DD2752 Building Safety Standards Report

1.1.    The GLA has introduced fire and building-safety measures through: 
•    the London Plan
•    the London Plan Fire Safety Guidance
•    building-safety requirements for schemes in receipt of capital grant; and those built on land owned by the GLA, and GLA Land and Property. 
1.2.    These policies have existed to address what the Mayor has judged to be inadequate national building-safety policies. 
1.3.    There have been significant amendments to building regulations since these policies were first developed. These include: provision for second staircases in buildings over 18m; changes to the threshold for combustible materials on external walls; and new duties under the Fire Order. Most significantly, the Building Safety Act also places strict regulatory oversight on all higher-risk buildings. With the conclusion of the Grenfell Tower Inquiry Phase 2, and the government’s acceptance (as written or in principle) of all recommendations, national building-safety policy is set to change further. 
1.4.    The GLA is likely to launch a successor to the Affordable Homes Programme (AHP) 2021-26 by autumn 2025. This is the Mayor’s primary funding lever to deliver affordable housing in London. The Mayor is committed to ensuring that homes delivered by the AHP meet the standards Londoners expect. To ensure the AHP is designed with the best possible understanding of the changing national regulatory framework, and the levers available to the Mayor to improve safety, the GLA intends to commission advice to understand: the regulatory gaps, if any, left by the emerging national framework; and the appropriateness of implementing further Mayoral interventions via funding guidance. 
 

2.1.    The objective of this work is to ensure that the Mayor is enhancing, rather than duplicating, national building-safety standards; and that any London-specific requirements are fit for purpose in a rapidly changing landscape.
2.2.    The output to support this objective is the delivery of a report to the GLA in August 2025. This will be delivered via a contract between the GLA and the appointed consultant. The procurement will be conducted in accordance with the Contracts and Funding Code.
2.3.    The report will be an evidence-based evaluation of building-safety requirements in the AHP 2021-26, and will contain options on which requirements should be included in any successor programme. 
 

3.1.    Under section 149 of the Equality Act 2010, the Mayor and GLA are subject to the public sector equality duty, and must have due regard to the need to:
•    eliminate unlawful discrimination, harassment and victimisation
•    advance equality of opportunity between people who share a relevant protected characteristic and those who do not
•    and foster good relations between people who share a relevant protected characteristic and those who do not. 
3.2.    The protected characteristics are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation and marriage/civil partnership status. The duty involves having appropriate regard to these matters as they apply in the circumstances, including having regard to the need to: remove or minimise any disadvantage suffered by those who share or are connected to a protected; take steps to meet the different needs of such people; encourage them to participate in public life or in any other activity where their participation is disproportionately low. This can involve treating people with a protected characteristic more favourably than those without one.
3.3.    The AHP 2021-26 Equalities Impact Assessment (EqIA) found that building-safety requirements would potentially improve resident experience across the range of tenures supported by the programme (with a range of protected characteristics represented). This positive impact would occur by assuring residents their homes are built to high safety standards, and reducing resident stress. The requirements would also potentially benefit older or less mobile Londoners (including disabled Londoners), as they were expected to afford greater protections for those most vulnerable in a fire. 
3.4.    These requirements, according to the EqIA, are not expected to have a material impact on housing delivery. Lower levels of delivery through the AHP would have a disproportionately negative impact on Londoners facing the greatest housing need, who are more likely to be in protected groups due to race or disability.
3.5.    This work will explore whether the EqIA’s assumptions remain accurate in the current context. This will improve the GLA’s understanding of how any successor programmes would impact Londoners according to their protected characteristics.
 

4.1.    On value alone this would be an Assistant Director (AD) decision, but on this occasion the Executive Director (ED) of Housing and Land (H&L) is the decision taker. This budget is held and approved under Land and Development unit, to be used to deliver the Building More Homes Delivery Plan. However it has been agreed that this spend will be incurred by the H&L Strategy & Policy team, which is part of H&L directorate. The Executive Director is required to authorise this decision as the H&L Strategy & Policy team does not report to an AD, but instead reports directly into the ED. 
4.2.    The key risk to achieving the objective and expected outcomes is that the report is delivered too late for use in drafting the prospectus for the successor to the AHP 2021-26. This risk is being mitigated by holding pre-tender engagement with potential contractors, who have confirmed the contract package of specification, budget and timeframe is achievable. 
4.3.    This work directly links into the Mayor’s priorities, as it relates to the design of the expected successor to the AHP 2021-26. The AHP is the major capital fund for London for affordable housing delivery; the funding conditions imposed have direct effects on the standards, safety and quantity of new homes delivered in London. This work therefore contributes to the three Mayoral housing mandates: building more homes, making best use of land, and improving London’s housing stock. It also contributes to the Mayor’s cross-cutting priorities of a resilient city, addressing structural inequalities and health in all policies.
4.4.    No conflicts of interest have been identified for any officer involved in drafting and clearing this decision.
 

5.1.    The Director’s approval is sought for expenditure of up to £25,000 in 2025-26, from GLA Housing and Land’s 2025-26 revenue budget, to commission a report on building-safety requirements in the AHP 2021-26. This will be delivered via a contract with an external consultancy, following competitive tender. This report is to inform building-safety requirements in any successor to the AHP 2021-26.
5.2.    This is to be funded from a one-off growth budget of £1m revenue approved for Housing and Land, and is currently held in the Land and Development unit. This was approved as part of the 2025-26 budget. This budget is included in the Building More Homes Delivery Plan and MD3378.
5.3.    All appropriate budget adjustments will be made, and the consultancy contract will be managed by the Strategy and Policy team within Housing and Land.
 

6.1.    The work will be delivered according to the following timetable: