Emma
Of course your particular case could just relate to the fact that your overall number of empties has gone up for the reasons stated in your other post about counting void properties as empty. (I'll comment on that one separately.)

Anyway I do completely agree with you. We - whether individually as EPOs or corporately as Local Authorities - should simply not accept responsibility for the overall number of empty propeties in our areas nor the trends. That doesn't mean we have no responsbility but as you have rightly said the extent of our influence has to be seen in proportion to things like:

• trends in the wider housing market
• how information is collected and reported by local authorities
• the behaviour of liable people in reporting the status of their properties

Given the relatively low numbers reported by most authorities for BVPI64, this is self-evident and common-sense. The suggestion that we are in a position to make such a difference that this would be the preponderant factor in determining the overall number of long-term empties is sheer fantasy. Where is the methodology to support such a view?

However, rather than whingeing, which we can sometimes be all too good at in local authorities, NAEPP needs to make a reasoned, polite but nevertheless firm approach to the Audit Commission pointing out that such a view is unsustainable and insisting that, if they want to promote such a view and make judgements on local authorities,they should supply justifications based on a clear methodology. So I think the next steps are

• to start to collect evidence that the Audit Commission are making unwarranted assumptions about the performance of local authorities based on the HSSA returns; and
• preparing a reasoned, evidence-based submission as to why such assumptions are unwarranted
• promoting the alternative view that LA's should be measured on whether or not they have an empty homes strategy that is coherent and evidence-based and whether they are implementing it

David Gibbens
Housing Enabling Manager, Exeter City Council

NAEPP submitted a detailed response to the Audit Commission consultation on Comprehensive Performance Assessment (CPA) for 2006. This response (see Library) identified many weaknesses in H18. After H18 was renewed for 2006 without change, NAEPP requested a meeting with the DCLG: to seek exclusion of certain categories of empty homes from the definition of empty homes for the Housing Strategy Statistical Appendix (HSSA)(and thus for H18).

DCLG'S reply (see Library) states that the more ambitious alternatives proposed by NAEPP are not workable. However the good news is that DCLG and the Audit Commission are preparing improved guidance on the HSSA, including categories to be excluded from the long term empty homes figure: and will consult NAEPP on these proposals.

Graham Everett