Memorandum by the Chartered Institute
of Housing (CIH) (EMP 11)
1. INTRODUCTION
The Chartered Institute of Housing (CIH) is
the only professional body for individuals working in housing.
Its primary aim is to maximise the contribution that housing professionals
make to the well-being of communities. Membership status is dependent
on completion of a professional qualification and a track record
of professional achievement.
CIH has over 18,000 individual members working
for local authorities, housing associations, Government bodies,
educational establishments and the private sector. Many of our
members are engaged in day-to-day work which centres on the causes,
consequences and remedy of empty homes and low demand.
CIH welcomes this inquiry and the opportunity
it provides for a deeper investigation into the progress made
in addressing empty homes and low demand, and the need for future
strategy, action, and investment.
2. SUMMARY
We acknowledge the positive steps that the Government
has taken to address empty homes and low demand in some areas
of the country primarily through the nine Pathfinders. If problems
of current and future low demand are to be addressed effectively,
a national strategy for market restructuring is required.
Our main points for consideration include:
— Development of a National Strategy
for Housing Market Restructuring which incorporates support for
areas outside the nine Pathfinders.
— More balanced funding between renewal
and new supply.
— Publication of a report on government
progress to reduce its own stock of empty properties.
— Circulation of a timetable for disseminating
good practice emerging from the pathfinders.
— Publication of a good practice guide
for use of Compulsory Purchase Orders by local authorities.
— Assessment of whether CPO powers
can be effectively applied to tackle obsolescence.
— Resources to pump prime a national
equity release scheme.
— More effective administration of
compensation for demolition.
— Further integration of strategies
at local and regional level, including the RES, RSS, and RHS.
3(a) The scope and scale of the initiatives
proposed and underway in the Government's Housing Market Renewal
Pathfinder areas and other areas with problems of empty homes.
3.1 The creation of the nine Market Renewal
Pathfinders initiated by the Sustainable Communities Plan was
necessary and timely. The Pathfinders have brought significant
funding and targeted action to some areas of the North and Midlands
most damaged by housing market collapse and abandonment. Taking
a long-term strategic and cross tenure approach to the problem
across wide areas, rather than quick fixes, is definitely what
was required and positive outcomes are anticipated.
3.2 The scope and scale of initiatives outside
of the nine Pathfinders is, however, under-resourced, too limited,
and lacks strategic direction. The problem of empty homes due
to low demand is experienced beyond the nine Pathfinders, and
is not limited to large urban areas in the North and Midlands.
The Communities Plan specified that the nine Pathfinders cover
only 50% of the dwellings at risk of market dysfunction and community
abandonment. This means that local authorities and housing providers
with the remaining 50% of low demand properties in their jurisdiction
have no specific national strategy or comprehensive funding mechanism
to tackle the problems.
3.3 Whilst the work of the Pathfinders should
help to develop techniques and strategies for addressing the problems
in these remaining areas, action to prevent further decline in
non-Pathfinder areas is needed now. Regional Housing Boards have
begun to tackle this as identified in Regional Housing Strategies
but need a funding mechanism. To achieve this aim, a National
Strategy for Housing Market Restructuring (covered in more depth
in 5.1) should be developed.
4(b) The commitment and contribution of all
Government departments and other agencies to tackling the underlying
causes of empty homes.
4.1 The Communities Plan, Neighbourhood
Renewal Strategy, Decent Homes Target and increased funding pledged
by ODPM in the Spending Review 2004 all show a clear commitment
to intervention to tackle the underlying causes of empty homes.
4.2 However, there is a definite tension
between the recognition of the need to tackle empty homes and
the Government emphasis on the increased housing supply required
in the south. Whilst the creation and funding of Market Renewal
Pathfinders does show commitment, the £500 million available
falls far short of the total required to turn around the problem.
Initial proposals by local authorities for these nine pathfinders
envisaged a total expenditure of £8 billion over a number
of years. Clearly, low demand must continue as a Government priority
alongside increasing housing supply, if the remaining is to be
forthcoming in future years.
4.3 The recent empty homes figures seem
to provide proof that Government departments are taking action
to reduce their own empty properties such as those owned by the
NHS and MoD. A report on how this reduction has been achieved
would be welcome, to show whether the land/properties have been
used to meet aspects of local/national housing strategy, or whether
they have been sold to the highest bidder for development.
4.4 Whilst the Home Office community cohesion
agenda has been linked with housing, and joint work with ODPM
was underway in 2004, its focus outside Pathfinder areas has been
on using social housing lettings to prevent segregation. Some
emphasis should also be given to how public funds are invested
in private housing.
4.5 Departments responsible for economic
growth must also make sure that such growth happens beyond the
wider South East in order to ensure work to restructure housing
markets is not fatally undermined.
5(c) The availability of resources outside
the Pathfinder areas and the development of strategies to deal
with weak housing markets
5.1 Resources such as NRF or New Deal funding
can help to tackle problems such as poor educational attainment
or drug abuse which are often present in low demand areas, but
they do not have a strategic focus on weak housing markets.
