MD2551 Homelessness Change and Platform for Life Programme

In 2015/16 the GLA secured £15m of capital funding from the Department of Health and Social Care’s (DHSC) to deliver new and refurbish existing hostel accommodation for rough sleepers and young people at risk of homelessness who are in education, training and employment. Mayoral Decision (MD) 1578 approved the allocation of an additional £15m from the GLA with the same governance arrangements for the Affordable Homes Programme.

The GLA has so far allocated £24.1m to deliver 542 homes across 15 schemes, leaving £5.9m unallocated. A pipeline of eligible schemes has been generated. These require funding exceeding this amount.

In order to continue delivering much-needed provision, including hostels for people sleeping rough and refuges for victims of domestic abuse, it is proposed that up to £10m capital funding is allocated, in two tranches, one of £5m and the second up to £5m, from the Affordable Homes Programme to HC&PfL to fund additional affordable housing starts on site by March 2022.

New bids would come forward through continuous engagement with eligible providers. HC&PfL is part of the Affordable Homes Programme and the same decision-making procedures apply. As with current arrangements for the programme, providers will submit bids through the GLA’s Open Project System, that will then be assessed in accordance with the criteria set out in the prospectus for the Mayor’s HC&PfL programme. Officers will assess bids and, following peer review, make recommendations for funding allocations. Bids will be assessed for financial risks as well as deliverability and are subject to the GLA grant recovery mechanisms. Each successful bidder will be an Investment Partner with the GLA, with any additional due diligence required to be undertaken by Housing and Land with support from Financial Services. The Executive Director of Housing and Land will approve funding allocations, in accordance with governance arrangements in the Affordable Homes Programme under the GLA’s decision making framework.

The aim of HC&PfL is to boost delivery and improve the quality of hostel provision available to people who are homeless, to provide short-term accommodation for younger adults who are struggling to maintain employment or access further education due to the risk of homelessness, and to provide refuge accommodation for victims of domestic abuse.

The types of housing delivered through this programme carries the following benefits:

• safety and security for vulnerable Londoners who are homeless or at risk of homelessness;
• safety and security for vulnerable Londoners facing domestic abuse in their homes;
• improved physical and mental health and well-being of rough sleepers, young people at risk of homelessness, and victims of domestic abuse;
• engagement with employment, education, training, volunteering or meaningful activity;
• support to help vulnerable Londoners move into settled mainstream accommodation;
• a reduction in an individual’s support needs over time, where appropriate; and
• support to help younger adults maintain their employment and access routes into employment.

Under section 149 of the Equality Act 2010, as public authorities, the Mayor and GLA are subject to a public-sector equality duty and must have ‘due regard’ to the need to (i) eliminate unlawful discrimination, harassment and victimisation; (ii) advance equality of opportunity between people who share a relevant protected characteristic and those who do not; and (iii) foster good relations between people who share a relevant protected characteristic and those who do not. Protected characteristics under section 149 of the Equality Act are age, disability, gender re-assignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status (all except the last being “relevant” protected characteristics).

The funding is specifically designed to address the housing pressures and challenges faced by people who are homeless or at risk of homelessness, and victims of domestic abuse.

Of those seen sleeping rough in 2018/19:

• 51 per cent were non-UK nationals;
• 50 per cent had a mental health need;
• 16 per cent were women;
• most of those seen rough sleeping (56 per cent) were in the 26-45 age group;
• eight per cent were under 26 years old;
• 12 per cent were over 55; and
• five people were under 18.

Characteristics of victims of domestic abuse (figures are national unless otherwise specified, as there is very little robust London-specific data available):

• gender: women are much more likely than men to be the victims of high risk or severe domestic abuse;
• age: younger people are more likely to be subject to interpersonal violence. Most high-risk victims are in their 20s or 30s. Those under 25 are the most likely to suffer interpersonal violence;
• pregnancy: nearly one in three women who suffer from domestic abuse during their lifetime report that the first incidence of violence happened while they were pregnant;
• separation: domestic abuse is highest amongst those who have separated, followed by those who are divorced or single;
• drug and alcohol use: victims of abuse have a higher rate of drug and/or alcohol misuse (whether it starts before or after the abuse): at least 20 per cent of high-risk victims of abuse report using drugs and/or alcohol;
• mental health: 40 per cent of high-risk victims of abuse report mental health difficulties; and
• ethnicity: around half the people placed in refuges in London are from a BAME group.

