MD3378 Delivery Plan – Building More Homes

Background

1.1.    The Greater London Authority (GLA) has been establishing refreshed delivery and governance arrangements over the last few months. 

1.2.    In undertaking these changes, we have:

•    defined a set of London-level, long-term outcomes which reflect Londoners’ aspirations for the city and towards which the GLA and the GLA Group are working, in partnership with others
•    agreed a small set of strategic, high-level, programmes which the Mayor will commission the GLA Group to deliver in order that the GLA and the GLA Group make the appropriate contributions towards the London-level outcomes.

1.3.    MD3274 ‘Updates to GLA Governance Documents’, published on 13 June 2024, marked the first formal step in implementing new portfolio and governance arrangements and set out approved revisions to the arrangements through which the Mayor exercises and, where appropriate, delegates his powers. It also laid out some changes to the way the GLA’s senior leadership works to ensure that the GLA is successful in exercising its strategic role and in securing delivery.

1.4.    The GLA is now bringing forward for approval delivery plans for the 14 strategic, high-level, programmes which are led by the GLA and involve functional bodies as appropriate. These are numbered 1-14 and set out below, along with delivery plans 15-21, where the relevant GLA Group organisation is taking a leadership role: 

1.    Building more homes
2.    Making best use of land
3.    Improving London’s housing stock
4.    Reducing inequalities
5.    Accommodation and wider support for those who need it most
6.    Reducing non-residential emissions
7.    Delivering a greener, more climate-resilient London
8.    Cleaning London’s air
9.    Supporting Londoners to benefit from growth
10.    Supporting and inspiring young London
11.    Boosting London’s growth sectors
12.    Helping local economies to thrive
13.    Upgrading London’s infrastructure
14.    Celebrating London
15.    Reducing violence and exploitation
16.    Building safer, more confident communities
17.    Supporting and overseeing reform of the Metropolitan Police Service
18.    Improving the Criminal Justice System and supporting victims
19.    Healthy streets
20.    Decarbonising transport
21.    Providing more effective, accessible and affordable public transport.

1.5.    The Mayor has been issuing mandates for these proposed programmes to prospective Senior Responsible Owners (SROs). Mayoral mandates define what the Mayor wants to see from each of the programmes, including their scope, objectives, and cross-cutting priorities. Programmes and their associated delivery plans have been developed by the proposed programme SROs, working with the relevant Deputy Mayors, Mayoral Directors and others in response to the Mayor’s mandates. They have been developed to strike the right balance between setting out plans and retaining flexibility to respond to events and learning, as delivery progresses, recognising that agility is important in the context of a changing landscape.

1.6.    Delivery plans lay out the London-level outcomes to which each programme contributes. In considering the GLA’s specific role in contributing to the London-level outcomes, programme SROs have focused on the role of the GLA as London’s strategic regional authority. This has meant looking carefully at where activities most effectively sit within the London system and how the GLA can work with partners to unlock and drive progress. In some cases that will be through direct delivery or through funding. In others it will be through more indirect mechanisms such as system reconfiguration, coalition formation, technical support or capacity building.

1.7.    Resource allocations to each programme are based on the allocations contained in the GLA: Mayor Budget 2025-26. Changes required to delivery plans over time will be agreed by the Mayoral Delivery Board (MDB) or the Mayor in line with our governance arrangements.

1.8.    Delivery plans lay out how each programme makes a positive difference to the relevant London-level outcomes. Key programme outputs are also detailed and will be reported quarterly to MDB, which is responsible for monitoring the performance and delivery of each programme’s delivery plans. 

Overview of the Building More Homes delivery plan

1.9.    The Mayoral mandate for the Building More Homes programme is appended to this decision form at Appendix 1. The proposed delivery plan is appended at Appendix 2 and presented by the Executive Director, Housing and Land, as the proposed SRO, for the Mayor’s approval. 

1.10.    By approving the plan, and the resources allocated to it, the Mayor is enabling the GLA, working with partners, to contribute to the core London-level outcome that Londoners live in homes that they can afford through the delivery of the projects detailed in the plan.

