Memorandum from CIH (DAR 09-10)
INTRODUCTION
CIH is a membership organisation with extensive
reach across all English regions, covering rural and urban communities,
and every local authority area. We have a membership base of 20,000
individuals and every year we provide professional training and
services to a total of 30,000 housing sector professionals.
We are unique in housing in that we have a "domain"
approach to our work—reaching out not just to a particular
sector, but to everyone who works in or is involved with housing,
communities and regeneration. This includes housing associations,
local authorities, ALMOs, private sector landlords, umbrella organisations,
tenants' organisations, academics, funders, developers and members
of the wider third sector (for example refugee community organisations,
housing advice centres, credit unions, BME community organisations
etc).
We are also clear in recognising that housing
does not exist in isolation and so are committed to supporting
our members in developing neighbourhood and community activities
beyond their core landlord or development functions. In this we
see real synergy with CLG's remit around housing and local government
and its place in the wider sustainable communities/place-making
agenda. In looking at the department's strategic objectives we
are clear that CIH is well placed to support CLG in making contributions
across DS01, DS02, DS03, DS04 and DS05.
We believe that these factors—together
with and our established expertise, sector-wide reach and track-record
(particularly in relation to dissemination) mean that we have
been particularly well placed to support Communities and Local
Government as a strategically operating partner in relation to
its housing objectives.
CIH VIEWS OF
COMMUNITIES AND
LOCAL GOVERNMENT
The Committee has asked for CIH's views on the
"institutional capability" of the department. In particular
it has asked for our perspective on a number of questions:
3. Is its policy formulation sound and evidence-based?
4. Does it deliver what it says it will deliver?
5. How influential is it within, and outside,
Government, when pressing the claims of its main stakeholders,
and its own policy agenda?
Our response is framed around these questions
and we welcome this exercise by the Communities and Local Government
select committee. We are clear that as well as enquiring about
stakeholder views that the Committee should be open to ideas about
how links with partners could be further improved. Accordingly,
we also put forward some suggestions as to how we believe CIH's
relationship with the department could move to a more strategic
footing.
OVERALL VIEW
The CIH has a positive and productive relationship
with Communities and Local Government. We work closely with the
department at all levels, from Ministers through senior and junior
civil servants, through seconded specialisists and project teams,
as well as their sponsored agencies.
Our relationship is well established and we believe
both organisations are proactive in looking for opportunities
to collaborate to improve the delivery of shared housing ambitions
across communities.
Commenting on the department at this time has
to consider the unique challenges presented by unprecedented external
environment. We would note that the current financial and housing
turmoil appears to have placed significant pressures on CLG. It
has been noticeable that staff have been moved from existing work
to deliver new emergency programmes (the range of mortgage rescue
activities, the Housing Pledge). This is in addition to an important
and ongoing core programme (local government reform, an ambitious
housing development programme anchored in the 2007 Housing Green
Paper, planning reforms, and significant institutional change
internally and externally with the creation of the TSA, HCA, IPC,
NTV).
The re-prioritisation of department resources
(both capital and staffing) is not unwelcome, reflecting as it
does decisions that are being made across the economy to respond
to troubling times. However it has meant that there has been a
period of unusual fluidity. This has impacted on continuity of
some work. Perhaps most notable for CIH has been the shift of
focus from what we believe are some fundamental and important
long term questions (such as rental housing reform and the "parking"
of the green paper on this) to more immediate responses. While
we recognise that resources need to be best allocated, the long
term vision should not be lost. In this, chopping and changing
of priorities within the department has had an impact externally—as
people contributing their ideas and time to specific areas of
work see their contributions marginalised (albeit understanding
the wider pressures).
Perhaps most notable has been the revolving
door of Ministers. Delivering a coherent programme of work and
policy in these times would be difficult enough with strong leadership
and direction, let alone with frequent changes to the Secretary
of State and their ministers of state. Each new minister takes
time to get up to speed with existing priorities and also brings
with them fresh thinking. Despite the professionalism of the civil
service this would appear to consume senior officials time and
energy in a way that could be more productively employed.
The movement of the department to a more strategic,
policy-focused footing is welcome. With the creation of the HCA
(and TSA to a lesser extent) it has been clear that CLG has looked
to create strong delivery bodies to take forward the government
priorities it shapes and7 articulates. The policy-delivery split
is however one that always blurs. Those delivering on the ground
(with significant resources) are often well placed to pick up
on key issues and wish to be more responsive and progressive in
their thinking. The department finds itself increasingly reliant
on its delivery bodies for this information and evidence. It is
important that a strong relationship between the department and
its institutions is in place so that these energies and ideas
are developed mutually and with a strong sense of openness and
transparency. The framework created by the Housing and Regeneration
act is relatively embryonic but drawing on the strengths of the
respective organisations to improve policy making should remain
a priority going forwards.
