Project requirements

Westmorland and Furness Council was established on 1 April 2023 following reorganisation of local government in the region, consolidating the former districts of Barrow-in-Furness, Eden, and South Lakeland into a single unitary authority. The local authority commissioned RHE to undertake a comprehensive review and amalgamation of private sector housing enforcement policies concerning the Eden Pathfinder Programme and wider regional amalgamation. The objective was to ensure a consistent policy framework and approach to enforcement under a single regional policy framework, which would bring about methodical application of housing standards and associated regulatory compliance, with the aim of improving the quality of private sector housing across the region.

The project brief included a comprehensive review of PRS enforcement frameworks, Minimum Energy Efficiency Standards (MEES) documentation, financial penalty processes and fee policy structures. The main objectives were to bring about uniformity in cross-boundary enforcement, boost service delivery and make sure that all PRS enforcement documentation was fully compliant with current legislation and best practice.

In addition to document review, the project required engagement with operational teams, facilitation of workshops and formulation of a revised suite of policies and procedures covering enforcement under multiple regulatory regimes: the Housing Act 2004, Housing and Planning Act 2016, MEES Regulations and related landlord sanction frameworks including banning orders and rent repayment orders.

Project delivery

RHE Global completed the project in two phases: a district-specific review focused on Eden District and a wider consolidation phase covering all areas under Westmorland and Furness Council.

In Phase 1, the project reviewed Eden District’s enforcement procedures and service delivery arrangements for PRS enforcement. This entailed drafting updated operational procedures, creating MEES-specific templates for advice and enforcement (e.g. notices and penalty documentation) and developing fee-structure documents to inform decision-making protocols. Bespoke forms were created to support equable officer decisions and internal governance (e.g. ‘Officer fee calculation decision,’ ‘Record of panel review’ and ‘Consideration of representation’ forms).

Phase 2 extended this review local authority-wide, with a desktop audit of existing private sector housing policies and procedures across the former districts. The work necessitated cross-referencing multiple enforcement policy documents including those related to HMOs, civil penalties, electrical and fire safety and MEES compliance. The team found areas of disparity and weaknesses in the current policies and procedural documentation. Following review, RHE mapped and recommended a single amalgamated policy and procedural document for adoption across the region. A review of how PRS complaints and service requests are currently triaged and responded to across the local authority formed part of this process.

Throughout the undertaking, RHE facilitated structured interviews and workshops with housing enforcement teams, service managers and corporate leads to gain a complete understanding of local operational approaches and policy priorities. A full written report was produced, with recommendations for standardising enforcement frameworks, putting forward best-practice operational models and adopting a local authority-wide housing enforcement policy framework. The resulting private sector housing policy considers:

• Enforcement principles:

  • Establishes the local authority’s statutory approach to housing enforcement, which is grounded in proportionality, consistency, transparency and targeting

  • Clarifies enforcement objectives, including risk-based regulation and better housing conditions

• Complaint handling and inspection protocols:

  • Outlines procedures for triaging service requests, undertaking inspections, and identifying statutory hazards under the Housing Health and Safety Rating System (HHSRS)

  • Provides clarity on enforcement approaches across tenures, including HMOs, PRS and owner-occupied dwellings

• Overview of legislative enforcement powers

  • Details enforcement mechanisms under the Housing Act 2004, including improvement notices, prohibition orders and emergency measures

  • Covers sanctions under the Housing and Planning Act 2016, such as civil penalties, banning orders and rent repayment orders

• Compliance policies

  • Covers aligned enforcement procedures for Minimum Energy Efficiency Standards (MEES), Electrical Safety Standards, and Smoke and Carbon Monoxide Alarm Regulations

• Decision-making and documentation framework

  • Provides set documentation (e.g. notices, penalty calculation tools and decision logs) to support legally robust, consistent and accountable enforcement decisions

• Appeals, governance and oversight

  • Sets out clear procedures for representations, internal panel reviews and appeals

  • Adopts a governance structure to support officer authorisation, quality assurance and policy review.

To support policy implementation, RHE developed and delivered a full-day practitioner workshop for housing enforcement officers at Westmorland and Furness Council. The workshop covered enforcement under key legislation, financial penalty decision-making and complex enforcement scenarios such as banning orders and rent repayment orders. Facilitated by RHE specialist consultants, each session comprised a presentation alongside group-based case studies and discussion to inform the review process. 

Project outcomes

The project successfully put into place a comprehensive policy framework that consolidates housing enforcement approaches across Westmorland and Furness. Key outcomes are:

• Recommendations report: A full written report outlined the key inconsistencies across legacy policies and procedures and made practical recommendations for local authority-wide adoption of revised frameworks. The report  proposed RIAMS procedure integration, where appropriate, and a defined timeline for action.

• Consolidated private rented sector policy document: A new, draft Westmorland and Furness Private Sector Housing Enforcement Policy was developed, integrating key legislation including the Housing Act 2004, MEES Regulations, electrical and fire safety and PRS management.

• Template documentation and forms: A suite of operational templates and prescribed notices was produced – MEES-specific letters, penalty forms, decision-record templates and financial penalty matrices, to support uniform and transparent enforcement.

• Fee policy and decision-making policy frameworks: Standardised documentation was introduced to inform civil penalty fee-charging practices across the PRS and MEES regimes, ensuring legal defensibility and clarity of decision-making protocols.

The review was  also insightful regarding the operational pressures experienced by officers, highlighting areas for future service enhancement such as enhanced digitalisation of enforcement workflows and clearer triaging protocols for PRS service requests. This project has put forward a consistent, legally resilient and enforceable private sector housing enforcement policy for recommended adoption across Westmorland and Furness Council. It has created a clear and defensible policy framework that aligns with national guidance and reflects local enforcement priorities. To inform the policy document, RHE specialist consultants undertook engagement, research and document review, as well as practitioner training, aligning to current best practice for the delivery of proactive, risk-based enforcement. The project approach offers a model for other local authorities navigating local government reorganisation and service integration.

If you would like to learn more about our evaluation, policy or other regulatory consultancy services, please contact us. We’d be pleased to discuss how we can support your work.