New homes bonus consultation - post your views here
Submitted by admin on 12 November, 2010 - 13:44
We've added this in the monitoring and stats forum for the obvious reason that any payment will be entirely dependent on how local authority performance in this area is measured.
Submitted by TBriggs on 12 November, 2010 - 17:06.
I admit I've only skimmed it at this stage, but are they planning to use council tax data to calculate how many empties have been returned to use by the LA? I'm sure I don't have to tell anyone on this forum that that will not produce accurate results or demonstrate the involvement of the local authority in any meaningful way.
Surely we need to use something similar to the NAEPP guidelines to demonstrate an LA's actions.
If they are only going to pay on 'net' additions to the CT list, then 12 months worth of work bringing 20 problem long term empties into use could easily be wiped out because 20 (or more) properties become 'long term' empties - therefore what would be shown under BVPI64 or NAEPP guidelines as 20 successful interventions can just be cancelled out by the overall number of empties.
I can't see how this will benefit empty homes teams at all, but I'd be happy to be proved wrong.
The bonus will be based on the difference between the total number of long-term empties reported in one year's CTB (council tax) figures against the next year's. It effectively makes LAs responsible for the total number of private sector empties in your area. Your actual performance in returning homes to use doesn't come into it at all.
If the total number of LTEs goes down you will get a reward. So good rewards for data cleansing (identifying supposed empties that are actually occupied). For any given level of LTEs, you will not get a further reward unless you reduce the total further. So doing a good job keeping the situation under control will generate zero reward.
Of course, it does incentivise councils to support empty homes work because if the number is allowed to creep up then money will be lost from the new homes bonus that would otherwise have been earned on new homes delivered. So although you don't earn any more money for keeping LTE figures at a relatively low level, there are still big incentives for supporting empty homes work.
But I think it is wrong in principle to hold LAs responsible for the total state of the housing market in their area. It is a return to H18, H23 measures in the old CPA system.
The best bet for the purely money-oriented and cynical LA is to offer free furniture to all owners of LTEs to persuade them to register them as "second homes". The council then gets the bonus for reducing numbers of LTEs and keep the extra council tax on them for being second homes!
Submitted by CMillican on 23 November, 2010 - 11:51.
So if a Local Authority builds 400 new homes that qualify for the New Homes Bonus, but the Long Term Empties increase by 20 then the LA receives the NHB on 380 new homes?
Submitted by David Gibbens on 24 November, 2010 - 07:34.
Hi Carson - yes that's it. NHB is calculated on the net number of dwellings after deducting Long-Term Empties from total dwellings on the valuatoin list. So any change in the numberr of Long-Term Empties will affect the level of bonus.
Submitted by JRickman on 24 November, 2010 - 13:12.
David
Your last paragraph echos the thoughts I had after reading the document and seeing opportunities to maximise results. www.freecycle.co.uk
Supporting evidence of empty property brought back into use and occupied should be linked to this bonus programme to support and value Empty Property Officers work rather than quick win of cleansed database. Creating more second homes will continue to erode rural villages and make schools/shops vulnerable to closure. This will not help to sustain communities. Reclassification to second home will also protect owners from freedom of information requests by the pubic for lists of empty homes and perception of squatters.
Perhaps this Bonus scheme should incorporate how many second homes a person has particularly within a given area of their prime residence. Limit eligibility to one second home and classify others Long Term Empty. Ok this will see an increase in listed empty homes but may also be an effective strategy with incentives to bring back into occupied use and reduce the numbers on our housing register.
Submitted by Housinglc on 25 November, 2010 - 16:41.
I have only had time to have a quick read of everything, I will post a fuller response shortly
My own view that has been expressed by the others is that the system that is proposed is wide open to abuse by LA.
To be honest the LA could pay a Council Tax Officers to clean the data, encourage people to say that there is a single person in the property to stop it being classed as an empty home, holiday home issue etc
When we did a street walking survey in Kent, the consensus was that the CT data was between 15-25% out of date, in one LA this was as much as 30%.
While we all use the CT list as our starting point, it can swing massively from year to year and that's not on the basis of changing numbers but just on how Officers interpret the information.
If I was a cynical person, It could be suggested that the proposed system will cause LA to clean their CT list very well to obtain the maximum NHB, which will result in the Government being able to say that they have increased housing supply and reduced the number of long term empty properties overnight. The reality will be far from this.
Could I suggest an alternative approach in that the NHB is based on the actual numbers of empty properties brought back into use and the number of new properties being built.
These numbers can be verified and would be a true reflection of what is happening on the ground.
The NHB could be based on the number of years the property has been empty.