Our final general observation would be that
at times the department remains locked in to some particular silos—notably
those working on local government and those focusing on housing.
This has been most noticeable to CIH in discussions around issues
that affect both local government and housing—such as the
Housing Revenue Account reforms and the domain regulation order
(extending social housing regulation by the Tenant Services Authority
to local authorities). Different positions within the department
have taken time to reconcile, at times impacting detrimentally
on the speedy progress of important decisions—again arguably
exacerbated by Ministerial movement.
SPECIFIC QUESTIONS
1. How good is the Department at consulting
its main stakeholders on policy issues?
While we cant comment on the department's links
with other stakeholders, we believe that CLG is good at consulting
with CIH. In addition to the opportunities to respond to formal
consultation documents (which are clearly and proactively signposted
to us as an organisation), we also have strong relationships,
which enable us to support the development of thinking during
the policy process. This can take the form of involvement in project
boards or steering groups alongside other sector organisations
or activities that focus on what CIH can offer directly. For example,
CLG is active in looking for CIH to facilitate access to frontline
professionals and practitioners to support and test ideas. We
believe this is an important contribution to the development of
a sound evidence base, and practically implementable policy and
practice.
2. Does it take reasonable account of responses
to consultation?
The department does appear to have a culture of openness
and a willingness to listen to new ideas and respond positively
to criticism. We believe on the back of this that they do take
in to account responses to their ideas. One area of improvement
however would be stronger feedback on ideas that are not supported.
3. Is its policy formulation sound and evidence-based?
Our experience of working with CLG suggests
that the department works hard to develop a sound evidence base
for its policy formulation. In recent years it has made extensive
use of external expertise to bring increased robustness to this
process. For example, the Hills and Cave reviews. As an organisation
we have welcomed their focus and commitment to seeking the views
of front line practitioners to support and compliment their statistical
analysis. As noted earlier, with the increased separation of
some previously internal or delivery functions to organisations
like the HCA, NHPAU and TSA close working relationships with these
bodies (who have greater specialised knowledge and immediacy of
operational aspects of policy delivery) will be key to maintaining
and strengthening this facet of the department's work.
4. Does it deliver what it says it will deliver?
CLG generally does a good job of delivering
on its commitments. There have been some instances where work
has changed midstream (for example the work on third sector partnerships
or the rented housing reform green paper). In this it is important
to distinguish between political drivers, which may mean a direction
changes (the green paper) and what would appear to be departmental
decisions (the third sector work). Ministerial changes have become
something that the sector has unfortunately had to accommodate
and get used in recent years and does not reflect on the department
in particular. Where the department pulls a piece of work after
time and energy has been committed by stakeholders this is obviously
frustrating. Our experience has however been that this is the
exception rather than the norm.
5. How influential is it within, and outside,
Government, when pressing the claims of its main stakeholders,
and its own policy agenda?
In recent years a number of key housing pieces
of work have involved a number of departments beyond CLG. While
it is difficult to comment on the impact that CLG has with colleagues
across Whitehall there are a couple of observations that provide
insight in to CIH's perspective on this.
First, there was the positive news from the Housing
Pledge that funding was coming in to CLG from other parts of Whitehall.
This reflects well on the department in attracting (scarce) public
funding to housing as a government priority. Obviously, what is
not clear from this is how much of this was informed by CLG work
and how much was a simple political/cabinet decision and therefore
in effect little directly to do with the department per se.
Second, we have been involved in work involving
other departments where CLG has had little direct notable presence
despite that work being fundamentally important to the wider housing
portfolio (for example DWP reform working on housing benefit).
Again, it is also not clear what links were established outside
of our knowledge as a stakeholder (one would hope that these were
strong).
Third, on the recent issues of housing association
rents (the deflation question) and HRA reform (moving to self
financing and distributing debt), it would appear that important
discussions with HMT around key financial issues have not progressed
in the manner that those involved in housing would have hoped.
Finally, for many people working in the housing
profession we remain frustrated with the lack of joined up thinking
around the role that housing (and in particular social housing
providers) can play in supporting the realisation of other key
government ambitions. We continue to largely think around housing
as linked to "housing" PSA and LAA targets rather than
fully exploring at both the national and local level the impact
that housing can have on other key areas such as health and education.
THE CIH-CLG RELATIONSHIP
CIH has strong, well-established communications
systems for engaging with our constituency base and in this we
have been particularly well placed to work with CLG.