1.11.    London has a mountain to climb to reach its housing need as set by government (87,992 new homes a year from 2026), and to ensure that Londoners live in homes they can afford. The human and financial cost of homelessness and temporary accommodation – leaving one in 21 London children in temporary accommodation – is unacceptable. Lack of affordable housing is also holding back London’s economy and potential for further growth.

1.12.    The Building More Homes delivery plan aims to ensure that London’s housing sector is in the best position possible to deliver the number of homes needed, with a particular focus on social and affordable homes. It has three strands:

•    work to secure flexible funding to enable housing delivery, in recognition of sector viability challenges and that the cost of accelerating the building of genuinely affordable housing is substantial and beyond what the market can achieve alone
•    continued delivery of current Affordable Homes Programmes, alongside specific interventions to meet targets for council homes and rent control homes
•    work to enable more homes of all tenures by leveraging the GLA’s, GLA Group’s and wider public sector land holdings, financial resources, and relationships, to contribute meaningfully to London’s housing supply.

1.13.    The proposed delivery plan sets out the budget for each project within the programme.

1.14.    Projects detailed in the delivery plan fall into one of three categories:

•    projects which are already set out in detail in an existing Mayoral Decision or Director Decision 
•    projects for which this Mayoral Decision seeks Mayoral delegation to the SRO to take expenditure decisions  
•    projects which will require separate Mayoral Decisions.

1.15.    The projects with Mayoral Decisions and other relevant approvals in place are: 

•    continuing to administer the existing Affordable Homes Programmes: Affordable Homes Programme 2016-23 (AHP 16-23) and Affordable Homes Programme 2021-26 (AHP 21-26) - approved under MD2125, MD2282 and MD2707
•    leveraging GLA Group land holdings and joint venture interests to deliver high levels of affordable housing – approved under a number of existing overarching decisions, including MD2574, MD2747, MD3160, MD3164, MD3230, MD3244, MD3269, and MD3275
•    leveraging existing capital resources to fund infrastructure and land to support the delivery of homes – approved under MD2207 and MD2396.

1.16.    Projects for which this Mayoral Decision seeks Mayoral delegation to the SRO to take expenditure decisions are: 

•    promoting institutional investment into intermediate rent (£141,000 revenue in each year 2025-26, 2026-27 and 2027-28)
•    designing and delivering a new model of rent control homes to make an early contribution to the target for 6,000 rent control homes (£203,000 revenue in 2025-26, £204,000 in 2026-27 and £205,000 in 2027-28)
•    working through the London Housing Mission and other partnerships with government and stakeholders to identify and seek to implement the policy interventions necessary to further support housing outcomes (£1,000,000 revenue in 2025-26, £426,000 in 2026-27 and £427,000 in 2027-28). 

1.17.    Two projects will require separate Mayoral Decisions as they are expected to be large-scale funding schemes and because neither scheme parameters nor the quantum of funding in each have yet been agreed with government, meaning more detailed work is required before Mayoral approval is sought. They are:

•    negotiating and implementing the terms of the Social and Affordable Homes Programme 2026-36 (SAHP 2026-36) as a substantial successor AHP 
•    creating an interventionist City Hall Developer.

1.18.    The Executive Director, Housing and Land, will ensure compliance with the obligations set out in The Openness of Local Government Bodies Regulations 2014 which describe when written records of decisions and their content need to be published. Director Decisions and Assistant Director Decisions will be required where appropriate to meet these transparency requirements, including in instances where GLA funds are paid to external organisations.

Securing additional funding for projects in the delivery plan

1.19.    Key to delivering the objectives and expected outcomes of the Building More Homes delivery plan is securing funding to support the delivery of both new and existing projects. This funding may come from central government, but may also come from other sources including agencies, utilities providers, philanthropic funders and the private sector.

1.20.    Where funding is secured in the future to support the delivery of projects with legacy approvals in place, this decision form seeks approval to agree the receipt of such funding by the GLA without the need for a further Mayoral Decision. This would be for any funding secured to deliver projects that are already approved, and which contribute to the Building More Homes delivery plan.