6 months LA gets 1 year CT
1 Year LA gets 2 year CT
2 year LA gets 3 year CT
10 years LA gets 11 Years CT
This would ensure and encourage LAs to tackle their very worst properties rather than deal with the easier properties that would probably come back into use under their own steam
And the NHB would be payable based on the output rather than left to the vagaries of the CT data.
So I open that upto the group as an alternative approach to what has been suggested.
Lastly, in this document you mention about the Class C discount, my own view is that this should be kept and should not be abolished.
While it may be considered as a "tax break", who benefits from it, people who are moving or selling their property and landlords between tenancies.
While the LA may be penalised under the NHB after 6 months + 1 day, the LA does benefit from full CT after this period.
I believe removing this Class C discount would unduly penalise those parties. I see little merit in the removal of the discount as I genuinely feel that it will not reduce the period a property is empty.
Also just a note to say thank you to David for the work he has done on this so far.
Regards
Andrew Lavender
Landlords want their property filled asap to obtain an income and people want to sell their property as soon as possible.
Submitted by Nick P-G on 16 November, 2010 - 11:19.
1. Abolish the 6 month Standard Empty discount. Owners then pay full charge and have no incentive to register an empty. With fewer Standard Empties to maturinginto LTEs, we'll see a net reduction. Then,
2. Write to remaining LTE owners advising that they pay full charge whether they are LTE or occupied, but that we will only work on LTE owners. Some LTE owners may re-register their home as occupied. A further net reduction arises.
This won't reduce the number of real long term empty homes, but will certainly reduce the number of Long Term Empty as registered with C Tax. And we won't be able to claim a reward. A perverse win-win thingy for CLG.
The house building lobby has been mauling Eric Pickle on other issues. Will they embrace idea of money being diverted from house-building to empty homes without a fight?
The lack of options on page 43's "Description of Options considered" is amply compensated by the very helpful lesson on smoking cessation.
Has anyone tried to run an Empty Home Owners "Big Lunch" yet?
Submitted by Luke Taylor on 22 November, 2010 - 11:19.
Our main thoughts when reading the document reflects those also discussed. For example when we decided to send leaflets to the bottom end of the list, those 6 months to 1 year empty there were 200. It had been 2 months since we had received the most recent CT list. We checked through this bottom 200 to check if any had come into use by themselves, and only 39 remained vacant. We would assume that there will have been new long term empties added to the list as well, but this just reflects how changeable and turbulent the bottom of the list can be. This may also be representative of time taken to sell with the current market conditions.
We would therefore propose that if this ‘total’ figure is used for monitoring the bonus that homes empty over 2 years may represent a better reflection of council involvement. However the best method of cause would be to use the monitoring guidelines set out by EHN.
Although any indication that reuse of empty homes will be recognised as additional stock can only be a step in the right direction.
Submitted by David Gibbens on 22 November, 2010 - 16:11.
Thanks for those thoughtful comments Luke. It's nice to see a plug for the EHN Guidelines which we all worked so hard on to arrive at a consensus.
There is a problem with focusing the NHB on long-term empties - particularly at the 2-years-empty level. The problem is that for many authorities the numbers we would be likely to return to use would be so low that the amount of money generated by the NHB would probably seem not to be worth the investment. Authorities with poor quality data might do quite well though - I gather in London loads of supposed long-term empties (including ones empty for over a year) prove to be occupied when the audit is done. I expect that pattern is repeated in many other areas, particularrly where the dscount has been removed completely.
If the interventions measured by the EHN Guidelines were used instead of the total number of empties we would face lots of issues around auditing, plus perverse incentives for workinig hardest on those homes that were going to come back into use anyway. You would set up a situation where the council could more or less offer to split the reward with the owner: so if the owner accepts some incentive from the council, the council can claim a success and claim the reward...
You would also have to work out a very different way of calculating the bonus. Under the NHB proposal, you only get 6 years bonus if you keep the home from reverting to being an LTE for 6 years (kind of ... you are actually looking across all the LTEs). If you measure interventions only, what is the level of reward? How do you relate it the ongoing position? You could relate the reward to how long the property was empty before being re-occupied and that has a nice feel to it - but it doesn't alter the fact that the home might have been coming back into use anyway and you are not necessarily rewarding the actual work put in by the local authority.
So with some reluctance I have come to the conclusion that maybe this IS the best measure available, for all its disadvantages.
Submitted by TBriggs on 23 November, 2010 - 10:08.
I share Luke's concerns in regard to the 'bottom' off the Council tax list. This figure can fluctuate and also be wildly inaccurate. I prepared a draft consultation response last week suggesting only LTE's over 12 months should be considered for the NHB. Hopefully that would still incentivise LA's but also reduce the impact of the housing market in the stats.
While we're discussing the detail though, I'm keen to emphasise that any recognition of empty homes work and a potential reward for LA's is a very welcome step.
