The Northern Ireland Federation of Housing Associations (NIFHA) Represents 26 Registered

Date:24 June 2014
Consultation:2014 Review of the NI Housing Executive’s Housing Association
Nomination Process

Introduction

The Northern Ireland Federation of Housing Associations (NIFHA) represents 26 registered housing associations in Northern Ireland. Collectively our members provide 44,000 homes comprising general needs, specialist and supported accommodation, as well as shared ownership. Further information on our members and NIFHA’s work is available at

Housing associations are not-for-profit social businesses which increasingly borrow significant amounts of private finance to deliver public benefit in meeting housing need, supporting their tenants and investing in communities.

Background

The Housing Executive (NIHE) provided a paper for consultation on the Housing Association Nomination Process in April 2014 which was circulated by NIFHA to all housing associations. The NIHE presented the review of the nomination process on 23 June to a group of Chief Executives and Development Directors and members of Development Teams across a range of associations.

This short response collates the views of housing associations on the consultation proposals which were provided directly to NIFHA and reflects the discussion between associations and the NIHE at the consultation meeting.

General Comments

One of the biggest development challenges facing housing associations in the delivery of the Social Housing Development Programme is access to suitable sites. Locating land in areas of housing need and securing sites within market valuations, reflecting commercial and value for money considerations, is increasingly difficult. It is important therefore, that all partners in the development process work together to maximise opportunities to source land in the right areas at the right price. A rising market, the reluctance of some landowners to sell and a general shortage of land in areas of most housing need means that public sector land offers significant development potential for housing associations.

While the NIHE land bank has almost been exhausted, there are still some NIHE owned sites that could be developed to provide new social housing. There are also a number of large and strategic sites as well as smaller areas of developable land within the control of government departments and their agencies. The housing association nomination process applies to these sites when they come through the public sector disposal process as well as to remaining NIHE sites. It is imperative for housing associations that any nomination process is responsive to the potential in these sites and enables the best fit between available sites and associations. The risk appetite of the organisation, availability of financing and ability to move quickly in response to the timetable set by government departments and agencies will be important considerations in nominating associations for these sites.

NIFHA would contend that the current nomination process and criteria do not support effective delivery of the SHDP or make best use of available public sector sites. We welcome the review of the housing association nominations process and the NIHE’s commitment to flexibility, pragmatism and a more effective and timely approach when it comes to the nomination of NIHE and public sector sites. The reduction in the number of assessment criteria and streamlining of what was an unnecessarily bureaucratic system should have a beneficial impact on the transfer of sites. The introduction of a ‘Best Fit’ approach was generally agreed by associations to be a helpful addition to the nominations process.

NIFHA supports the combined approach of an emphasis on performance over a five year period alongside Expressions of Interest that should enable the delivery of large schemes as well as more difficult sites to nominate, such as those under 10 units, sites in rural areas, particular types of scheme etc. We also support the principle of looking at housing associations’ current areas of operation and existing schemes or ongoing development activity that may have a bearing on which sites they would be interested in, although this should not be the sole determination when considering ‘best fit’.

Specific Comments

In relation to Option 1 in the consultation document, NIFHA has been advised that some Procurement Groups do have policies and procedures in place to allocate NIHE transfer sites to members within the group. This should be reflected and continue to be an option.

In principle, there was general support for the proposal to recognise successful delivery when it comes to the Scoring and Ranking Matrix, with those associations who are actively contributing to the Social Housing Development Programme (SHDP) receiving a high score and ranking when it come to the nomination of sites. We welcome the focus on actual performance rather than subjective assessments.

However, housing associations expressed concern at the scheme/number of units breakdown in relation to the Actual Delivery Score in the Scoring and Ranking Matrix. There was also feeling that this could see the number of schemes delivered being prioritised over the number of units, with an association delivering a high number of schemes but with a small number of units, receiving a higher ranking than association delivering a large number of units but across fewer schemes. This could potentially act as a disincentive for those associations routinely developing significant numbers on several sites.

The Planned and Delivered Score is problematic. NIFHA believes that it is to housing associations’ credit that they are able to successfully substitute those schemes in the programme that are no longer viable. The localised nature of the SHDP and need to commit to specific schemes each year does not optimise delivery and delivery as programmed is not always possible for very valid reasons. To penalise associations, therefore, for not delivering against the programme even though they may deliver the target numbers in the area of need is not a reasonable assumption. We believe that associations should be measured on the number of units they delivered against the number of units they committed to delivering. NIFHA would suggest that this criteria and score could be removed without impacting significantly on the Scoring and Ranking Matrix.