1.21.    Where additional funding from government (or other sources) is secured in the future to expand or extend existing approved schemes contained in the Building More Homes delivery plan, listed in Appendix 4, and the parameters remain the same or similar as originally agreed with government (or the relevant body), this decision form seeks approval to delegate to the Executive Director, Housing and Land to agree the receipt of such funding after consulting with legal advisors and the GLA’s Chief Finance Officer and subsequently having secured agreement from the MDB. For the purposes of considering whether the parameters are similar as originally agreed with government (or the relevant body), the Executive Director, Housing and Land will have regard to whether the outcomes to be delivered have changed significantly or there is a significant change in attendant risks of the original scheme. If the outcomes to be delivered have changed significantly, or there is a significant change in attendant risks, or the decision is viewed as novel, contentious or repercussive, a Mayoral Decision will be required.

1.22.    Any decisions to accept additional funding will need to comply with the obligations set out in The Openness of Local Government Bodies Regulations 2014 as highlighted in paragraph 1.18 above. Any decisions to accept additional funding that do not require a formal decision form must be documented via a Record in Writing, as defined in MD3274 'Updates to GLA Governance Documents’, signed in June 2024, and will be reported publicly quarterly. 
Decision making in relation to Affordable Homes Programmes, Land Investment programmes and projects utilising returned Recycled Capital Grant and other specified forms of returned historic funding.

 
1.23.    The powers and functions of the GLA are exercised by the Mayor, as executive decision maker, on behalf of the GLA. Subject to some exceptions, the Greater London Authority Act 1999 (the ‘GLA Act’) provides that any functions exercisable on behalf of the GLA by the Mayor shall also be exercisable on behalf of the GLA by any member of staff of the GLA. MD3274 'Updates to GLA Governance Documents’, signed in June 2024, provides the default framework within which the Mayor’s powers are retained by him, delegated to others and exercised. It is a scheme of delegation; it sets down the rules and parameters for and within which decision-making in the GLA normally takes place.

1.24.    Under the Building More Homes delivery plan, significant delivery is expected through the existing Affordable Homes Programmes (project 2.1 in the appended delivery plan), a successor scheme (which project 1.1 seeks to secure), and through the existing land funds and our portfolio of recovered investments (project 3.2 in the appended delivery plan).

1.25.    Due to the scale of the funding, and the large number of transactions and decisions required to manage these projects effectively, different decision-making criteria and rules apply to these projects than those which are set out in MD3274 'Updates to GLA Governance Documents’ signed in June 2024. This also reflects the Mayor’s role in the planning approvals process.

1.26.    These different decision-making criteria and rules are appended as Appendix 3, which broadly reconfirms arrangements that have historically been in place in respect of Affordable Homes Programmes and land investment programmes and also includes rules in respect of projects utilising returned Recycled Capital Grant and other specified forms of returned historic funding. Appendix 3 should be read alongside the ‘Mayoral Decision-Making in the GLA’ document which was approved via MD3274. 

Reinvesting returned funding

1.27.    In addition to funding secured from central government and external sources, securing the objectives and expected outcomes of the Building More Homes delivery plan may also require the support of funding returned from approved GLA schemes and other specified sources of returned historic grant.

1.28.    The GLA has oversight of a range of different current and historic funding schemes that the Mayor has approved, or which were transferred to the GLA from the Homes and Communities Agency in 2012, and through which funding is sometimes, or may be, returned to the GLA. A list of these schemes is set out in Appendix 4 and other sources of returned historic grant are specified in Appendix 3.  

1.29.    These schemes operate in different ways, using a range of different funding methods – predominantly grant (recoverable in certain circumstances) and loans – and this means the amount and type of funding returned to the GLA through these funding schemes varies. The GLA is restricted in how returned funding can be used, with all of the returned funding being restricted to delivering housing priorities, and some having further restrictions.

1.30.    This decision form seeks approval to allocate funding that has been (or will be) returned to the GLA into delivering projects that are already approved as part an existing scheme listed in Appendix 4, without the need for a further Mayoral Decision. 

1.31.    The governance and delegations related to decisions to reinvest returned funding into Affordable Homes Programmes, Land Investment programmes and projects utilising returned Recycled Capital Grant and other specified forms of returned historic funding are detailed in paragraphs 1.23-1.26 above and Appendix 3. 

