Graham

Thanks for very useful comments.  My thoughts are interpolated below.  Your numbering has got lost in the process and all your points are no.1, but I think it is clear enough what are your points and what are my responses.

1. Potentially confusing to have two documents (full and summary).   Perhaps preferable to have just the full document, with its reasoning located at the end of the document:  so as to make the guidelines themselves shorter.

I think you are right that we should get it down to one document but I would still  like to try and keep the rationale with the actual guidelines.  This might require some more sophisitcated formatting eg with the rationale in boxes.  Once you move the rationale somewhere else you have to duplicate the guidelines themselves for the rationale to make much sense.

1. The guidelines are significantly more complex than in the former BVPI64 Code of Guidance.   The alternative would be to continue the guidelines in the former BVPI64 Code of Guidance:  subject to necessary changes like the six categories and the changed definition of dwelling.

There is some additional complexity and there is more clarification and amplification I feel.  Areas where addtional complexity is inevitable is around the 6 categories, that for example then require guidelines around how you allocate the original empty dwellings to the re-occupation categories when there are conversions.

Some addtional scenarios have been addressed and I think this is useful progress; and also some more prescriptive criteria have been introduced to help sort out when pressure by the EPO might be considered to be effective (or not).

Then further attention has been given to matters not previously addressed but they are real and this is the golden opportuity to deal with them.  The two key ones were:

• the issue about local  authority interventions being effective within a reasonable period of time.  This was to disallow scenarios where local authorities (or their agents) take control of properties and then don't actually do anything about them for long periods  of time.  To count these when finally something is done has the potential to undermine the credibility of the statistics and I believe is a real scenario in some places eg cpo followed by inaction.
• the other was about the role of partners and trying to define where action by partners could reasonably count as resulting from local  authority interventions

I am happy to discuss either of these if there is a view that these refinements are unnecessary. They certainly do introduce some  rather abstract discussion around chains of cause-and-effect etc which ideally we could do without.

Fundamentally,  though, these ARE the same guidelines. I sat down with old ones expecting to be able to amend them in  an hour or so, but they were more wrapped up in the old PI than I had thought.  This is what came out: the old ones with new categories - as agreed; new rules related to those categories - essential; some more specific exclusions and inclusions - ie refinement; and some other general considerations which maybe we can reduce as you are indicating.

1. An example of complexity potentially causing confusion:  para 51 (full document) may appear to contradict paras 39 & 50.

To be honest I don't think it is fair to call this complexity, it is just intended to be a clarification where perhaps I have failed to make things clearer.  51 is supposed to distinguish a situation where the local authority liaises with a landlord to bring a property into a rent and deposit guarantee scheme (allowable under 39 and 50 as you rightly say) and one where it is the tenant who has found the property and wants to live in it and simply approaches the local  authority for financial support eg via eg rent-in-advance which I thought should be disallowed.  But I do agree that these situations can blur into one another.  What we can't do however is sweep these distinctions under the carpet - we do badly need to provide guidance, whilst I admit I don't pretend to know exactly where the line should be drawn.  As there is some considerable opposition to allowing rent-and-deposit scenarios to be counted as successes,I felt the line needed to be tighter than previously.  One for  further  discussion I feel.  I accept it might be better to reduce apparent complexity by putting 51 in the list of "special cases".

1. The exclusion of RSL properties may make it harder to achieve widespread acceptance of these guidelines.

We had previously agreed - about 4 years ago - to exclude RSL properties but were not allowed to do so during the life-time of BVPI64 because it was considered too big a change by CLG.  There are huge numbers of ways  in which local authorities can be invovled  in lets of vacant RSL homes and I think it needs this simple radical move - ie no relets - as the only way to exclude all sorts of things that could otherwise be counted.

If you allow RSL properties to be treated as normal private sector empties then an authority that has done an LSVT might claim all sorts of "successes" where an adjacent authority doing exactly the same sort of thing with its own stock could not.  It would be (and has been) a major loophole to include RSL properties and a source of distortion.  Let social housing be regulated and monitored by social housing routes such as housing inspections and the like.

If authorities do want to count such work, then they can do so via local statistical measures or PIs.

1. Para 39 of full document:  fifth bullet point should also mention LA loan-funding

Yes - I will  add a bullet point for loan-funding.

More comments please!

David Gibbens Housing Enabling Manager, Exeter City Council