David - is EHN preparing an official consultation response that we can have sight of before it's sent?
Council tax data
I admit I've only skimmed it at this stage, but are they planning to use council tax data to calculate how many empties have been returned to use by the LA? I'm sure I don't have to tell anyone on this forum that that will not produce accurate results or demonstrate the involvement of the local authority in any meaningful way.
Surely we need to use something similar to the NAEPP guidelines to demonstrate an LA's actions.
If they are only going to pay on 'net' additions to the CT list, then 12 months worth of work bringing 20 problem long term empties into use could easily be wiped out because 20 (or more) properties become 'long term' empties - therefore what would be shown under BVPI64 or NAEPP guidelines as 20 successful interventions can just be cancelled out by the overall number of empties.
I can't see how this will benefit empty homes teams at all, but I'd be happy to be proved wrong.
Based on total number of lt empties not LA performance
Tony - your interpretation is correct.
The bonus will be based on the difference between the total number of long-term empties reported in one year's CTB (council tax) figures against the next year's. It effectively makes LAs responsible for the total number of private sector empties in your area. Your actual performance in returning homes to use doesn't come into it at all.
If the total number of LTEs goes down you will get a reward. So good rewards for data cleansing (identifying supposed empties that are actually occupied). For any given level of LTEs, you will not get a further reward unless you reduce the total further. So doing a good job keeping the situation under control will generate zero reward.
Of course, it does incentivise councils to support empty homes work because if the number is allowed to creep up then money will be lost from the new homes bonus that would otherwise have been earned on new homes delivered. So although you don't earn any more money for keeping LTE figures at a relatively low level, there are still big incentives for supporting empty homes work.
But I think it is wrong in principle to hold LAs responsible for the total state of the housing market in their area. It is a return to H18, H23 measures in the old CPA system.
The best bet for the purely money-oriented and cynical LA is to offer free furniture to all owners of LTEs to persuade them to register them as "second homes". The council then gets the bonus for reducing numbers of LTEs and keep the extra council tax on them for being second homes!
David Gibbens (EHN Policy and Supoprt)
New |Homes Bonus
So if a Local Authority builds 400 new homes that qualify for the New Homes Bonus, but the Long Term Empties increase by 20 then the LA receives the NHB on 380 new homes?
Yes - new homes + change in LTEs
Hi Carson - yes that's it. NHB is calculated on the net number of dwellings after deducting Long-Term Empties from total dwellings on the valuatoin list. So any change in the numberr of Long-Term Empties will affect the level of bonus.
David Gibbens (EHN Policy and Support)
second homes
David
Your last paragraph echos the thoughts I had after reading the document and seeing opportunities to maximise results. www.freecycle.co.uk
Supporting evidence of empty property brought back into use and occupied should be linked to this bonus programme to support and value Empty Property Officers work rather than quick win of cleansed database. Creating more second homes will continue to erode rural villages and make schools/shops vulnerable to closure. This will not help to sustain communities. Reclassification to second home will also protect owners from freedom of information requests by the pubic for lists of empty homes and perception of squatters.
Perhaps this Bonus scheme should incorporate how many second homes a person has particularly within a given area of their prime residence. Limit eligibility to one second home and classify others Long Term Empty. Ok this will see an increase in listed empty homes but may also be an effective strategy with incentives to bring back into occupied use and reduce the numbers on our housing register.
Jo Rickman (Housing & Enabling Officer)
True Reflection of the Work or Manipulation of the CT Data?
I have only had time to have a quick read of everything, I will post a fuller response shortly
My own view that has been expressed by the others is that the system that is proposed is wide open to abuse by LA.
To be honest the LA could pay a Council Tax Officers to clean the data, encourage people to say that there is a single person in the property to stop it being classed as an empty home, holiday home issue etc
When we did a street walking survey in Kent, the consensus was that the CT data was between 15-25% out of date, in one LA this was as much as 30%.
While we all use the CT list as our starting point, it can swing massively from year to year and that's not on the basis of changing numbers but just on how Officers interpret the information.
If I was a cynical person, It could be suggested that the proposed system will cause LA to clean their CT list very well to obtain the maximum NHB, which will result in the Government being able to say that they have increased housing supply and reduced the number of long term empty properties overnight. The reality will be far from this.
Could I suggest an alternative approach in that the NHB is based on the actual numbers of empty properties brought back into use and the number of new properties being built.
These numbers can be verified and would be a true reflection of what is happening on the ground.
The NHB could be based on the number of years the property has been empty.
