every country doesn’t change (apart from the Netherlands where they will keep reclaiming it from the sea). And whilst Britain is crowded compared to most, many regions aren’t and both Belgium and the Netherlands have more people per square kilometre.

Where Britain does differ is in the rather odd way we do our planning. It is crucial to understand that in historic and comparative terms we have a very curious approach to permitting (or refusing) development. Other than a few ‘permitted developments’ there is no right for the landowner to develop their own land – unlike, for example, Germany where there is a constitutional right to do so.

Local Plans are also much weaker. They are policy documents not regulatory documents, which influence but do not control what can and cannot be built – and, as you probably know, viability tests can be (and are) used to ignore them.

Finally, the primary permission that is needed to build something is a planning permission unlike the rest of Europe (other than Ireland) where a building permit is the main sign off you need, checking that you comply with the (more powerful) local plan. There, the right to develop is regulated, very often with greater clarity about what is permissible.

This matters because the higher level of theoretical control and lower level of permitted clarity increases planning risk. This poses a major barrier to entry to self-builders, smaller developers and other third sector developers.

It is no accident that the UK has consistently had a more concentrated development sector, with a systemically lower proportion of self-build and SMEs than most countries. Britain has a planning system in which each new site is contested.

The politics is ‘downstream’ not ‘upstream’. This means nobody is quite sure what will end up being built on any site. This alarms and motivates NIMBYs. But it also isn’t good for anyone who wants to build on land, including self-builders.

More planning risk is, in relative terms, good for larger housebuilders, however. With their huge resources they are better able to take those risks. And they push it further – they overpay for land, knowing they can use the argument of viability to make sure they can cut corners on affordability and appearance, or build higher than the council and communities want (sometimes at greater densities than research suggests is beneficial to wellbeing). Smaller groups or individuals, the kinds that might be interested in self-building, can’t get a look in.

In fact this should not be a surprise. The 1947 planning settlement was in part designed to make it hard for ‘selfish and anti-social’ self-builders (known in the 1930s as ‘plotlanders’) to build homes on plots they had bought.

There are numerous case studies from abroad that could form the blueprint for a British approach to self-build housing. They include the German ‘Baugruppe’ model, Japan’s factory-built model and the USA’s ‘stick home’ model. But these all rely on greater clarity for the self-builder on what is, and is not, acceptable so as to control ‘planning risk’.

The best known example of such a policy is probably Almere, a Dutch city that is re-discovering self-build housing. The city designated a zone of rural land and drew up a design code with rules on construction, irrigation, agriculture and even road connections.

Within this framework, individuals who purchased a plot were totally free to develop their own plot of land to their own specifications and needs. This is not small-scale or tokenistic, but a significant part of the growth of the fifth largest Dutch city.

Of course it is possible to custom-build (i.e. self-build at scale) within the current system. But it takes a lot of work from a council and developer. In Almere ,individuals can purchase a plot designated by the local authority. When they have a mortgage, the buyer is at liberty to customise their home from a wide variety of different “ready-made” homes, many designed by in-house architects all of which are deliverable in Almere.

Developr Igloo’s self-build site in Heartlands, Cornwall, uses six designs, each of which is by a different architectural practice. Purchasers can choose from these six, as well as a tailored approach to internal layouts and finishes. However despite all the work that council and developer have put in there is, still a need to apply for planning permission on a plot by plot basis. Pre-approval has got to become much easier.

What we need is some predictability. There are steps in the right direction, such as the requirement in the new Draft London Plan for councils to create Design Codes for small sites. These can help give the certainty that allows self-builders to get hold of the land needed to get (self)building. The new draft National Planning Policy Framework has also supported more design codes and offered consultation on permitted development. Good. We are getting there. But it is slow work.

Self-build can work in the UK today. But it is not as easy as it should be. Throwing money at the problem won’t resolve it. We need to give greater clarity to self builders (and SMEs) about what they can and cannot build – just as they have in most of Europe and much of the US. Without that supporting self-build is just pushing water up hill.

Kieran Toms is a researcher and urban designer at Create streets.