We can disseminate information about relevant issues
both through our existing resources and through bespoke instruments
as required. We also use these bespoke in-house systems to reach
out to our constituency base to seek their views to help shape
our contribution to CLG's policy priorities.
— CIH's weekly e-news is read by 20,000
members (and more than twice this many people unofficially as
a result of it being forwarded by members) and is acknowledged
as the "must read" housing email bulletin by practitioners—mixing
up-to-date information about policy developments, advice about
best practice and events and opportunities to feedback on latest
thinking and consultations.
— Housing Practice, our bi-monthly glossy
insert in Inside Housing has a wide reach and provides a key route
for informing our membership around current issues.
— Housing magazine is published every two
months and is an in-depth publication that reaches both practitioners
and key decision makers—it is also distributed via Inside
Housing.
— Our internet site and membership portal
also provide comprehensive information and services to members
and non-members alike.
— We use "expert" groups to debate
particular topics—sometimes at policy lunches and sometimes
in a "virtual" way via e-mail.
— Our "Moodle" website-based
discussion forums allow individuals to debate and share information
across the sector and for example was successfully used to support
CIH's debates around the John Hills' Review
— In addition to paper and electronic communications,
the CIH also runs its annual conference at Harrogate, widely acknowledged
as the housing event of the year (with the Secretary of State
or Housing Minister traditionally speaking and 10,000 participants
attending during the week). This conference is highly valued by
housing professionals across the sector and is used by CIH to
disseminate and discuss new ideas and good practice ideas.
— We also run a suite of extremely successful
regional events and conferences throughout the year—organised
by our regional committee network of senior officers and practitioners.
— We also run events on particular themes—such
as the "Lettings and Homelessness" Conference, the national
Leaseholders conference, as well as one off events on topical
areas of interest (eg: the future of regulation, the changing
role of local authorities in housing) etc.
— Our comprehensive national education
and training work is the cornerstone of much of CIH's activities.
It provides a direct link into the ongoing professional development
of the sector—from Board members, Chief Executives and Directors
through housing officers and neighbourhood wardens. Work ranges
from open access courses on specific issues such as housing law,
our provision and maintenance of the definitive on-line Housing
Manual, through specialist workshops on environmental sustainability,
to our regeneration master-classes and leadership development
programme (run with Warwick University 's Business School.
— We run the annual "Oscars"
for housing—the UK Housing Awards—which enables us
to collect hundreds of examples of the latest good practice and
promote new ideas across the whole sector.
— Finally, CIH is also the majority owner
of "HouseMark"—the well respected benchmarking
and performance improvement organisation that supports the dissemination
of good practice and promotes continuous improvement.
All of these resources provide a two-way flow
of information—enabling the CIH to not only help inform
the sector but also to consult widely on particular policy and
practice initiatives. It is our unique ability to undertake this
two-way exchange of ideas and information that is the cornerstone
of our relationship with the department. We see ourselves as having
a partnership role in both contributing to policy development
and to policy implementation.
A STRATEGIC PARTNERSHIP?
While our existing relationship with CLG is
positive,—particularly in relation to policy development
and events—we would be supportive of a more strategic partnership.
There is scope to develop an even more comprehensive way of working
with the department. This could be achieved in a number of ways
including the following:
— Looking at our publication suite (in
particular "Housing" magazine) we would offer
scope for features, interviews, in-depth articles etc in these
from CLG ministers and officials on topical issues.
— Similarly, we could support CLG in ensuring
that news around latest announcements, consultations and developments
is promoted through these in order to reach as wide a possible
audience.
— We also believe that a closer strategic
relationship would be mutually beneficial in supporting the swift
and effective translation of CLG policy into practice through
our seminar, education and training programmes. This would help
to improve the sector's effectiveness not just in the short term,
but also over a longer time frame by contributing to its overall
capacity building. Much of this work now involves using an "e-learning",
"action learning" or "communities of practice"
approach—encouraging practitioners to support one another
to learn in an on-going rather than one-off way—using web-based
discussion forums and visits as well as more traditional forms
of learning.
— Finally, we would like to build on the
strength of recent working to run bespoke local, regional and
national stakeholder events with the department on particularly
topical issues. We would hope to be able to support the department
in moving away from traditional consultation exercises which can
focus overwhelmingly on problems, to an approach that emphasises
solutions. Such workshops can be organised in a number of different
ways depending on needs. In some cases we have organised "policy
lunch" discussions where CLG officials have "observed"
discussions without contributing directly. The added value CIH
offers in running such events is firstly our ability to bring
together people from across the sector and secondly our ability
to use our policy knowledge to pull together the contributions
made into coherent messages and ideas.
