Dear NAEPP members

We are meeting CLG on the 17th September to discuss their proposals for collecting data about empty homes as part of the Housing Strategy Statistical Appendix.

This email is to get your feedback to inform our position at the meeting. We would be grateful if you would reply to this email and edit in your responses to the CLG questions (and some further questions of our own). Thanks in anticipation.

Section 1 - The Process

Were you aware that CLG were making these proposals before hearing about them in NAEPP newsletters?

YES/NO

 

Secton 2 - Specific CLG Proposals

(The following have been extracted word-for-word from the CLG proposals.

Please put after each one Agree or Disagree as appropriate.

If you Disagree it would be helpful if you would give your reasons.)

 

1 Drop ‘RSL’ and ‘other public sector’ dwellings from HSSA form

Why?

Data quality and duplication (RSL figures) and data not used (other public sector figures)

Agree / Disagree

 

2 Use CTB data to estimate total vacant dwellings

Why?

Most consistent data source across LAs

Agree / Disagree

 

3 Use RSR to estimate RSL long and short term vacant dwellings –

Why?

RSR data felt to be of better quality than HSSA figures.

Agree / Disagree

 

4 Use BPSA to derive LA vacant dwellings, but combine Q21-23 and Q24-26

Why?

BPSA gives long and short-term vacant dwelling split; combine some questions as more detailed split on length of vacancy not used.

Agree / Disagree

 

5 Use NROSH to complete RSL and LA vacancy figures when it reaches a high enough level of completion

Why?

Will reduce data burden on LAs in long-run.

Agree / Disagree

 

Secton 3 - NAEPP Proposals

The following are NAEPP draft proposals which we would expect to put to CLG

Activity Monitoring

We believe all local authorities should be required to monitor and report on their activity on empty homes. The Housing Strategy Statistical Appendix is the logical place to do that. We currently have the NAEPP Guidelines that give criteria for establishing what actions by local authorities should qualify for helping bring empty homes back into use.

 

The NAEPP proposal would be along the lines of local authorities being required to report on

a) all the empties they have brought back into use (including preventive action and transactional empties)

b) those properties that have been empty for more than x months

 

Our questions:

 

Do you agree with the basic principle of activity monitoring?

Agree / Disagree

 

Do you agree that stats collected about both (a) and (b) above are of value?

Agree / Disagree

 

What period of time should be used at (b) above to separate out success with long-term empties?

X months / years

 

(Note, if this proposal is successful BVPI64 Guidelines would then be reviewed and improved to ensure they are fit for purpose for this type of activity monitoring)

 

Second Homes

We think it essential that if second homes are to be excluded from the main count of empty homes (as at present) we should know how many properties are being excluded.

 

Realistically we think the simplest approach is to exclude furnished empty properties (ie second homes according to the Council Tax legislation)

BUT:

only such ones as have been empty for a certain period of time. We think that to exclude all furnished empties would clearly be to under-state the number of empty homes by ignoring those such as furnished lets between lettings. We are also aware of properties subject to EDMOs that have been furnished (eg in Lewisham).

 

This looks the best approach because:

• the data can be extracted automatically from the council tax base

• the methodology would be consistent across all local authorities whereas at the moment we know different authorities are using different criteria

• there would be a reaonable balance between counting and excluding furnished empties

 

Our Questions:

Do you agree with principle of reporting the number of second homes excluded from the count of empty homes?

Agree / Disagree

 

If this number is reported, do you agree that the most practical approach would be to derirve it automatically from council tax base figures?

Agree / Disagree

 

If this approach is used, what length of time do you think a furnished empty should be empty before it would count as a “second home”

X months

 

(Note Likely criteria would be 12 or 24 months).

 

Section 4 – Any other suggestions or comments

 

 

 

o0o

 

Thank you for your assistance.

 

David Gibbens for NAEPP Executive