HPDG Consultation - NAEPP Response (Final)
Since producing the 2nd draft, 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 appreciate the concerns that people have about the abolition of the indicators but I am not clear that everyone realises what a powerful incentive the CLG "empty homes strategy" criterion is likely to be.
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!
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HPDG Consultation Response v3
Perhaps I am too cynical by now to believe that writing a strategy, because without a big stick to enforce it, it is unlikely to work at Local Authorities where it is not wanted. OK so I am bitter and twisted, but when the CLG encouraged the use of HALS, the DWP was able to scotch the idea by not funding it. Similarly, unless you have someone to ‘champion’ the strategy at Director or Councillor level, you may find that you have an Empty Homes post for three days a week but that it lacks the resources to back it.
However, there is little point in being a Luddite. BVPI 64 is a battle (strategic withdrawal?) that has been lost. To win the war we need to make sure that the Empty Homes strategies are robust, fit for purpose and are backed up with necessary resources to enable them to work.
Performance and stuff
Not hugely disagreeing with you Philip, but your comment sparked a number of thoughts. As you are probably aware, I don't regard the demise of BVPI64 as a defeat or strategic withdrawal but as a victory for common sense.
I do feel that people haven't really taken on board what powerful leverage the HPDG criterion might be. Nor I feel have people recognised how ineffective BVPI64 was. I appreciate that some people are definite that their jobs depended on BVPI64 but across the South West forum I cannot think there could be more than a couple in that position at best.
Across the SW, areas that wanted empty homes strategies had them before BVPI64 came along, and BVPI64 doesn't seem to have made any noticeable difference to the numbers of Empty Homes Officers. All the issues that you raise about lack of resources were not effectively addressed by the existence of BVPI64 as far as I can see.
However, a criterion that you have an effective empty homes strategy before you are eligible to claim possibly hundreds of thousands of pounds in Housing Delivery Grant does look like a pretty good incentive. If at senior level you try and create a sham Empty Homes Initiative just to qualify for grant, that would be a heck of a gamble, don't you think? So I believe we should support this measure whole-heartedly and recognise it as the best fillip to empty homes initiatives at local level that there has ever been.
If they would adopt our proposal for topslicing some money to fund empty homes initiatives that would be even better, because it would incentivise those authorities who aren't going to get Housing Delivery Grant anyway (and we don't know how many of those there are - I am hoping only a small number).
And finally, regarding "improvements" to BVPI64 I do think we should be clear that performance on long-term empties is always going to vary significantly from area to area and that the impact of local authority work, relative to the extent of the problem, is going to be limited except in the most favourable circumstances. Unfortunately I would say that that is truer today than ever, even with EDMOs available to us, because we have less opportunity to intervene via housing association schemes because of pressure on grant and changes in the housing market.
That's leaving aside the thorny issue about what can genuinely be counted as effective local authority intervention. One of the downsides of competing with one another in the BVPI64 game is that everyone gets sucked into playing the numbers game. I found the spectacle of grown adults running around asking "can I count this? can I count that?", in order to please Sir, a bit embarrassing.
In reality, a lot of the time you simply don't know and never will know what difference your intervention really had. You can make any assumptions you want, but at the end of the day a lot is speculation. This applies particularly to the issue about whether the property "would" have come back into use, which is certainly a fair and apprporiate question to ask.
Moving the threshold from 6 months to a year or even two years doesn't really address that issue. Properties that are empty for a year or two years or longer also come back into use through the natural operation of the market and the fact that the LA gets involved in that process doesn't automatically tell you what would have happened if they hadn't been involved any more than it does with properties empty for only 6 months. Most (not all) of the time we would be kidding ourselves if we believe that they were truly lost to the housing stock just because they were empty for a year or two years. In reality, a property that has been empty for two years but has now been sold and has a bulder doing it up is not really a problem empty any more; whereas a property that has been empty for 3 months because the owner has moved abroad and doesn't want to let it is already a problem empty.
As an empty homes officer I think you know which are the properties that really were languishing long-term and where your intervention has genuinely made a difference, when you become aware of all the circumstances of the case. They are really satisfying ones to tackle. But also the hardest. And in the large majority of authorities surely annual numbers of succesful interventions in those extreme cases would be small to zero unless you are demolishing them by the dozen - or have lots of them round to start with, which very many authorities do not.
Meanwhile though your average empty homes initiative continues to produce results in the form of private sector renewal (improvements to properties) and sourcing properties for those in housing need, which after all is where most of the moral imperative for empty homes work comes from. Let's not undervalue that.
But yes you are absolutely right that it is hard to get an initiative to achieve much if it is not backed up - but having an EHO in post makes it more likely that resources will come forwards as they can champion the strategy within the authority. If the work is left to others such as Environmental Health managers, they may be the very people who do not want to put resources into empty homes strategies because they have other priorities. So I think we are right to emphasise the role of the Empty Homes Officer (without in any way wishing to denigrate the very large number of private sector environmental health officers and housing enabling officers who do a good job running their local empty homes initiative).
Here endeth the rant. I do have real work to do, honest.
David Gibbens Housing Enabling Manager, Exeter City Council
HPDG Consultation
PS on last two paras
Sorry, I didn't include the last two paras, as stated but they are of course in the attachment.
David Gibbens Housing Enabling Manager, Exeter City Council