5.2 The joint CIH and NHF submission to
the Spending Review 2004[2]outlined
our bid for a National Strategy for Housing Market Restructuring,
supported by additional funding to Regional Housing Boards (£350
million) to enable non-Pathfinder areas to tackle current or potential
low demand. The Spending Review commitment to provide additional
funding and expand the Pathfinder approach to other areas suffering
low demand is welcome but does not go far enough. Regional Housing
Boards have in some areas supported the development of new Housing
Market Renewal approaches outside the Pathfinders (eg Black Country
& Telford) but lack the scale resources required.
5.3 England still needs a national strategy
which works on a continuum of need (thus allowing preventative
as well as reactive programmes) and allows a range of interventions
to be applied in different ways to suit local market forces: it
must be supported by ring-fenced funding, effective delivery vehicles,
links to wider spatial strategies and the planning system, and
could give a key administrative role to the Regional Housing Boards.
Such a strategy would:
— enable Government to meet its own
policy targets (eg PSA5);
— provide a policy and funding framework
for housing in mixed tenure areas;
— provide a framework for community
cohesion, sustainability and regeneration in areas of privately
owned and rented homes;
— link housing with physical/social
and economic regeneration; and
— complement other regeneration and
renewal initiatives eg Objective 2, NRF.
6(d) The dissemination of good practice,
innovation and co-ordinated interventions within and outside Pathfinder
areas
6.1 Good practice is currently shared between
Pathfinders through both informal networks and formal arrangements
such as structured workshops or the Pathfinder policy working
group. At present it does not seem that good practice and innovation
developed by Pathfinders is being widely disseminated beyond the
Pathfinders. Whilst Pathfinders may not have been in operation
for long enough to have evidence which proves the effectiveness
of certain approaches, it would be helpful if a timetable for
publication or delivery of any good practice/innovation output
could be made available. CIH is well positioned to assist in the
further development and dissemination of good practice, and would
welcome the opportunity to work with ODPM and the existing Pathfinders
to do so.
6.2 Many Pathfinders have had to embrace
the previously discredited tool of stock clearance. Whilst staff
in these areas are becoming more knowledgeable about the use of
Compulsory Purchase Orders, other local authorities still lack
confidence and expertise in this area. The ODPM guidance on CPOs
is very long and technical, and a good practice guide in the style
of CIH Empty Homes good practice guide could be very useful to
local authority officers. We are currently working towards developing
such a guide.
7(e) Whether Councils have sufficient powers
to tackle the problem of empty homes in their areas
7.1 Where properties are empty due to poor management
or physical standards, councils do have a good range of powers
available to them. These powers are supplemented by an increasing
amount of good practice developed by councils.
7.2 The introduction of Empty Homes Management
Orders through the Housing Act 2004 could be a useful tool to
reduce empty homes. It seems unlikely that many councils will
actually take over management of empty properties because of the
administrative and financial burden and probable lack of skills
in housing departments which no longer manage their own stock.
Councils which choose to apply EHMOs may benefit from a partnership
with a local RSL which could undertake management and maintenance
functions on their behalf. The possibility of being served with
an EHMO may spur landlords into bringing their properties back
into use, but to make best use of the orders, councils must back
them up with an effective guidance and advice service and link
them to grant/loan giving departments.
7.3 The power to use Compulsory Purchase
Orders is also welcome where local authorities have been unable
to get cooperation from landlords. Whilst these have been used
effectively by some authorities, application is a complicated,
lengthy process, and so many authorities would benefit from increased
guidance and support in using CPOs. The location of CP powers
in different pieces of legislation, with no specific reference
to use for obsolescence/market renewal, means that authorities
must seek best fit within existing provisions which relate to
health and wellbeing. ODPM, in its response to the select committee
report on the draft housing bill (July 2003), stated that it would
consider whether the range of uses for CPOs was sufficient. The
experiences of the Pathfinders in using CPOs should feed into
such an assessment and lead to legislative changes if necessary.
7.4 Private landlord forums, accreditation
schemes, and Housing Association Leases can be put to effective
use by councils to tackle empty homes without recourse to statutory
methods. Notable good practice is the Newcastle Private Rented
Project which shows innovation in using partnership working and
available funding sources to tackle low demand.
7.5 Where poor local conditions (eg crime,
joblessness, poor facilities) are causing low demand, councils
must act strategically to tackle overall deprivation—a housing
centred approach will not be successful. Councils are now more
accustomed to creating strategic partnerships which can pool powers
and resources to tackle poor health, low employment, high crime,
poor education etc but this must be a long term approach and is
unlikely to have an immediate impact on empty properties. Some
regeneration areas have found that properties are kept empty in
anticipation of a profitable sale when prices increase over the
life of the regeneration project: use of powers and good practice
to reduce empty homes should be applied in such circumstances.
7.6 Where properties are empty due to market
failure, councils outside of Pathfinder areas are unlikely to
have access to the resources or expertise needed to tackle the
problem. This is further evidence that a National Strategy for
Market Renewal is required.
