Since producing the above, I've revised the last couple of paras further to emphasis that, although tying HPDG to the existence of an empty homes strategy is likely to be a good incentive to LAs to develop their empty homes work, this assumption needs to be reality tested. 

I also suggested that NAEPP might help CLG develep a specimen Job Description for an Empty Homes Officer and added a criterion for an effective empty homes strategy that someone be dedicated at least 3 days a week to empty homes work on a continuing basis. Finally, I indicated that empty homes work should be given higher profile in the Inspection regime.  Here are the final 2 paras which are probably most sensitive.  Though I fear everyone has now gone home! 

16      The consultation document indicates that there would be problems trying to quantify the contribution of empty homes towards housing delivery.  We agree that caution is required and that the over-riding imperative should be to ensure the existence of effective empty homes initiatives in all local authority areas.  

17      We think it probable that the incentive offered by the Housing Delivery element of  HPDG will be sufficient in most authorities to offset the impact of abolishing the national empty homes performance indicators (and indeed may provide a much better incentive than those indicators).  But this is only true if most authorities would be likely to benefit from the Housing Delivery element of HPDG and would thus stand to lose funding if they did not have an effective Empty Homes Strategy in place.  CLG should model the likely distribution of the Housing Delivery Grant to satisfy themselves that the Housing Delivery Grant criterion will provide adequate leverage.   Otherwise it should take further steps as a matter of urgency to ensure that empty property work is adequately recognised and encouraged.  It also needs to think about the position at the end of the 3-year HPDG programme.

David Gibbens Housing Enabling Manager, Exeter City Council