1.32.    Decisions to reinvest returned funding into schemes already approved by the Mayor but that do not fall within the areas detailed in Appendix 3 will be delegated to the Executive Director, Housing and Land if this MD is approved. Such decisions will be made in line with the governance processes associated with each scheme listed in Appendix 4.   

1.33.    The Executive Director, Housing and Land will ensure compliance with the obligations set out in The Openness of Local Government Bodies Regulations 2014 which describe when written records of decisions and their content need to be published. Where any decisions to reinvest returned funding that do not require a formal Decision form are made, they must be documented via a Record in Writing, as defined in MD3274 'Updates to GLA Governance Documents’, signed in June 2024, and will be reported publicly quarterly. 
 

2.1.    The delivery plan for the Building More Homes programme describes how the GLA will work across the housing sector and in close collaboration with London local authorities and central government to understand and overcome the barriers to housing delivery across all tenures. It includes activity towards meeting the Mayor’s commitment to deliver 40,000 new council homes, delivery of 6,000 ‘rent control’ homes for key workers by 2030 and establishing a new City Hall developer.

2.2.    The objectives and expected outcomes of the programme are set out in the Building More Homes delivery plan which is appended as Appendix 2.

2.3.    The core London-level outcome to which this programme will contribute is: Londoners live in homes they can afford. This reflects the importance of building more homes in London, particularly social and other forms of affordable housing, to address an overall imbalance of housing supply and demand, which is making housing more unaffordable in our city.

2.4.    The Building More Homes programme will also make a substantive contribution to the following wider London-level outcomes: Londoners are not homeless; Londoners’ homes are safe and decent; and stable, long-term economic growth benefits all of London’s communities.
 

3.1.    Under section 149 of the Equality Act 2010, the Mayor and GLA must comply with the public sector equality duty (PSED) and must have due regard to the need to:
•    eliminate unlawful discrimination, harassment and victimisation and any other conduct that is prohibited by or under the Equality Act
•    advance equality of opportunity between people who share a relevant protected characteristic and those who do not
•    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 re-assignment, pregnancy and maternity, marriage and civil partnership (but only in respect of the requirements to have due regard to the need to eliminate discrimination), race (ethnic or national origins, colour or nationality), religion or belief (including lack of belief), sex, and sexual orientation. 

3.3.    Consideration of the PSED is not a one-off task. The duty must be fulfilled before taking a decision, at the time of taking a decision, and after the decision has been taken, to ensure that equalities impacts are kept under ongoing review.

3.4.    The Building More Homes delivery plan helps achieve a number of the Mayor’s statutory equality objectives, and progress on delivery of these objectives is reported on each year in the Mayor’s Annual Equality Report.

3.5.    New homes delivered through the Building More Homes programme will likely help many people with protected characteristics, as many of these groups are disproportionately represented among those in need of housing they can afford. This is in part because they are more likely to experience homelessness or overcrowding; or to have low incomes that make it difficult for them to afford market housing. Others with protected characteristics may be more likely to need supported accommodation, or accommodation that meets particular design requirements.

3.6.    People from a minority ethnic background are disproportionately likely to experience poverty and associated housing constraints. These groups will therefore benefit from an increased supply of social housing, particularly homes at social rents, supplied through this delivery plan. People with disabilities are likely to benefit from the provision of supported and specialist accommodation. While older people are less likely to benefit from the delivery of more intermediate homes, as they are less likely to be eligible for a mortgage or meet the eligibility requirements of intermediate housing, they will benefit from provision of social rent and an increased supply of supported accommodation targeted at older age groups. 

3.7.    A number of projects in the Building More Homes delivery plan have already been through Equality Impact Assessments (EqIAs). These projects include existing Affordable Homes Programmes (project 2.1 in the delivery plan, approved through MDs 2052, 2125, 2282 and 2707), and the Homes for Londoners Land Fund (project 3.2 in the delivery plan – approved through MD2207).

3.8.    The project of designing and delivering a new model of rent control homes (project 2.2 in the delivery plan) is currently undergoing an EqIA, which will be published once completed and before any new model is rolled out.

