The Empty Homes Community Grants Fund was officially launched by Andrew Stunell on 24th January. The consultancy
Tribal has been selected as the third party organisation to manage the programme day-to-day. They will be processing the grant applications. Applications are to be received by
Tribal by 17th April 2012 (no time of day is stated).
We have placed a link to the Bidding Guidance in our library
here.
Criteria
There are no surprises in CLG's bidding guidance: most of the text is lifted word-for-word from the HCA bidding guidance on its own part of the £100million empty homes programme. The same criteria are used around length-of-time empty, standards to be achieved and so on. However, the absence of the HCA as a controlling presence might allow interpretations to be more liberal.
For example, within the HCA programme the strict connection to the Affordable Rent regime is clearly enforceable. Within the Community Grants Fund, the requirement is that the housing is affordable using the criteria laid down in Planning Policy Statement 3. Those criteria were amended to include Affordable Rents (ie 80% of market rents) but continue to include Intermediate housing which is:
Housing at prices and rents above those of social rent, but below market price or rents
This could include homes let at, say, 90% of market rents.
Similarly, where both sets of guidance say that, for leased properties, they "expect the minimum lease length will be five years", Tribal are likely to have more freedom to decide what to do if their expectations are not met.
Eligibilty of organisations
This programme is for a wide range of community organisations but there is a requirement for, among things,
- Constitution or memorandum and articles of association
- Fully signed audited accounts
- Original bank statement
This would make it hard for "start-up" organisations to bid and can be thought of as a departure from the model adopted in the HCA's main programme which allowed organisations to become Registered Providers after any money had been allocated. If empty homes practitioners are working with groups in the hpoe that this programme will catalyse the formal creation of a new community organisation they may well be disappointed. It remains to be seen whether this is a strict requirement - it is not stated as such.
Revolving Funding?
The new programme continues to seek the impossible by encouraging applications for revolving funds whilst expecting to assess the value-for-money on the first property.
Bids may include proposals to create or contribute to a revolving fund for the reinvestment of funding in delivering further properties as loans are re-paid.
In assessing value for money, we will take account of the first property brought back into use for the funding requested.
On a revolving fund the value for money should be assessed on the total quantum of housing delivered which might be split over several properties as the money is recycled. Conversely, if the value for money is assessed on the first property, you would not expect it to be good value for money if the amount of grant was actually intended to be spread across further properties over a longer period of time. We will write to CLG/Tribal/HCA on this point.
Tribal
We cannot say that the appointment of Tribal to manage the programme is a surprise but nor could it have been predicted. From their website it is apparent that their main focus has been education (which is of course relevant to the "skills and training" aspect of the Community Grants Fund).
The involvement of a new organisation with new ways of working in the empty homes world is an exciting prospect. Tribal hasthe opportunity, by supporting the community organisations that bid, to support the development of some really innovative approaches. We wish Tribal the best of luck and will do whatever we can do to ease their entry into the empty homes world and make their involvement as productive as possible for all concerned.
One issue that must arise is the duration of CLG's contract with Tribal. The HCA is to all intents and purposes a permanent body. When the HCA superseded the Housing Corporation, the legislation had to accomodate the transfer of functions from one to the other. This is relevant to important matters such as the disposal of grant-funded assets by housing associations: this remains under control of the HCA and is, rightly, ubject to a great deal of regulation . It will be interesitng to find out how the on-going control of assets is to be managed in this new programme where the contract is with Tribal. What longer-term controls will exist over homes that have received public fundinig via this programme?
It will also be interesting to find out whether any money has been allocated to Tribal for capacity-building or analysis. For example the Emtpty Homes Network has been calling consistently for a systematic and transparent analysis of the value-for-money of different loan and grant schemes to allow VFM to be made more transparent. Will such a formal analysis be possible within Tribal's contract?
How much money?
The bidding guidance repeat the wording from the HCA's bidding guidance:
There is no fixed split of funding between the Empty Homes Community Grant Fund and the Homes and Communities Agency route. However we hope to be able to award at least £10m via the Empty Homes Community Grant Fund and as much as £30m, if sufficient high quality bids come forward.
As the funding allocations for the HCA part of the programme are expected to announced on March 24th 2012, it will be interesting to see what will happen if the HCA allocates, say, £90million of funding, leaving only £10million for the Community Grants part of the programme. The promise that the amount awarded under the Community Grants Fund could be "up to £30million" depending on the quality of the bids does not seem deliverable unless the programme split has been agreed in advance to allow that much head-room. Or perhaps, as with the £50million, additoinal money will be found if necessary.