6 months LA gets 1 year CT
1 Year LA gets 2 year CT
2 year LA gets 3 year CT
10 years LA gets 11 Years CT
This would ensure and encourage LAs to tackle their very worst properties rather than deal with the easier properties that would probably come back into use under their own steam
And the NHB would be payable based on the output rather than left to the vagaries of the CT data.
So I open that upto the group as an alternative approach to what has been suggested.
Lastly, in this document you mention about the Class C discount, my own view is that this should be kept and should not be abolished.
While it may be considered as a "tax break", who benefits from it, people who are moving or selling their property and landlords between tenancies.
While the LA may be penalised under the NHB after 6 months + 1 day, the LA does benefit from full CT after this period.
I believe removing this Class C discount would unduly penalise those parties. I see little merit in the removal of the discount as I genuinely feel that it will not reduce the period a property is empty.
Also just a note to say thank you to David for the work he has done on this so far.
Regards
Andrew Lavender
Landlords want their property filled asap to obtain an income and people want to sell their property as soon as possible.
New Homes Bonus
1. Abolish the 6 month Standard Empty discount. Owners then pay full charge and have no incentive to register an empty. With fewer Standard Empties to maturinginto LTEs, we'll see a net reduction. Then,
2. Write to remaining LTE owners advising that they pay full charge whether they are LTE or occupied, but that we will only work on LTE owners. Some LTE owners may re-register their home as occupied. A further net reduction arises.
This won't reduce the number of real long term empty homes, but will certainly reduce the number of Long Term Empty as registered with C Tax. And we won't be able to claim a reward. A perverse win-win thingy for CLG.
The house building lobby has been mauling Eric Pickle on other issues. Will they embrace idea of money being diverted from house-building to empty homes without a fight?
The lack of options on page 43's "Description of Options considered" is amply compensated by the very helpful lesson on smoking cessation.
Has anyone tried to run an Empty Home Owners "Big Lunch" yet?
Nick P-G
Reading BC
01189373091
new homes bunus
Our main thoughts when reading the document reflects those also discussed. For example when we decided to send leaflets to the bottom end of the list, those 6 months to 1 year empty there were 200. It had been 2 months since we had received the most recent CT list. We checked through this bottom 200 to check if any had come into use by themselves, and only 39 remained vacant. We would assume that there will have been new long term empties added to the list as well, but this just reflects how changeable and turbulent the bottom of the list can be. This may also be representative of time taken to sell with the current market conditions.
We would therefore propose that if this ‘total’ figure is used for monitoring the bonus that homes empty over 2 years may represent a better reflection of council involvement. However the best method of cause would be to use the monitoring guidelines set out by EHN.
Although any indication that reuse of empty homes will be recognised as additional stock can only be a step in the right direction.
Thanks
Numbers will be relevant
Thanks for those thoughtful comments Luke. It's nice to see a plug for the EHN Guidelines which we all worked so hard on to arrive at a consensus.
There is a problem with focusing the NHB on long-term empties - particularly at the 2-years-empty level. The problem is that for many authorities the numbers we would be likely to return to use would be so low that the amount of money generated by the NHB would probably seem not to be worth the investment. Authorities with poor quality data might do quite well though - I gather in London loads of supposed long-term empties (including ones empty for over a year) prove to be occupied when the audit is done. I expect that pattern is repeated in many other areas, particularrly where the dscount has been removed completely.
If the interventions measured by the EHN Guidelines were used instead of the total number of empties we would face lots of issues around auditing, plus perverse incentives for workinig hardest on those homes that were going to come back into use anyway. You would set up a situation where the council could more or less offer to split the reward with the owner: so if the owner accepts some incentive from the council, the council can claim a success and claim the reward...
You would also have to work out a very different way of calculating the bonus. Under the NHB proposal, you only get 6 years bonus if you keep the home from reverting to being an LTE for 6 years (kind of ... you are actually looking across all the LTEs). If you measure interventions only, what is the level of reward? How do you relate it the ongoing position? You could relate the reward to how long the property was empty before being re-occupied and that has a nice feel to it - but it doesn't alter the fact that the home might have been coming back into use anyway and you are not necessarily rewarding the actual work put in by the local authority.
So with some reluctance I have come to the conclusion that maybe this IS the best measure available, for all its disadvantages.
David Gibbens (EHN Policy and Support)
six or twelve months empty?
I share Luke's concerns in regard to the 'bottom' off the Council tax list. This figure can fluctuate and also be wildly inaccurate. I prepared a draft consultation response last week suggesting only LTE's over 12 months should be considered for the NHB. Hopefully that would still incentivise LA's but also reduce the impact of the housing market in the stats.
While we're discussing the detail though, I'm keen to emphasise that any recognition of empty homes work and a potential reward for LA's is a very welcome step.
David - is EHN preparing an official consultation response that we can have sight of before it's sent?
Tony