The NAEPP executive discussed this last week. I will prepare a response in time for the deadline of 21 December.
We concentrated on NI 154 (net additional homes provided), as NI 170 (previously developed land vacant or derelict over 5 years) measures the problem rather than the solution.
Opinion was divided over whether to propose an additional NI specifically on empty homes, or to propose adaptation of NI 154 to include empty homes activity. The latter view argued that CLG is very unlikely to agree any extra NIs, given its determination to have a drastically lower number than the number of BVPIs.
NI 154 as drafted includes changes of use and conversions, but not reoccupied vacant dwellings, when calculating net additional homes provided. It does not require the LA to show that its actions caused any changes of use or conversion.
If we propose that NI 154 also take account of reoccupied vacant dwellings, we should suggest a substantial vacancy period for qualifying properties: given the criticism of BVPI 64 resulting from its lack of a minimum vacancy period. One suggestion is 2 years, which would correspond to the new vacancy period qualifying for 5% VAT. Such a long vacancy period may also make it easier to assume LA responsibility without needing to prove it.
NI 154 as drafted deducts demolitions when calculating net additional homes. By the same logic an amended NI 154 should perhaps deduct dwellings which have become vacant over the stipulated vacancy period during the year in question. However the data reliability implications of doing that may make it unacceptable.
Please show in this forum before 3 December your views on these options:
Whether to propose an extra NI, or adaptation of NI 154.
If an extra NI, what it should be.
If adaptation of NI 154:
What minimum vacancy period.
Whether the LA should need to show that it caused the reoccupation.
Whether the calculation should deduct dwellings becoming vacant for the same period.