Some associations deliver schemes through a development partner. It is not clear if those schemes are attributed to the commissioning association or the development partner in the NIHE’s assessment of delivery of new schemes. This could make a difference to the scoring and ranking of some smaller/community-based housing associations.

Given that the Nomination Process will also be used to identify housing associations for other types of NIHE schemes - House Sale Buy-Backs/Single Dwelling Stock Transfer, Targeted Existing Satisfactory Purchase/Off the Shelf, Complex Needs Special Acquisitions and Concept Planning/Feasibility Study – it does not seem reasonable to only measure performance based upon the delivery of new build units. We are not necessarily advocating complicating the Scoring and Ranking Matrix and given our emphasis on the need for this process to engage with the disposal of public sector sites it may not be appropriate to include this information in the matrix. However, when it comes to schemes such as those listed above, other aspects of housing association delivery will need to be considered.

Although those associations who are delivering at scale will benefit most from this new approach, NIFHA would ask that all developing associations who wish to be considered for a nomination are able to be included in the process. The Expression of Interest criteria will hopefully allow for those associations developing smaller numbers of units, but who may have an interest in smaller sites, specialist schemes, schemes with listed buildings and particular areas, to access the nomination process. It should be noted that some small sites or specialist schemes are difficult to develop and can take considerable investment and resource. Development activity may be constrained by the availability of land rather than financial capacity or risk appetite and it is important to provide the opportunity for smaller associations (in development terms) to access suitable sites. Given the Ministerial and policy emphasis on encouraging more housing associations to actively participate in the development of new homes, we welcome the use of Expressions of Interest and the ‘Best Fit’ approach to provide opportunities for smaller developing associations where appropriate. NIFHA contributed to the NIHE Land and Strategic Regeneration Team’s development of a new approach to managing the delivery of schemes on transfer sites and we believe that this will support the successful development of these sites within an established timeframe.

The more flexible approach outlined in the consultation document was welcomed and greater use of sector knowledge, discretion and a ‘Best Fit’ approach is helpful. However, with a less rigid application of the matrix comes a need for more transparency and accountability as to how decisions were made. Some understanding of the rationale for decisions where a ‘Best Fit’ judgement has been applied would also be helpful. A schedule of what has been delivered and by whom in terms of transfer sites was felt to be useful and could be circulated to associations by NIFHA on an annual basis. Housing associations also requested an overview of what transfer sites have been nominated, for how many units and to whom over the past ten years. We appreciate that communicating more detail on the decision-making process and allocation of sites could be time-consuming for the Strategic Development Team, but NIFHA is happy to take on a role in coordinating that communication with associations.

NIFHA welcomes the accommodation of “differing areas of operation, levels of risk appetite and resource capacity” of associations within this revised framework. We would ask that a nuanced approach is taken in each of these areas and other aspects which may affect the nominations process and should hopefully be reflected in the Expressions of Interest from associations.

The proposal to offer a six week window in which housing associations could make a decision about whether to accept a nomination was felt to be reasonable and there was general agreement that any association which has not responded within this timeframe should lose the nomination. The associated timeframe for development currently being piloted by the NIHE’s Land and Strategic Regeneration Team will also support timely delivery of NIHE and public sector sites.

If an initial nomination is refused, the proposal to provide detailed reasons as to why that was the case is helpful and was welcomed by associations. If there are technical reasons why a nomination was refused, it is important in order to keep the process moving as quickly as possible that this information is provided in full to the next association in the matrix.

In relation to supported housing schemes, those housing associations who have a particular interest and expertise in supported housing noted that it would be important to retain existing processes for nominating associations to delivery these schemes through other procurement options.

NIFHA welcomes the opportunity to contribute to this consultation and the development of a fit for purpose nominations process for the transfer of NIHE and public sector sites. We are happy to play a coordinating role in ensuring that the transparency and accountability noted in the consultation document is communicated to housing associations. We look forward to working with the NIHE to determine how this role can be best fulfilled.

Submitted on behalf of NIFHA by:

Jennie Donald
Deputy Chief Executive

Page1 of 4