MD3400 Delivery Plan – Cleaning London’s Air

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 function 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 MPS
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 revised 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 Cleaning London’s Air delivery plan

1.9.    The Mayoral mandate for the Cleaning London’s Air programme is appended to this Decision form at Appendix 1. The proposed delivery plan is appended at Appendix 2 and presented by the Assistant Director CAQTI, 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 following core London-level outcomes:

•    London has the cleanest air quality of any major world city
•    all Londoners live in a city that supports their mental and physical health
•    children and young Londoners achieve the health and learning outcomes they need to thrive at every stage of development
•    London is a net-zero carbon city.

1.11.    Despite huge progress, London still exceeds the World Health Organization’s (WHO) recommended health-based guidelines for both NO2 and Particulate Matter (PM), meaning Londoners are not breathing clean air. These pollutants impact us across the whole of our lives with around 4,000 early deaths linked to air pollution each year. They are also linked to asthma, cancer, maternal health issues, and even mental health problems, including emerging evidence of links to dementia. These impacts do not fall equally across the city; poorer and Black, Asian and Minority Ethnic communities are affected more severely. 

1.12.    Younger and older people are particularly vulnerable to the effects of air pollution with every school in London located in areas which exceeds the WHO recommended guidelines. The death of Ella Adoo-Kissi-Debrah, subsequent inquest into her death and resulting Prevention of Future Deaths report have established specific actions that the GLA and other bodies must take. It is therefore essential that we continue the ground-breaking work delivered over the past nine years to continue to clean up our air to ensure that it is healthy and safe for all.

1.13.    To ensure that London has the best air quality of any major world city, and to protect public health and minimise inequalities, it is necessary to focus on all the major sources of pollution in the city. Transport is still the largest single source but because of the impact of the Mayor’s interventions, including the Ultra Low Emission Zone (ULEZ), the transport contribution has dropped significantly. As a result, there needs to be more focus on other sources, such as pollution from construction and buildings. 

1.14.    The Cleaning London’s Air delivery plan has four key intervention workstreams: 

•    understanding the policies, interventions, powers and resources needed to make London’s air the cleanest of any major world city as quickly as possible
•    cutting pollution from all sources to improve health outcomes and reduce health inequality for Londoners
•    working with London boroughs and other partners take effective action to reduce exposure and emissions
•    raising awareness amongst London’s communities of the health impacts of air pollution and empowering them to advocate for local action.

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

1.16.    Projects detailed in the delivery plan fall into one of two 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.

1.17.    The projects with Mayoral Decisions and/or other relevant approvals already in place are:

•    installing PM2.5 filters for classrooms in 200 London primary schools, alongside associated monitoring and delivery of assemblies and lessons – approved under MD3263
•    delivery of the Non-Road Mobile Machinery Low Emission Zone (NRMM LEZ) programme to reduce emissions from the construction sector through the progressive tightening of existing standards, which will drive innovation – approved under MD3300
•    provision of oversight and support through the London Local Air Quality Framework (LLAQM), to ensure boroughs are delivering Mayoral air quality policies, taking action on air quality and fulfilling their statutory duties – approved under MD3139
•    research and production of a report on how and when London could meet WHO air quality guidelines – approved under MD3139 and ADD2760
•    ongoing pollution forecasting and issuing of the Mayor’s pollution alerts during days of predicted elevated pollution, provides health information which enables Londoners to reduce their exposure to air pollution, especially those most vulnerable to its impacts – approved under MD3139
•    delivery of the Breathe London programme enables the GLA to monitor localised pollution and empowers London’s communities to advocate for local action to improve air quality – approved under MD3217.

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

•    production of the London Atmospheric Emissions Inventory, and associated data analysis and research to enable the GLA to track London's progress in tackling major sources of pollution – approved as part of TfL business planning
•    evaluation of the ULEZ programme to understand the reduction in NOx emissions from transport, enabling Londoners to breathe cleaner air. This will include research on the health impacts of air pollution and the associated benefits of the Mayoral polices
•    reducing key sources of air pollution identified in the London Atmospheric Emissions Inventory (LAEI) 2022 to help London meet the WHO air quality guidelines, alongside minimising exposure. This may include programmes, campaigns and research on sources such as woodburning, rivers, tyre and brake wear and commercial cooking   
•    provision of leadership and work with other cities and organisations within the UK, mainland Europe and further afield to build stakeholder support for further action to reduce pollution
•    supporting TfL with research and initiatives towards achievement of the Decarbonising Transport programme. The main budget for this programme is approved via TfL business planning.

1.19.    The Assistant Director CAQTI 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

1.20.    Key to meeting the objectives and expected outcomes of the Cleaning London’s Air 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. 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 Cleaning London’s Air delivery plan. 

