MD3102 The Mayor’s Refugee Housing Programme

1.1 In March 2022, central government launched the Homes for Ukraine and Ukraine Family Scheme to welcome Ukrainians fleeing conflict into the UK. Central government has also resettled Afghans who worked alongside the British government and the armed forces; people who assisted UK efforts in Afghanistan; and vulnerable groups, such as women and girls, people who are LGBTQ+, and minority groups at risk due to their ethnicity or religion.

1.2 London has a proud history of providing sanctuary to those fleeing conflict. As of March 2023, Londoners are hosting over 16,000 Ukrainians through the Homes for Ukraine scheme, and hundreds of Afghans have been accommodated in Home Office bridging accommodation sites within London. 

1.3 The Mayor is committed to supporting refugees to rebuild their lives and thrive in their local communities. The GLA has worked in partnership with the Home Office and Refugee Resettlement Coordinators across London boroughs to support their involvement in resettlement schemes. Through the London Strategic Migration Partnership (LSMP), the Mayor seeks to ensure the success of refugee resettlement in London.

1.4 The initial six-month commitment by hosts through the Homes for Ukraine scheme will, in the vast majority of cases, be ending soon or have already ended – adding further pressure to local authorities’ homelessness duties. There are also Afghan refugees, and evacuees from Afghanistan, in Home Office bridging accommodation who need permanent housing solutions, with some at risk of eviction.

1.5 The challenge of identifying long-term housing solutions for these cohorts, as well as increasing the availability of dispersed accommodation to house people seeking asylum, is being exacerbated by pressures in London’s housing market. These pressures include unaffordable private rents, insufficient levels of housing supply and the high cost of construction.

1.6 In December 2022, the Department for Levelling Up, Housing and Communities (DLUHC) announced a new £650m support package impacting the Ukrainian resettlement schemes. The package of support includes the £500m Local Authority Housing Fund (LAHF), which will fund local authorities in England to obtain up to 4,000 homes for Ukrainian and Afghan households, and individuals fleeing conflicts.

1.7 The Mayor has secured £126,183,294 in capital grant funding from the LAHF. In London, this share of the LAHF will be administered as the Refugee Housing Programme (RHP).

1.8 Through the RHP, the Mayor will provide capital grant funding to local authorities and, subject to subsidy control compliance (see 1.22, below), registered providers (RPs) to deliver up to 600 affordable homes in London for those who are eligible.

1.9 The RHP intends to provide delivery partners with the flexibility to pursue a range of different delivery models to secure affordable housing in a way that meets housing need and responds to local contexts. These delivery routes include:

i. refurbishing and/or converting existing properties owned by the delivery partner

ii. acquiring, refurbishing and/or converting properties not owned by the delivery partner; this  approach includes bringing empty or dilapidated properties back into use

iii. acquiring new-build properties ‘off the shelf’

iv. building new homes.

1.10 All homes grant-funded through the RHP must be located within Greater London.

1.11 It is expected that properties funded through this programme will have a minimum of two bedrooms (save in exceptional circumstances). Delivery partners will also be expected to deliver larger homes for households currently in Home Office bridging accommodation. Larger homes, to accommodate households leaving bridging accommodation, will have a minimum of four bedrooms, given the average family size of those in bridging accommodation.

1.12 Homes delivered through this fund must be low-cost rented housing. Rents charged by delivery partners can include Affordable Rent or London Affordable Rent benchmarks, or Social Rent levels. Homes that are let, and funded through the RHP, must be compliant with the Regulator of Social Housing’s Rent Standard. Rents can also be set at Local Housing Allowance (LHA) levels, as long as this is no more than 80 per cent of local market rents (including service charges). Delivery partners will also be required to consider the impact of both service charges and the total benefit cap on affordability when setting rents.

1.13 Homes delivered through the RHP will provide accommodation to eligible cohorts for a minimum of three years; no maximum time limit is imposed. Homes delivered via the RHP must remain affordable in perpetuity, and will eventually become available to support general needs housing (once their use by the eligible cohort ends), including to discharge local authority housing and homelessness responsibilities.

