It is surprising that noone has commented on a subject of such importance to Empty Property Officers.   Please comment now on the first draft response below.   Thank you.

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NAEPP will be responding separately on CLG’s other relevant current consultation:  Housing and Planning Delivery Grant – Consultation on allocation mechanism.   NAEPP notes the CLG statement in para 62 of that document that:

“We recognise the argument made by many respondents in the first consultation that bringing empty properties into housing use increases the supply of housing in the same way as building new homes.”

NAEPP is therefore surprised that the logic of this recognition is missing from the National Indicator (NI) proposals.   The two documents need to be consistent:  particularly as the Housing and Planning Delivery Grant document proposes using NI 154 for measuring net additions above 0.75% of existing stock for the Housing Element of Housing and Planning Delivery Grant.

NAEPP appreciates the Government’s desire to reduce the indicator burden on local authorities, and the weaknesses in Best Value Performance Indicator (BVPI) 64.   However NAEPP considers that NI 154 could be usefully adapted to reflect the logic of the CLG quotation above.

The NI 154 draft definition puts gains through change of use or conversion on a par with new build completions.   NAEPP proposes that long term unoccupied dwellings restored to occupation be similarly included in this formula.

NAEPP proposes that  long term unoccupied dwellings be defined as those unoccupied at least two years.   The benefits of this vacancy threshold would be:

• It would be consistent with the revised threshold (from January 2008) for the 5% VAT rate on works of renovation or alteration.
• Such a long period would eliminate any scope for misuse that the looser definition of BVPI 64 may have provided.
• Such a long vacancy would normally suggest a problem requiring a catalyst for change.   It would therefore be unnecessary to demonstrate that occupation had been as a direct result of local authority action.   (NAEPP notes that the draft formula does not require the local authority to demonstrate that it has caused any changes of use or conversions, other than by granting planning permission.)

I would like to see an extra NI but an adaptation of NI 154 is probably the best we could get. 

3.

Looking at a graph of how many Empty Homes (declared as such by their owner to Council Tax) there are in Luton against time, the decay curve indicates that it is after the 4 year point that Empty Homes appear much more likely to stay empty.  [However, I must admit that my feeble skills, when it comes to statistical analysis, cannot verify this significance.]  

4.

Regardless of my theory, I believe that we must take into account those people who complain about the condition of the property, especially the neighbours who are facing a drop in value of their property thanks to the Empty Home being next to them.  If we leave the definition of an Empty Home with too long a lead-in period, then we will be criticized for ignoring the property while it falls apart. 

I would propose that the minimum vacancy period should be 18 months - At this point I believe that we can still change the mind of those who are undecided about what to do with their Empty House.  If we leave it much longer than it appears that apathy sets in and it all becomes “too difficult” for the owner to act positively.

5.

There have been several occasions in the past where a home has become occupied but, probably out of spite, the owner will not acknowledge that it was my ‘encouragement’ that was significant in returning the property to the housing stock.  If I did not have to produce evidence that, on the balance of probabilities, it was my encouragement that was the cause of the change, then I could commit the “BVPI 64 sin” and claim any property that came back into use within a year or so of my sending the owner a letter!

6.

I agree that data reliability is a major factor here.  I know of an Empty Home that, even with bedroom windows smashed, still has the owner claiming that a single person occupies it…  If we try to remove error by extending the time before a property becomes an Empty Home, then we should not introduce doubt elsewhere.

7. 

I am also deluded enough to think that the 2 year vacancy period to qualify for 5% VAT should be reduced to 18 months and that a property’s VAT should be 0% after 4 years, perhaps even 3 years!  A month or so ago this would have been wishful thinking, but the current climate at the Treasury might mean that they acknowledge their error and correct it…  

Thank you for posting this.  On the whole I think it is excellent,  and the Empty Homes Agency will be saying very similar things.  The only exception is on the threshold, which we are convinced should be six months.

We understand there are good reasons not to like six months; we fully acknowledge the counting discrepancies and abuses around BPVPI 64 and the difficulties of 'proving' a local authority's agency in bring a property back into to use.

Admirably rigorous and principled though the views in favour of a year or more are, we think this is to misconstrue the Government's approach to measurement of housing performance, however.  DCLG is set on increasing the supply of housing.  That's it.  They are not detained by the delicacies of who is responsible and proving it.  The proposed arrangements for Housing and Planning Delivery Grant will not 'prove' LA agency in achieving higher housebuilding rates.  So we don't think we should impose a greater burden of proof on empty property work.

As the draft NAEPP response points out, six months is the threshold used for several aspects of empty homes work (not least the official definition of long-term).  That, ultimately, is why the EHA thinks it should be the period used for NI 154 and HPDG.