1.21.    Where additional funding from government (or other sources) is secured in the future to expand or extend existing approved projects contained in the Cleaning London’s Air delivery plan, 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 Assistant Director CAQTI 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 Assistant Director CAQTI 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, 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 decision 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 1.19 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.

1.23.    Some of the Mayor’s air quality priorities will be delivered and managed by Transport for London (TfL) under the following programmes and their associated delivery plans: 

•    Healthy streets
•    Decarbonising transport
•    Providing more effective, accessible and affordable public transport.

1.24.    The budget for ensuring delivery of these programmes is largely the responsibility of TfL and as such will be managed through TfL’s existing decision making and governance processes under these programmes. However, budget is required within the GLA to support those functions associated with these programmes (as well as the Cleaning London’s Air programme) which cannot be carried out by TfL.
 

2.1.    The delivery plan for Cleaning London’s Air describes how the GLA is uniquely positioned to drive further action and innovation to ensure all Londoners are breathing cleaner air. It will do this by using its comprehensive understanding of air pollution to inform Londoners and stakeholders; by mobilising and coordinating partners like the boroughs, TfL and universities; using statutory powers (e.g. over planning); and delivering its own programmes.  

2.2.    The objectives and expected outcomes of the programme are set out in the Cleaning London’s Air delivery plan which is appended at Appendix 2.

2.3.    The core London-level outcome to which this programme should contribute is: Londoners are breathing clean air. 

2.4.    The Cleaning London’s Air programme will also make a substantive contribution to the wider London-level outcomes: Londoners live in a city that supports their mental and physical health; Children and young Londoners achieve the health and learning outcomes they need to thrive at every stage of development; London is a world-leading global city; and London is a Net Zero carbon city.
 

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 Cleaning London’s Air delivery plan will help 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.    In June 2023 the GLA published updated analysis on exposure to air pollution showing that not only are there huge health impacts of pollution, but also that they disproportionately impact the most vulnerable; more deprived people; and Black, Asian and Minority Ethnic communities. It also established that those who contribute the least to poor air quality suffer the most from it. This means that improving air quality is fundamentally about tackling social injustice and health inequalities.

3.6.    Marginalised communities, and groups with protected characteristics, are often disproportionately affected by air pollution. Research has found there are on average higher concentrations of NO2 in areas that have higher percentages of non-White ethnic groups, with a particularly skewed distribution for the Black/African/Caribbean/Black British population. 

3.7.    The projects set out in this MD will benefit all Londoners; however, due to the unequal impacts of pollution on the most vulnerable Londoners, there is likely to be a positive effect in tackling social and health inequality. Having a better understanding of the geographical variation in the health risks of long-term exposure to air pollution will also create new opportunities to take targeted and effective action.
 

Risks and issues

4.1.    The following programme-level risks to the delivery of the Cleaning London’s Air programme have been identified:

4.2.    The Assistant Director CAQTI as the SRO for the programme will be responsible for implementing and overseeing a risk framework for the programme. Project risks and mitigations will be managed as currently at the project level and reported periodically to the Cleaning London’s Air Programme Board. The Programme Board will also review the above programme-level risks and mitigations, reporting to Mayoral 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 Cleaning London’s Air programme will also contribute towards delivering the Mayor’s London Environment Strategy and the Equality, Diversity and Inclusion Strategy. 

4.4.    The Mayor’s London Environment Strategy sets the goal of London having the best air quality of any major city in the world. 

•    London Environment Strategy Policy 4.3.1: The Mayor will establish new targets for PM and other pollutants where needed. The Mayor will seek to meet these targets as soon as possible, working with government and other partners.

4.5.    The Mayor’s Equality, Diversity and Inclusion Strategy sets out how he will work to create a fairer, more equal, integrated city where all people feel welcome and able to fulfil their potential.

•    Objective 4: “Improve Londoners’ air quality and access to green space and lower the city’s carbon emissions so that inequalities in exposure to harmful pollution and climate risks are reduced.”

Consultations

4.6.    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.

4.7.    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.  

4.8.    Where further Mayoral Decision forms will be required to progress the projects in the Cleaning London’s Air delivery plan, consultation will be undertaken where appropriate; this will be shaped through engagement with relevant stakeholders such as delivery partners, London boroughs, businesses, and other organisations such as community and campaign groups, as well as philanthropic and other funding bodies.

 
4.9.    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 Cleaning London’s Air 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.    The GLA: Mayor Budget 2025-26 does not include capital slippage estimated at £2.7m for the Mayor’s School Filter Programme as at the time of writing the GLA Capital Accounts for 2024-25 have not yet been finalised to confirm the slippage. The budget for the slippage will be adjusted for in-year, including profiling to ensure delivery for the period between 2025-26 to 2027-28.

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

5.5.    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 the GLA’s 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 power 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), under 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 general 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 Assistant Director CAQTI, subject to the conditions and requirements set 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 Assistant Director CAQTI must have regard to 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. 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.