1.14 Eligible cohorts for this housing will be those who are homeless; those at risk of homelessness; and those who live in unsuitable temporary accommodation (including bridging accommodation), and who also belong to one of the following schemes:

i. the Afghan Citizens Resettlement Scheme (including Eligible British Nationals under this scheme) (ACRS)

ii. the Afghan Relocations and Assistance Policy (ARAP)

iii. Homes for Ukraine

iv. the Ukraine Family Scheme

v. the Ukraine Extension Scheme.

1.15 The GLA and the DLUHC will enter into a Memorandum of Understanding (MoU) that sets out the terms regarding the administration and delivery of the LAHF in London. The MoU sets out and agrees the funding commitments from the DLUHC; the financial expenditure; agreed delivery milestones; reporting and evaluation commitments; and communications between the parties.

1.16 The MoU sets out the delivery target of 600 homes, and the total capital funding allocation of £126.2m. The MoU also provides a breakdown of the following housing targets:

i. 494 homes (two or more bedrooms) for households that meet the overall eligibility criteria (as set out in paragraph 1.14)

ii. 106 larger homes, (four or more bedrooms) for households who have been resettled via ACRS and ARAP, and are currently residing in bridging accommodation.

1.17 The DLUHC will provide the GLA with funding in two tranches:

i. year one allocation – £37,854,988 (30 per cent of the total allocation)

ii. year two allocation – £88,326,306 (70 per cent of the total allocation).

1.18 The DLUHC will pay the year two allocation once the GLA has demonstrated that at least 60 per cent of the year one allocation has been committed.

1.19 The GLA must make best endeavours to meet the overall delivery target of 600 homes by 30 November 2023, which will be measured on exchange of contract or equivalent milestone. The DLUHC is committed to funding any contract that the GLA or its delivery partners enter into by 30 November 2023, even if completion occurs after this date.

1.20 The DLUHC will confirm if any additional funding is available to the GLA following a reallocations process. The reallocations process follows the DLUHC’s initial round of allocations to 182 local authorities in England (plus the GLA). Additional funding will become available if the national LAHF programme is undersubscribed. The reallocation will align with the fund objectives and consider area need and deliverability.

1.21 The GLA will publish funding guidance for the RHP shortly. The RHP funding guidance for London will include information for prospective bidders on the funding conditions, programme objectives and bidding process.

1.22 Local authorities in London will be able to bid for capital grant from April 2023, and bidding will be open continuously for up to 12 months or until all available grant is allocated, whichever is earlier. The opening of the programme to bids from private RPs is subject to the GLA making a “subsidy scheme” under the Subsidy Control Act 2022 following a mandatory referral of the proposed scheme to the Competition and Markets Authority’s Subsidy Advice Unit (SAU) for independent evaluation.

1.23 The GLA must wait until the publication of the SAU’s report, and the expiry of a short cooling-off period, before the scheme is made. Housing and Land (H&L) officers have prepared the submission to the SAU. Once the SAU’s report is received, any comments made by the SAU in respect of the proposed scheme will be considered and, following the cooling-off period, the Executive Director of H&L will decide whether to approve the opening of the RHP to RPs to apply for funding. Such approval would only be given where the Executive Director is satisfied that any comments in the SAU’s report have been appropriately addressed; and, if any amendments are made to the RHP funding guidance as a result, it remains substantively consistent with this Mayoral Decision and the terms of the MoU.

1.24 Bids will need to be submitted through the GLA’s Open Project System and assessed according to criteria set out in the Mayor’s RHP funding guidance. H&L officers will assess bids and, following peer review, make recommendations for funding allocations. The Executive Director of H&L will approve funding allocations, in accordance with the decision-making processes for the Affordable Homes Programme, as set out in Mayoral Decision-Making in the GLA.

2.1 The LAHF programme aims to support local authorities in England to provide accommodation for those with housing needs who have arrived in the UK via Ukrainian and Afghan resettlement schemes. The programme intends to address immediate housing pressures related to these cohorts, and create a new and permanent supply of affordable housing in the long-term.

