Empty Homes Agency Response

to DCLG Housing and Planning

Delivery Grant Consultation Paper

Principles of a new grant

Q1) Do you agree that these should be the principles of the
new grant?

We agree that the new grant should aim to incentivise local

authorities to respond to local housing demand and need as well as
reward efficient planning systems. However, we don’t think it would
be helpful to simply offer rewards for numbers of new homes
created. The need for housing differs from one part of the country to
another; indeed there are some housing markets in which there are
already too many houses. We also think it important that the reward
does not incentivise local authorities to facilitate housing
developments that are of poorer quality or have lower
environmental standards than are permitted under the current
planning arrangements.

In our view housing demand and need can be met in a number of

ways. The most important of which will clearly be building new
homes. However, in our view, making efficient use of the existing
housing stock including bringing empty properties back into housing
use can make a significant contribution to meeting housing demand
and need. We think it essential that grant should also be offered for
creating new homes from existing buildings even if no planning
permission is needed for such developments. The government made
the same point in their response to the Barker review: “The
Government believes that in addition to a step change in new
provision, it must also make effective use of existing stock. One way
of achieving this is to bring more empty property back to the
market. Bringing empty properties back into use has fewer
environmental impacts than building new homes as such properties
will also be located near to existing facilities and infrastructure.” The
Government’s Response to Kate Barker’s Review of Housing Supply
December 2005.
There are 290,000 long-term empty homes in England. Whilst it is
true that are many are in areas of housing oversupply there are also
many in areas of the country with the highest housing demand. For
example 25,700 in the Eastern Region, 32,600 in the South East of
England and 36,100 In London. There are in addition commercial
properties with the potential for creating over 400,000 homes lying
vacant. Bringing these properties into housing use increases the
supply of housing in the same way as building new homes. In our
experience communities find it hard to accept the need for building
new houses if they perceive there to be a problem with empty
property in the area. For practical as well as reasons of perception
we believe it is essential to make best use of the existing housing
stock before building more houses.

Other than providing new housing, reusing empty property has

many additional benefits to the community:

1. Regenerating existing neighbourhoods; empty property is

recognised by the police as magnets for petty crime such as
fly tipping, graffiti, and vandalism and even arson. A
Hometrack survey in 2003 reported that empty homes
devalue neighbouring properties by an average of 18%. These
problems can be reversed by bringing empty homes back into
use
2. Saving embodied energy: Research work carried out by the
Empty Homes Agency shows that creating a new home from
an empty house creates less then one sixth of the carbon
emissions of building a new house.
3. Increasing the viability of local services and businesses.
Bringing empty homes back into use brings new customers for
local services such as local shops and public transport into the
area. Unlike new housing developments where new services
often have to be provided, most empty homes are within
neighbourhoods already served by infrastructure. There is
therefore a double benefit; savings in providing new
infrastructure and a boost in customers for existing services.
4. Reducing the pressure on green field sites: Creating new
housing from existing buildings reduces the need to build as
many new houses. This should make it possible to build a
higher proportion of new houses on brownfield sites.

Given the additional benefits of bringing empty property into

housing use, we think it important that this source of housing supply
is prioritised over other sources. We support the proposal outlined in
David Kidney MP’s pamphlet “Redfield Sites” that a sequential
approach to providing new housing supply should be adopted, First
is it possible to provide housing from existing buildings, second is
there potential for using previously developed land and third only
after the potential of the first two sources have been exhausted
consider the greenfield sites. Whilst we accept that this proposal is
not government policy many aspects of it, such as a target for
brownfield site development and making use of empty homes to
meet housing supply, are.

We think that it is important that the Housing and Planning Delivery

Grant recognises these important areas of policy and incentivises
local authorities to prioritise housing from empty homes over other
methods. We would support Housing and Planning Delivery Grant
being offered to local authorities at a higher rate (perhaps double)
for new homes created out of long term empty properties.

Many local authorities are very effective at helping bring privately

owned empty property back into housing use. The introduction of
Empty Dwelling Management Orders has given local authorities a
new power to tackle empty homes and appears to have increased
the demand on them to effectively deal with this issue. Even so a
large number of local authorities do not in our view put sufficient
value on this area of work. In our experience many local authorities
do not make the strategic link between bringing empty properties
into housing use and providing new housing supply. We think that
the Housing and Planning delivery grant could be a very effective
tool in helping overcome this problem and increase housing supply

Potential beneficiaries of the grant

Q2) Do you agree with the proposed beneficiaries of the

grant?

Yes

Introducing a floor and performance improvement reward

Q3) Do you agree with the proposal to introduce a floor that

needs to be
reached before any incentive is granted? At what level
should a floor
be set?

Q4) Should the improvement element of the grant include a

separate
improvement fund or be stair cased? Are there any other
ways to
incentivise improvement?
We can see the rationale for introducing a floor that needs to be
reached before local authorities are rewarded. We think it is
important that local authorities are rewarded and incentivised to
facilitate additional housing supply rather than simply be rewarded
for what would have happened anyway.

If a floor is set we think that homes created from empty properties

should be excluded from it albeit with their own separate floor.
Facilitating empty homes brought back into use is a proactive
activity for local authorities, unlike planning which is largely
responsive. New homes form empty buildings are therefore likely to
be all additional housing supply, which would not have been made
available without the local authority’s intervention.

Rewarding stretching targets

Q5) Do you agree with the proposal to reward local

authorities that adopt challenging targets?

No, in our view the behaviour that should be rewarded is

responsiveness to market needs and demands. In some markets
increasing housing supply may be relatively easy for the local
authority and very much needed by the community. In others
increasing housing may be difficult but the need is lower. In these
situations rewarding the degree of difficulty may be
counterproductive.

Areas of high/low demand

Q6) Do you agree with the proposals for identifying which

authorities will be eligible to receive the grant?

We suggest an alternative approach to identifying which authorities

should receive grant. Set a threshold for the proportion of homes
that are abandoned. Crudely this can be measured by the
proportion of all homes that have been empty for more than 6
months. Areas that exceed the threshold should receive grant for
empty property brought back into housing use, but not for increased
housing delivery through new build housing. Areas below the
threshold should receive grant for both.

The rationale behind this approach is that the areas of country with
the greatest proportion of long-term empty homes are those with
lowest housing demand. There are of course long term empty
homes in areas of high housing demand, but not to the same degree
as where demand is lower and there is in-effect an oversupply of
housing

This approach would have two benefits. Firstly; we think it would

encourage local authorities with high numbers of empty homes to
tackle them before giving priority to new-build homes. This echoes
the sequential approach we outlined in response to question 1 of
this questionnaire. Secondly it won’t create a perverse incentive for
local authorities to encourage new housing developments where
there is already an oversupply of housing.

Measuring against Regional Spatial Strategy/Local Plan

numbers

Q7) Which approach do you prefer? Can you suggest an

alternative approach?

Measuring against Regional Spatial Strategy/Local Plan numbers.

Measuring performance and auditing the data

Q8) Do you agree with measuring delivery using a figure

based on three year rolling average of supply?

We agree, although we think that this should be phased in over the

first three years after the introduction of the grant. So that in the
first two years reward grant is paid for just the previous year’s
performance. If historic performance from prior to introduction of
the grant were taken into account it would be hard to demonstrate
that the grant has incentivised behaviour or caused any additional
housing supply to be provided.