Given the above, the proposals in this paper are likely to have positive impacts on a number of groups with protected characteristics. As rough sleepers are over-represented among those with the protected characteristics of race and disability, the proposals are likely to have positive impacts on these groups. Furthermore, in comparison to the general population, victims of domestic abuse are more likely to be women, to have mental health support needs and to be from a BAME background.

a) Key risks and issues

The key risk is lack of take up, which could leave some of the additional £10m funding under-subscribed. This risk will be mitigated by widely promoting the programme among investment partners and profiling budget from the Affordable Homes Programme to HC&PfL in two tranches, one of £5m, and a second of up to £5m, with timing and profiling reflecting the budget requirement as and when new HC&PfL allocations are approved by the Executive Director.

b) Links to Mayoral strategies and priorities

The objectives of the proposals support:

• the Mayor’s London Housing Strategy policies 7.2c; and
• the Mayor’s Violence Against Women and Girls (VAWG) Strategy.

c) Impact assessments and consultations

Both the London Housing Strategy and the VAWG Strategy were subject to public consultation and equalities impact assessments.

d) Conflicts of Interest

There are no conflicts of interest to declare.

The decision requests approval for up to £10m additional capital funding to be allocated to the HC&PfL programme from the Affordable Homes Programme, to support the development of new and refurbishment of existing hostel and refuge accommodation starts by March 2022.

Transfers will be made in two tranches of £5m and up to £5m, profiled during the statutory annual budget setting process.

There are no other one off or ongoing revenue costs associated with this decision as staffing costs will be absorbed within existing budgets.

Under section 333ZE of the GLA Act, which applies section 31 of the Housing and Regeneration Act 2008 to the GLA with modifications, the GLA must ensure that a Registered Provider of Social Housing is the landlord of accommodation if the GLA is proposing to give financial assistance on condition that the recipient provides low cost rental accommodation.

Platform for Life is a programme for shared accommodation let at an Affordable Rent for young people aged 18-24, who are homeless or at risk of homelessness and are in housing need. Homelessness Change covers the capital costs of redeveloping and improving hostel accommodation, refuge accommodation for victims of domestic abuse, for Affordable Rent, and facilities for the delivery of healthcare, training or education aimed at supporting rough sleepers, those at risk of sleeping rough, and other non-statutory homeless people. Provided that eligibility criteria are articulated to ensure that this Affordable Rent accommodation is made available accordingly, the funding provided for Homelessness Change and Platform for Life will constitute social housing financial assistance for low cost rental accommodation under section 333ZE of the GLA Act and section 31 of the Housing and Regeneration Act 2008.

Under section 333ZE(3) of the GLA Act, any sums received by the GLA in respect of repayments of grants made by it for the purposes of social housing must be used by the Authority for social housing purposes.

Under section 30 of the GLA Act, the GLA has the power to do anything which it considers will further any one or more of its principal purposes of (i) promoting economic development and wealth creation (ii) promoting social development; and (iii) promoting the improvement of the environment in Greater London. The GLA is permitted to provide grant funding for those aspects of the Homelessness Change programme, which do not constitute social housing assistance, providing that it considers that doing so will further any one or more of its principal purposes; and providing that it is not prohibited from doing so by section 31, which prohibits the GLA from using its section 30 power to incur expenditure in providing any education services, any social services; or any health services in any case where the provision in question may be made by a London borough council, the Common Council or any other public body. However, section 31(6) does not prohibit the GLA from incurring expenditure in co-operating with, or facilitating or co-ordinating the activities, of those bodies.

Any such matters that the GLA proposes to fund, outside of the provision of social housing assistance, would appear to fall within section 30 and to not be prohibited by section 31 of the GLA Act.

In using the powers under section 30 of the GLA Act, the Mayor will need to comply with the requirements of section 30(4-5). These factors, relating to health and sustainable development, are taken into account in the original bidding prospectus. In addition, under section 32 of the GLA Act the Mayor is empowered to use his section 30 powers after consultation with such bodies or persons as considered appropriate in each case; and must consider consulting with London borough councils, the Common Council and the bodies listed in section 32(3) of the GLA Act.

In taking the decisions requested, the Mayor must have due regard to the Public Sector Equality Duty; namely the need to eliminate discrimination, harassment, victimisation and any other conduct prohibited by the Equality Act 2010, and to advance equality of opportunity between persons who share a relevant protected characteristic (race, disability, gender, age, sexual orientation, religion or belief, pregnancy and maternity and gender reassignment) and persons who do not share it and foster good relations between persons who share a relevant protected characteristic and persons who do not share it (section 149 of the Equality Act 2010). To this end, the Mayor should have particular regard to section 3 (above) of this report.

Legal advice has been sought in relation to the preparation of suitable contracts for approved allocations.