2.2 The objectives of the LAHF – and in London, the RHP – are as follows:

i. To ensure recent humanitarian schemes (Afghan and Ukraine schemes) offering sanctuary to those fleeing conflict provide sufficient longer-term accommodation to those they support.

ii. To support housing-pressured areas that have generously welcomed substantial numbers of Ukrainian refugees, so that they are not disadvantaged by further pressures from these arrivals on the existing housing and homelessness systems.

iii. To mitigate the expected increase in pressure on local authority homelessness and social housing resources, which arise from the eligible cohort as sponsorship, family placements and/or bridging accommodation arrangements come to an end. This will be achieved by increasing the provision of affordable housing available to local authorities to support those in the cohort who are homeless, at risk of homelessness, or in bridging accommodation.

iv. To deliver accommodation that, as far as possible, can be converted into general needs housing units in the longer term. This approach will support wider local authority housing and homelessness responsibilities to UK nationals after usage by this cohort ends.

v. To use accommodation solutions to enable effective resettlement and economic integration of the eligible cohort.

vi. To reduce impacts on the existing housing and homelessness systems, and those waiting for social housing, including by reducing costs of emergency, temporary and bridging accommodation.

3.1 The Mayor’s Social Integration Strategy, All of Us, aims to support Londoners to play an active part in their communities and the decisions that affect them. This includes a commitment to challenge the barriers to integration that are faced by migrant and refugee communities. Homelessness, poor housing conditions and overcrowding are often cited as major issues faced by refugees and people seeking asylum.

3.2 In the UK, refugees are at risk of homelessness without assistance. The reasons for this include the following:

i. the high up-front cost of a tenancy deposit makes many homes in the private rented sector unavailable and unaffordable

ii. the rental costs of private-sector properties that are above the LHA rate can be difficult to meet for refugees in receipt of Universal Credit

iii. refugees experience barriers accessing English provision and employment opportunities, which hinders the ability to cover shortfalls in rent after the LHA or to be exempt from the benefit cap

iv. discrimination against people on benefits often hinders them from entering the private rented sector, which is also relevant to refugee populations.

3.3 This funding programme is specifically designed to address the housing pressures and challenges faced by refugees, including those at imminent risk of homelessness or rough sleeping.

3.4 Under section 149 of the Equality Act 2010, the GLA is subject to the Public Sector Equality Duty. This requires the GLA, in the exercise of its functions, to have due regard to the need to:

i. eliminate unlawful discrimination, harassment and victimisation and other conduct prohibited by the Act

ii. advance equality of opportunity between people who share a protected characteristic and those who do not

iii. foster good relations between people who share a protected characteristic and those who do not.

3.5 Protected characteristics under section 149 of the Equality Act are age, disability, gender reassignment, pregnancy and maternity, race, religion or belief, sex, sexual orientation, and marriage or civil partnership status. The proposals in this paper are likely to have positive impacts for recent cohorts of refugees; eligible British nationals; and households on low incomes.

3.6 Between early 2022 and February 2023, more than 161,400 Ukraine Scheme visa-holders arrived in the UK; and more than 23,500 Ukrainians were granted permission to extend their stay. Of those aged 18-64 who arrived on the Ukraine Schemes between March and September 2022, most were women (43,800, compared with 9,800 men). In the same period, 33 per cent of total arrivals were under 18.

3.7 Between April 2021 and November 2022, 22,833 individuals arrived in the UK from Afghanistan under the Afghan resettlement and relocation programmes. Over 9,000 people were placed in Home Office hotel accommodation; around half of these were children.

3.8 The Afghan resettlement schemes (ACRS and ARAP) enabled the evacuation and resettlement of those who worked alongside the British government and the armed forces; people who assisted UK efforts in Afghanistan; and vulnerable groups, such as women and girls, people who are LGBTQ+, and minority groups at risk due to their ethnicity or religion. The homes delivered through the RHP will enable the effective resettlement of this cohort, with many living in bridging accommodation and with sites due to close this year.

3.9 Refugees experience a rate of mental distress that is disproportionate to the wider population. Refugees have often survived traumatic experiences including war, sexual violence, torture, gender-based violence and human trafficking. In addition, elements of the UK’s asylum system are harmful to the mental health of refugees. Mental health issues can have an impact on a refugee’s ability to navigate the homelessness application process, access suitable accommodation, and engage with practitioners and local authorities.