8(f) The priority given to the demolition
of homes and the consideration given to effective methods of refurbishment
8.1 The legacy of demolition projects pursued
in the 1950s has made residents and regeneration staff wary of
revisiting mass stock clearance. Outside of Pathfinder areas,
elected council members keen to preserve their political position
are often reluctant to endorse clearance schemes. Within Pathfinders,
recognition of the role of well planned and executed demolition
schemes has grown amongst officers and members, and new approaches
to planning, consulting, managing, and funding clearance are being
developed.
8.2 Demolition programmes must be implemented
well if they are to gain public support and achieve their aims.
To avoid the mistakes of the 1950s, schemes must be run efficiently;
financial packages available to residents must be appropriate;
and residents must have access to information and sensitive support
around their rehousing options. They must also be involved in
delivering these programmes.
8.3 Implementation of demolition programmes
has shown that owner-occupiers can suffer from lack of information
and insufficient financial compensation. In North Staffordshire
Pathfinder, owners whose houses are scheduled for demolition are
only entitled to relocation compensation if they move to approved
"sustainable" areas where property prices are inevitably
higher[3]For
many this can mean leaving behind family and community connections,
and not having sufficient resources to purchase a replacement
property. Access to mortgages is obviously limited by age and
income, which means these problems are worse for older, economically
inactive, or low income households. Those who find themselves
unable to remain in owner-occupation not only lose the benefits
of future property equity but may also find it difficult to access
social housing due to long waiting lists. Some households have
also complained that they were not able to get information from
local councils about areas they could move to in time to make
an informed decision. This indicates that processes need to be
tightened up and further consideration of varying personal circumstances
given.
8.4 Demolition is not necessarily the most
appropriate tool, even in low demand areas. More resources are
required to support innovation in refurbishment schemes. Equity
release schemes are a good tool, but have been slow to become
established, eg the West Midlands Regional Housing Board has piloted
Kick Start, a property appreciation/equity release approach across
seven local authorities. Additional resources are required to
pump prime such schemes and act as an incentive to owners of run
down property. The removal of VAT from refurbishment work should
also help to make refurbishment a more cost effective option.
9(g) The availability of the necessary skills
and training to support staff promoting projects to tackle the
needs of areas with weak housing markets
9.1 We are aware that, even at a senior
level, staff working in areas with weak housing markets often
have to feel their way in tackling the problems in their area
and that different projects sometimes reinvent the wheel because
of difficulties experienced in sharing good practice. This links
to point 6.1 above.
9.2 CIH and BURA will be running a Regeneration
Masterclass in the autumn, which will consist of three two-day
residential workshops. The aim is to help senior regeneration
professionals from the public and private sector to maximise knowledge,
understanding and communication at all levels between the many
and diverse organisations involved in the planning and delivery
of such projects. A report will be produced after the Masterclass
which will help regeneration professionals to build their skills
and knowledge.
10(h) How housing market renewal is addressed
in other strategies including local and regional plans and other
regeneration programmes
10.1 CIH research[4]shows
that a lack of co-ordination between economic and infrastructure
decisions, housing investment and planning policy has perpetuated
the problem of unbalanced housing markets. Whilst housing market
renewal has become more central to national objectives, strategic
approaches do not yet necessarily take the integrated approach
which is needed.
10.2 At a regional level, further integration
of strategies is needed, but is hampered because responsibility
for economic, housing and spatial strategies is split between
Regional Development Agencies and Assemblies. CIH advice notes
for Regional Housing Boards[5]gave
some guidance on how this should be achieved.
10.3 Further work to develop the scope and
capacity of local authority housing strategies is also required.
The growing regional agenda and the separation of local authorities'
landlord and strategic functions means that local authorities'
strategic role is changing. These changes may make it difficult
for local authorities to know how to address housing market renewal
in their strategies—it is beyond the traditional strategy
work many have done before, and is increasingly driven by regional
priorities. Many authorities do not integrate public and private
sector when designing and implementing housing strategies, and
similar problems can be observed with a lack of integration between
housing and planning matters. CIH is currently undertaking some
work on the future of local authorities' strategic role, based
on Nick Raynsford's Vision for Local Government.
10.4 The future implementation of proposals
in the Treasury consultation "Devolving Decision Making"
gives cause for concern. The consultation outlines the intention
to include funding for Market Renewal Pathfinders in regional
allocations, but also sets out proposals to enable Regional Assemblies
to prioritise between housing, transport, and economic policy
areas. In strategic terms, considering housing, transport, and
the economy together should be very beneficial. However, the example
given in the consultation (1.20) suggests that funding for housing
could be kept very low for a number of years, when housing practice
shows that consistent action and investment is necessary. Competition
between the three sectors could develop, and make fund allocation
into a bidding process. Additionally, successful regeneration
often requires housing, transport and the economy to be addressed
simultaneously—regional decisions made to prioritise, say,
housing over transport could potentially prevent this from happening.
2 http://www.cih.org/policy/NSHMR.pdf Back
3
http://www.renewnorthstaffs.gov.uk/documents/12-Assistance%20policy%20120304.pdf
p 14. Back
4
http://www.cih.org/policy/IntelligentApproaches.pdf Back
5
http://www.cih.org/policy/regionalagenda.pdf Back
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