3.9.    Two other projects in the Building More Homes delivery plan require further Mayoral Decisions or other formal approvals, through which equalities considerations will be finalised, including a full EqIA where appropriate. These are the negotiation and implementation of a successor Affordable Homes Programme (project 1.1 in the delivery plan), and the creation of an interventionist City Hall developer (project 1.2 in the delivery plan). There is no overarching decision for leveraging GLA Group land holdings and joint venture interests (project 3.1 in the delivery plan), but equality impacts are and will be assessed at the time of making a decision for the wide range of activities and interventions that make up this project.

3.10.    The equality impacts of the Building More Homes delivery plan and the projects within it will be kept under review as appropriate to ensure that the PSED is complied with on an ongoing basis.
 

Risks and issues

4.1.    The following programme-level risks to the delivery of the Building More Homes programme have been identified:

4.2.    The Executive Director, Housing and Land, as the SRO for the Building programme will be responsible for implementing and overseeing a risk framework for that programme. Project risks and mitigations will be managed as currently at a project level and reported periodically to the Programme Board. The Programme Board will also review the above programme-level risks and mitigations, reporting to Mayor Delivery Board alongside progress against programme objectives as part of the GLA's quarterly reporting regime. 

Links to Mayoral strategies and priorities

4.3.    The programmes outlined in this decision supports the following Mayoral strategies: 

•    The Mayor’s commitments and policies. It will also support delivery of the Mayor’s Housing Strategy, including the key aim to build more homes for Londoners and to deliver more genuinely affordable homes. In developing this delivery plan the continued relevance of the Housing Strategy has been kept under review.
•    The Mayor’s Equality, Diversity and Inclusion Strategy sets out an aspiration to ensure all Londoners have a good quality home at a price they can afford, and recognises that increasing the supply of genuinely affordable homes will help those particularly affected by London’s housing crisis. Distributing Affordable Homes Programme funding is a major tool that the Mayor has to directly increase the number of affordable homes in London.
•    The Mayor is required to publish a Spatial Development Strategy for London (The London Plan). The current and forthcoming London Plan will shape the operating environment for housing delivery and will be instrumental to the success of this delivery plan.  

Consultations 

4.4.    For projects which already have a formal decision form in place, the consultation undertaken for these projects is set out in the relevant decision forms. 

4.5.    The level and timing of consultation will vary for those projects not requiring a subsequent formal decision form. This will be a mixture of informal consultation with key stakeholders, as well as formal consultation.  

4.6.    Where further Mayoral Decision forms will be required to progress the projects in the Building More Homes delivery plan, consultation will be undertaken where appropriate; this will be shaped through engagement with relevant stakeholders such as delivery partners, community stakeholders and advisory groups.

4.7.    There are no conflicts of interest arising from those involved in the drafting and clearance of this decision form. As and when individual conflicts of interest arise during the delivery of initiatives contained in the Building More Homes delivery plan, they will be handled in line with the GLA policy on registering and declaring interests.
 

5.1.    The programme budget is set out in the delivery plan and summarised in the table below.

5.2.    The budget allocated to this delivery plan is presented in the GLA: Mayor budget 2025-26 approved on 31 March 2025 under MD3330 as below:

5.3.    Any budget commitments for future years are subject to the annual budget setting process.

5.4.    Any future transfers and movements within the budget for this programme, or between this and other programmes, will be handled in accordance with the GLA’s governance processes.
 

6.1.    Under section 30(1) of the Greater London Authority Act 1999 (the GLA Act), the Mayor acting on behalf of the GLA has the power to do anything that he considers will further any one or more of its principal purposes, which are:

•    promoting economic development and wealth creation in Greater London
•    promoting social development in Greater London
•    promoting the improvement of the environment in Greater London. 

6.2.    In deciding whether or how to exercise the general powers in section 30(1), section 30 (4) of the GLA Act requires the GLA to have regard to the effect which the proposed exercise of the power would have on:

•    the health of persons in Greater London
•    health inequalities between persons living in Greater London
•    the achievement of sustainable development in the UK
•    climate change, and the consequences of climate change. 

6.3.    Where the GLA exercises the power under section 30(1), pursuant to section 30(5) it must do so in the way which it considers best calculated to:

•    promote improvements in the health of persons in Greater London
•    promote the reduction of health inequalities between persons living in Greater London
•    contribute towards the achievement of sustainable development in the United Kingdom
•    contribute towards the mitigation of, or adaptation to, climate change, in the United Kingdom.

6.4.    The GLA must also make arrangements with a view to securing that in the exercise of the power in section 30(1), there is due regard to the principle that there should be equality of opportunity for all people in accordance with section 33 of the GLA Act and consult with such bodies or persons as the GLA may consider appropriate in this particular case in accordance with section 32 of the GLA Act.

6.5.    Under section 34 of the GLA Act, the GLA, acting by the Mayor, the Assembly, or both jointly, may do anything that is calculated to facilitate, or is conducive or incidental to, the exercise of any functions of the GLA exercisable by the Mayor; or, as the case may be, by the Assembly, or by both acting jointly. The foregoing sections of this report indicate that the decisions requested by the Mayor concern the exercise of the GLA’s powers under section 30 and section 34 of the GLA Act. 

6.6.    Under section 38 of the GLA Act, any function exercisable by the Mayor on behalf of the GLA may also be exercised by a member of the GLA’s staff – albeit subject to any conditions that the Mayor sees fit to impose. To this end, the Mayor may make the requested delegations to the Executive Director, Housing and Land, subject to the conditions set out above and requirements set out in this Mayoral Decision. 

6.7.    Section 31 of the GLA Act places limits on the general power and prohibits the GLA from incurring expenditure on anything which may be done by TfL, MOPAC or the LFC. 

6.8.    In taking the decisions requested of him, the Mayor must have due regard to the Public Sector Equality Duty (PSED) contained in section 149 of the Equality Act 2010. To this end, the Mayor should have particular regard to section three (above) of this report.

6.9.    If the Mayor makes the decisions sought, officers must also ensure that:

•    no reliance is placed on, nor commitments made in reliance of:

-    third party funding until legally binding commitments are secured for it and officers are satisfied that their proposed use of the same aligns with any conditions of award
-    future budgets remaining subject to the outcome of the budget setting process for future financial years, until those budget setting exercises are completed
-    “returned funding” without confirmation that it can be used as proposed and, where applicable, liaising with third party funders and varying current GLA funding agreements to reflect the reallocation of funding

•    where applicable, the Subsidy Control Act 2022 is observed
•    where expenditure concerns: 

-    purchase of services: they are procured in accordance with the GLA’s Contracts and Funding Code (the “Code”) and where applicable the Procurement Act 2023 (the “Act”); officers liaise with Transport for London’s procurement and supply chain team, which will determine the detail of the procurement strategy to be adopted in accordance with the Code and the Act; and put in place appropriate contractual documentation and ensure it is executed by the chosen service provider and GLA before the commencement of those services 
-    the award of grant funding such awards are made fairly, transparently, in accordance with the GLA’s equalities requirements and with the requirements of GLA’s Contracts and Funding Code and funding agreements are put in place between and executed by the GLA and recipients before any commitment to fund is made.

6.10.    If the Mayor makes the decisions sought, the Executive Director, Housing and Land must comply with the obligations set out in The Openness of Local Government Bodies Regulations 2014 when taking decisions in accordance with the delegations set out in this decision form or any other delegations in existing Mayoral Decisions as set out in Appendices 3 and 4. In particular regulation 7 which provides that where a decision has been delegated to an officer either (a) under a specific express authorisation or (b) under a general authorisation and the effect of the decision is to award a contract or incur expenditure which, in either case, materially affects the GLA’s financial position, the officer to whom the delegation has been made must produce a written record of the decision (regulation 7(1) and (2)). Regulation 7(3) provides that the written record must be produced as soon as reasonably practicable after the decision has been taken and must contain the date the decision was taken, a record of the decision taken with reasons, details of options considered and rejected, if any, and where a decision is delegated under a specific express authorisation, any conflicts of interest. Regulation 8 requires the written record, together with any background papers, must as soon as reasonably practicable after the record is made, be made available for inspection by members of the public including on the GLA’s website.
 

7.1.    Timelines are as set out in the delivery plan appended as Appendix 2.