3.10 Increasingly families on low incomes are living in the private rented sector, impacted by the benefit cap and/or struggling with housing affordability. Given the average family size of Afghans in bridging accommodation, the delivery of larger homes (four or more bedrooms) through this programme will particularly support the housing needs of this cohort.

3.11 In the medium and long term, this programme aims to deliver more affordable housing in London, which will bring significant equalities benefits to those living in the capital. Black, Asian and Minority Ethnic Londoners experience worse housing conditions, less tenure security, higher rates of housing need, worse affordability and lower wealth than White Londoners.

3.12 The supply of new, genuinely affordable homes will benefit those who are most likely to be negatively impacted by poverty and high housing costs, including older people, Deaf and disabled Londoners, and young Londoners.

Key risks and issues

4.1 Key risks are set out below:

Links to Mayoral strategies and priorities

4.2 The Mayor is committed to supporting refugees to rebuild their lives and thrive in their local community. The GLA has worked in partnership with the Home Office and Refugee Resettlement Coordinators across London boroughs to support their involvement in the resettlement schemes.

4.3 Through the LSMP the Mayor seeks to ensure the success of refugee resettlement in London. The LSMP Board is chaired by the Deputy Mayor for Communities and Social Justice. The purpose of the LSMP Board is to provide system leadership on migration, asylum and refugee issues in London.

4.4 The GLA convenes subgroups of the LSMP to tackle problems faced by refugees and people seeking asylum in London. There are currently subgroups set up to:

i. convene local authorities, central government and civil society partners to respond to immediate crises affecting these populations, and work to improve medium and long-term efforts to better support refugees and people seeking asylum

ii. support the operational delivery of refugee resettlement in London to enable London local government and the Home Office to meet their commitments towards refugee resettlement, and to enable the social integration of resettled refugees

iii. support the welfare of people seeking asylum accommodated in contingency hotels; and evacuees and refugees accommodated in Afghan bridging hotels, and in the core initial accommodation estate in London.

4.5 The Migrant and Refugee Advisory Panel operates as an expert panel to advise the work of the LSMP and the GLA’s social integration team; and to inform other relevant GLA teams on issues related to migration, asylum and refugees.

Tackling homelessness and helping rough sleepers

4.6 The overarching cause of London’s growing homelessness problem is the worsening shortage of affordable homes, combined with changes to the welfare system. The lack of social housing means many Londoners on low incomes need to rent privately with the help of housing benefit, Universal Credit and other benefits that may be needed to help with rent.

4.7 Preventing homelessness in all its forms, and supporting those who do become homeless into sustainable accommodation, are key priorities for the Mayor. The Mayor’s 2018 London Housing Strategy commits the Mayor to ‘investing in accommodation for homeless Londoners and working with councils to coordinate procurement of accommodation’.

Delivering genuinely affordable housing

4.8 To address London’s affordability pressures and rising housing need, the Mayor’s 2021 London Plan sets a target for 52,000 new homes to be built in the capital per year, over the next 10 years. The 2021 London Plan also sets a strategic target for half of these homes to be genuinely affordable.

4.9 In July 2021, the Mayor launched the Right to Buy-back (RTBB) programme to fund councils to acquire market homes for use as council homes, or as accommodation for homeless families. In September 2021, the Mayor expanded the RTBB programme as part of a wider offer to help councils support the arrival of Afghan refugees. Through this expanded offer, the Mayor funded the London boroughs of Hounslow and Islington to acquire 39 homes for recently arrived Afghan families.

4.10 In March 2022, the GLA launched a £1m revenue fund to help London boroughs increase take-up of the Mayor’s RTBB capital funding programme. The overall objective of the revenue fund is to help boost the short-term capacity and resources available to council housing teams, to increase acquisitions funded through the Mayor’s RTBB fund.

Consultations

4.11 In developing the Mayor’s RHP, the GLA has consulted with London Councils and a range of London boroughs, including through lessons learnt and experiences on related GLA programmes (for example, the Mayor’s RTBB fund).