WORKING WITH
LOCAL PEOPLE
CIH is fully committed to the department's commitment
to engaging local people in setting and delivering local priorities.
We work closely with tenants and residents and their representative
organisations to ensure that our work is shaped by the people
using and affected by services. For example, our work on resident-led
self inspection has been at the forefront of new thinking around
community empowerment and we have been proactive in our support
of Community Land Trusts—a community ownership model supported
in the Quirk Review. In addition, our "Active Learning for
Residents" programme is ground-breaking in accrediting the
learning undertaken by tenants and residents as part of their
engagement in housing and community projects.
In this we also believe that our relationship also
provides CLG with an opportunity to be active in meeting its obligations
under the Third Sector Compact.
ADVOCATE IN
POLICY DESIGN,
DEVELOPMENT AND
IMPLEMENTATION
One of the key roles of CIH is its policy and
practice function—indeed we exist to help housing professionals
provide the best services they can to their customers. This enables
us to act as a key advocate for our constituency, providing a
well evidenced, respected and influential voice in our dealings
with CLG and other key stakeholders.
This is a role that we have developed over a
number of years. It is supported by a strong communications infrastructure
(as outlined above) that enables us to not only provide up-to-date
information outwards, but also allows us to work with our constituency
to gather their views and represent them at the highest level.
It also enables us to facilitate access for the department to
an extensive range of practitioners—from operational specialists
in fields like supported housing, through to the most senior tiers
of management and leadership—across the public and private
sectors.
CIH has been at the forefront of housing policy
and practice thinking for many years and we are already established
as an important departmental stakeholder on housing issues. It
was CIH that first called for a decent homes standard and target,
we worked closely with ODPM on the Communities Plan development
and we have been supportive of the departments recent policy thinking
around new housing and existing communities.
The CIH has been involved in many of the key
steering groups shaping this work helping to provide a strong,
independent sectoral-wide voice to both support and challenge
departmental thinking. CIH has worked with the department on the
housing and regeneration review, Martin Cave's review of social
housing regulation, John Hill's work on the role and purpose of
social housing, the LA self-financing pilots, PPS3 reforms, Digital
Switchover, current work on local housing strategies, the Leading
Places of Change initiative, the housing and regeneration act,
the HRA review, the recent Housing Pledge and many other specific
policy initiatives. Many of these have involved policy in development
and we are well versed in the importance of maintaining confidentiality
during (and indeed after) this process.
Our involvement with CLG is multi-faceted. It
encompasses supporting the department with policy design and development,
as well as using our skills and expertise in improving delivery
and implementation. Where we have been involved in improving practice,
we have a strong track-record of success, with feedback from the
department recognising the impact and value that CIH is able to
realise.
UNDER A
MORE STRATEGIC
APPROACH
We do, however, believe that, as part of a more
strategic approach to partnership there is scope to do more:
— We will look to continue to provide the
voice of the CIH on key groups and committees on specific issues.
— We will look to draw on a wider membership
base to bring senior specialists to working groups (for example,
local authority performance specialists on to the HRA working
groups).
— As noted above, we are well placed to
run tailored events for CLG on specific national policy initiatives
in order to support and improve consultation with the sector.
— We would also look to provide greater
access to existing national, regional and local platforms for
CLG to engage with sector.
— We would also look to draw on our overseas
networks to support CLG in accessing innovative ideas and practice
from the international housing community.
IMPROVING OUR
WAY OF
WORKING
We believe this area provides the most significant
scope to capitalise on the existing strengths of the CIH-CLG relationship
and we welcome the openness of CLG's thinking in wishing to develop
its own capacity as well as more openly engage with constituents.
There are a number of areas where we believe
the CIH could support CLG's ambitions.
— Membership of CIH for CLG housing staff—membership
conveys a wide range of benefits, including exclusive access to
online resource materials.
— We could also work with CLG to establish
housing-based personal development plans for individuals who wanted
to develop their housing knowledge.
— Access to the CIH on-line Practice Online
for all staff.
— CIH runs around 60 one and two day events
each year on specific subjects and topics. We would be pleased
to offer CLG access to these.
— In-house training. We could also offer
in-house training for CLG staff.
— Consultation Events. We would be willing
to run tailored quarterly consultation events for the department.
As noted, we would want to focus these events on positive outcomes
and targeting high level participants.
— We would host online discussion forums
(with password access for agreed individuals) that would provide
CLG with secure access to key practitioners.
— We also offer to work with CLG in identifying
and securing secondment opportunities both for sectoral specialists
coming in to the department (mirroring the success of the Homelessness
special advisors), and for department staff seeking to spend time
in the sector.
Richard Capie
Director of Policy and Practice
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