Conflicts of interest

1.12 The officers involved in the drafting and clearance of this form have identified no known conflicts of interest.

5.1 The decision is seeking approval for the GLA to receive capital grant in the amount of £126.2m, from the DLUHC’s LAHF. The purpose of the grant is to provide capital grant funding to local authorities and RPs, to deliver up to 600 homes in London for those who are eligible (as outlined in paragraph 1.14, above) by 31 March 2024.

5.2 The grant will be funded in two tranches: 30 per cent in 2022-23, and 70 per cent in 2023-24. However, GLA’s receipt of the second tranche of payment is subjected to GLA achieving commitments of 60 per cent of the 2022-23 allocation.

5.3 Should additional DLUHC funding for this programme become available, the decision is also seeking approval to accept an additional allocation from the DLUHC for the RHP.

5.4 The programme will be administered as the RHP and aims mainly to meet the housing needs of those who arrived in the UK via Ukrainian and Afghan resettlement schemes. There is a risk that GLA may not achieve the target by 31 March 2024; however, risk-mitigation strategies are outlined at 4.1, above. 

5.5 Revenue grant is not available for the RHP. However, H&L is satisfied that the programme can be delivered within the existing revenue budget.

6.1 Section 30 of the Greater London Authority Act 1999 (as amended) (GLA Act) gives the Mayor a general power to do anything that he considers will further one or more of the principal purposes of the GLA. The principal purposes, as set out in section 30(2), are:

i. promoting economic development and wealth creation in Greater London

ii. promoting social development in Greater London

iii. promoting the improvement of the environment in Greater London.

6.2 Given the above and section 34 of the GLA Act, which allows the Mayor to do anything that is calculated to facilitate, or is conducive or incidental to, the exercise of any of his functions (including his functions under section 30), the GLA is empowered to receive funding from the government and provide financial assistance for the purpose of the recipient providing affordable housing to those in housing need.

6.3 In determining whether or how to exercise the power conferred by section 30(1) of the GLA Act, the Mayor must:

i. have regard to the effect that these decisions will have on the health of persons in Greater London; health inequalities between persons living in Greater London; the achievement of sustainable development in the United Kingdom; and climate change and its consequences (sections 30(3-5) of the GLA Act)

ii. pay due regard to the principle that there should be equality of opportunity for all people (section 33 of the GLA Act).

6.4 In taking the decisions requested of him, the Mayor must also 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 and foster good relations between persons who share a relevant protected characteristic and persons who do not (section 149 of the Equality Act 2010). These matters will also need to be taken into account when assessing specific bids for funding proposals and entering into funding agreements.

6.5 In respect of paragraphs 6.3 and 6.4, above, the Mayor should have particular regard to section 3 of this report.

6.6 In addition to the above, where the Mayor is proposing to use the power conferred in section 30(1) of the GLA Act, the Mayor must consider consulting in accordance with section 32 of the GLA Act (see section 4.11 above). The Mayor will need to consult in accordance with section 32 of the GLA Act, as appropriate, prior to entering into any funding agreements.

6.7 Where funding is to be granted by the GLA for the provision of low-cost rental accommodation, it should be noted that sections 31 to 36 of the Housing and Regeneration Act 2008 (as amended by section 333ZE of the GLA Act) will apply. This includes a requirement upon the GLA to impose a condition ensuring that a registered provider of social housing is the landlord when the accommodation is made available for rent.

6.8 The award of GLA funding under this programme is not a payment for services, and is therefore not subject to the requirements of the Public Contracts Regulations 2015. This notwithstanding, the GLA is still subject to the overarching duties of fairness and transparency. Officers must ensure that the funding is distributed fairly, transparently, in accordance with the GLA’s equalities duties, and in a manner that affords value for money in accordance with the GLA’s Contracts and Funding Code.

6.9 Legal advice should be sought on the forms of funding agreement to be used for this funding programme, including advice as to any subsidy control requirements; and no commitment to fund should be made before the relevant funding agreement is entered into.

6.10 Section 38 of the GLA Act provides that any function exercisable on behalf of the Authority by the Mayor, shall also be exercisable by, amongst others, any member of staff of the Authority, if or to the extent that the Mayor authorises and subject to any conditions imposed by the Mayor. The Mayor may make the requested delegation to the Executive Director of H&L, if he so chooses.

7.1 An indicative timeline is set out below: