Library closures

Written evidence submitted by Simon Gurevitz on behalf of Friends of Preston Library and Preston Community Library (LIB 079)

I am a member of Friends of Preston Library and Preston Community Library in Brent.

· This submission addresses the question "What constitutes a comprehensive and efficient library service for the 21st century".

· Library services are too complex and communities are too diverse for a simple formula to be identified. Instead, a robust methodology for assessing the impact of library closures is offered.

· The approach is consistent with Charteris and has general application. References to Brent, by way of example, are confined to footnotes with the exception of paragraphs 39-45 .

· Following Charteris, it is argued that a clear strategy for library services is essential.

· The strategy should be evidence based and aimed at delivering the identified and valued needs of users.

· As part of the strategy, there should be an implementation plan that shows how services will be maintained for all users, not just those local to surviving libraries.

· In the absence of such information, credibly based, the Secretary of State (SoS) should declare that the strategy is inadequately founded and should not proceed.

· The SoS/dcms may find it useful to establish a panel of experts who could assess Council plans that come under challenge, comparable to Job Evaluation experts who can be called on by Employment Tribunals.

· It should not be for the SoS to probe Council plans from a distance; the onus must fall on Councils to demonstrate that their strategy is evidence based and not simply a cost-reduction program or an ego trip by another name.

· Councils are the providers of library services. Whether these services are comprehensive should primarily be determined by reference to the consumers of these services.

· Efficient should not be reduced to "cheap". It should incorporate whether the users can efficiently access the services.


1. Charteris found that what Wirral Council claimed was an evaluated strategy was not a strategy [1] .

A statement of intent or hope does not constitute a strategy even if a Council chooses to call it such. Improvements in operational effectiveness, which incorporates efficiency, are desirable but are not a substitute for a strategy.

2. A strategy is defined here to be a broad outline of how objectives are to be achieved. The objectives for a library should pertain to meeting the identified and valued needs of the residents; primarily but not exclusively focused on current library users but with provision for attracting non-users. To be effective, the plan for implementation of the strategy should be set out in detail and shown to be viable.

3. In the absence of clear objectives, or if the objectives do not relate to needs that library users value, a plan will suffer from lack of essential direction and will not justify the term "strategy".

4. It should be possible to identify whether a library strategy is successful or failing, both during implementation and subsequently, by establishing criteria and collecting and monitoring the necessary data in a timely manner. If this is not done then there is a risk that failure will neither be identified nor admitted and so corrective action will not be taken.

5. The library strategy, as presented to the public, should provide the supporting, validated evidence on which it is based. If there is no such evidence, or if the evidence or the decision based upon it is shown to be flawed, then the strategy should be withdrawn and a new strategy devised. Resistance to this by a Council should be expected so it is critical that it is made a requirement; otherwise, Councils will be able to act without restraint or penalty.

6. The Secretary of State (SoS) can be called upon to assess whether he is satisfied that, following a closure program, the resulting library service will meet the 1964 Act in advance of the change being implemented and has no independent means of doing so. He has to rely on information provided by the Council. Given that the SoS, as a norm, is reluctant to intervene [2] , given the difficulty in reversing closures and given the detriment suffered by users while an inadequate program is pursued, the responsibility must lay with a Council to demonstrate rather than claim the potential impact of its strategy.

7. Therefore, if the SoS is not to spend his time collecting data from every Council, the onus must be put on Councils to demonstrate that they have done such work as would satisfy the Charteris criteria before instigating a consultation on library closures. The necessary data must have been collected and competently analysed, [3] forecasts of the impact of the strategy made using clearly specified and justified assumptions and tested with sensitivity analysis. Alternatives should be similarly assessed and not brushed aside.

8. Under natural justice, the issue must be resolved in a timely manner. The consequences for a local community are too great to allow undue delay. If a Council is unable to demonstrate that it has done its homework, such as would satisfy Charteris, and, if it is not able to do so immediately, that should suffice to demonstrate that the Council’s intentions are (as yet) unsound. This should lead to the SoS immediately requiring the withdrawal of the plans so that the Council can undertake the necessary research and/or revise its plans. It should not lead to an extensive, time consuming, correspondence. [4] The SoS should be able to call on an expert to quickly assess whether a Council’s strategy and plans are adequately founded.

9. At present, the 1964 Act seems to be a no-go area for the SoS. This means that the public is denied the legal protection which is its right and which can only be accessed via the SoS.


10. Even though comprehensive might primarily be intended to mean the scope of the collection (books, dvds, etc) and facilities (computer terminals, study space, etc), it cannot be divorced from the ability of different sub-groups of the population to access it.  (The British Library in Boston is comprehensive but not very accessible.)  So comprehensive access is an important component of a comprehensive library service.

11 It is not sufficient, therefore, to look only at the assets of the library service to determine if the service is comprehensive. The question of "Comprehensive to Whom" must be addressed. So it is library users, rather than Councils, who are best placed to assess whether the service is comprehensive. The Council may be regarded as the provider, the users as the consumer and it would be normal to ask the consumer about the quality of the service.

12.The withdrawn Public Library Service Standards (PLSS) of June 2008 addressed some of these aspects. PLSS1 used the percentage of households within 1 mile as a prime target. However, distance is really a proxy for cost and time; these are the factors that users consider. [5]

13 PLSS 6 set a target (8,600-7,650) for the number of library visits per 1,000 population. It was explicit in stating that where a library is part of a multi service centre, authorities should count as a library visitor only those who use the library element of the overall provision. [6]

14 Other targets addressed book replenishment rate, electronic access, speed of service e.g. to provide ordered books and overall service standards as assessed by the under 16’s (target, 87% Good+) and over 16’s (target 94% Good+). That is, the views of Under 16’s were viewed as of particular interest.

NB These USER percentages do not capture dissatisfied users who go elsewhere or simply cease usage. [7]

15 It may be thought that these targets are too restrictive given the range of contexts that different Councils serve. But perhaps they may be taken to broadly indicate where a sound service should lay (on those metrics), allowing for any specific features of the catchment area.

16 However, the underlying issue being addressed by the Select Committee is that of library closures. There will, therefore, be a specified change that can be assessed and it is the marginal effect of such a change that is the focus of this submission.

17 There are no significant technological or procedural efficiencies that would indicate a reduction in local libraries. The internet has allowed access to the catalogue, book reservation and reference material but this does not replace the need for libraries. Edinburgh has one of the most developed electronic offerings yet, far from closing libraries, it has continued to open new ones.

18 ebooks may be expected to alter the way books are borrowed but their usage is still small and the most popular eBook, Kindle, is as yet not able to access books on Overdrive, the London Library Consortium eBook system. It is, therefore, premature for a Council’s library strategy to depend on ebooks to deliver any significant volume. [8] [9]

19 Rather, current changes are, in the main, instigated by the need to make financial savings. However, the 1964 Act does not provide for any such escape route. Further, the dcms overtly states that change for primarily financial reasons is not acceptable. This obliges Councils to falsely claim that their change is instigated by more strategic considerations and that any financial benefits are merely incidental.

20 What has to be established is the test by which such changes should be assessed for compliance with the 1964 Act. It is argued here that the factors that should be taken into account are:

Marginal Time and Cost to Users

The Data and Assumptions on which the future library performance forecasts are based

Indicators of Efficiency

Indicators of Comprehensiveness

Implementation Plan

Transition Management

21 In all the above, the quality and accessibility of relevant information is paramount. To allow a Council to prevail by following a legal process using selective, biased data collected via an inept survey just makes a mockery of insisting on an expensive but pointless consultation process.

22 In a London or Metropolitan Council there will be found natural flows of people for non-library purposes such as getting to a station, bus stop or shopping street. Libraries do best when located in close proximity to these natural flows, less well when users are required to make a separate, single-purpose trip. That is because the marginal impact of going to a library located within a natural flow is low in terms of both cost (fares, petrol, parking) and time. Logistics is a further aspect, especially if you are a parent taking children, or have limited mobility due to age or infliction.

23 If such a well-positioned library is closed, users have to contemplate a significantly higher cost that is not effectively indicated by distance alone. A different time slot has to be found instead of popping in on the way home or when shopping. The time and cost of travel are now full cost and not marginal so the relevant distance will most often be from home to the nearest open library. If the travel time is, say, 45 minutes each way then the total time that will have to be found for a library visit is effectively half a day. Aside from some retired people, what percentage of people can conjure up an extra half day?

24 Further, if the service required is study space or access to a terminal and if the facilities in the nearest remaining library are inadequate to restore the space and facilities lost due to closure, users will simply not go to a library as they know their needs are unlikely to be met, irrespective of travel time and cost.

25 The reality is that each of the residual libraries must have the capacity to match the user needs of the increased catchment areas that they are asked to serve. If they cannot do that, users will not go there. And even if the capacity is provided, beyond a certain travel time – which I do not seek to here specify, it could differ according to context – the additional travel time and cost will effect to exclude users from the library service, irrespective of capacity and efficiency measures. [10]

26 So the distance users have to travel to reach a library is an inadequate indicator of the service they receive; far from being a comprehensive service, it may be no service at all. Such a case would constitute a failure of service and a clear breach of the 1964 Act. Neither the SoS nor Councils are currently required to identify such a failure so the Act is effectively unpoliced. In this way, the needs and rights of large tranches of residents can be ignored even while nearby communities receive a satisfactory service.

27 In rural areas the initial context is entirely different, as are both needs and expectations. For example, expected travel times are different and it may be a relatively rare need for a student to travel to a library to find a quiet study space.

28 If the purpose of a library is to advance the education of the public (or similar) then while that role has remained constant the means whereby it is achieved has changed. Consequently, what constitutes comprehensive has changed correspondingly and now includes such as DVD/CD loans, computer terminal usage for both study and access to the internet, non-computer study areas, books in different languages and children’s learning-related activities.

29 Comprehensive should also mean that this offering – or, at least, its core – should be available to all. The 1964 Act does not discriminate against so-called middle class areas. Therefore, the offering should appear comprehensive to users throughout the catchment area. Otherwise, Councils could reduce their libraries so that they could offer a comprehensive service in those that remained while effectively offering nothing to those users who do not live in close proximity. [11]

30 However, all libraries need not offer the same full range of services. This could be uneconomic. It is more important that services should reflect local need. This requires that councils periodically identify and measure or assess local need in order to respond accordingly. A Council that does not do so cannot be deemed to have justified its strategy, as per Charteris. [12]


31 It is also suggested that the question of "Efficient for Whom" be considered. Even if "efficient" is taken to mean 'cheap to run' this must be assessed in terms of metrics such as cost per access, not just cost.  Efficiency is a ratio of outputs to inputs and both must be incorporated into an appropriate measure such as cost per visit, cost per issue and these should be considered along with the impact on the potential user population or efficient could be consistent with a very small User base. That is why a target for users per 1000 population is essential.

32 As indicated above, what might be efficient (cheap) for a Council may be very expensive for a user and could conceal a diminution of absolute service, either in certain ignored areas or across the catchment area. That is, dysfunctional behavior [13] may not be identified by cost ratios alone.

33 Councils should be required to produce all relevant efficiency ratios, including cost per visit, cost per issue, cost per hour opened, etc. The PLSS definition of what constitutes a valid visit for this purpose is still valid and should be a required method. Such ratios have relevance but only as part of a wider canvas of information and so long as there is the ability to interpret in a non-trivial way. For example, some libraries may offer a greater range of IT support to users and this could appear to reduce efficiency. [14]

34 Where, as indicated above, users are excluded from a library by reason of cost and or time, that is because the library service is not efficient from their perspective.

35 A library strategy involving closures should be required to include details of its transition plan. The necessary capacities for each service should be maintained throughout so that closures are not allowed before the replacement services are in place. The lost capacities should be specified, by library, and the new capacities specified by replacement library, not simply as a grand total for the borough; otherwise the new capacities could be in the wrong place.

36 Forecasts of usage and capacities must be presented and an effective means of monitoring specified and followed such that if the forecast effects are not realized – or can be shown to be unachievable - the strategy can be revised to recover the situation. This is necessary so that Councils cannot simply specify intent and call it a strategy (see Charteris) and so that users do not find themselves with an irreversible, inadequate service manifestly not consistent with the 1964 Act and which would never have been accepted had it been accurately forecast. [15]

37 A community, by definition, applies to a group of people in a geographical area who cohere such as to obtain the benefits of support and camaraderie and avoid the worst of isolation and loneliness. Where are they to meet to achieve this coherence beyond places of worship? A library serves such a function e.g. with children’s reading circles, as does a local shopping parade where neighbours can be met without prior arrangement.

38 The removal of local libraries means that these opportunities are lost. Travel to a further library may not be possible for those most in need and, even if it is possible, the new, enlarged community cannot fulfill the same function; those whom you meet may not live nearby.

39 The argument and proposals above have general applicability. So although not conceived specifically for Brent they can legitimately be applied there. On the basis of the information provided in the footnotes it is evident that Brent has not complied with even one "good practice". There is no needs-based strategy, no forecast, no adequate transition or implementation plan and no means of determining failure.

40 As in the Wirral case, the simultaneous closure of half of Brent's libraries will lead to a clear failure to provide a comprehensive and efficient Library Service to local people.


41 Preston & Kilburn Libraries: A Comparison

Preston Kilburn

Cost (£k)* 186 252

Issues 90,000 67,000

Visits 97,000 103,000

Cost/Issue 2.01 3.76

Cost/Visit 1.92 2.45

Issues/100 Visits 93 65

Visits/Squ Mtr 388 166

Costs used are Staff +Premises costs taken from the Brent’s Final Report on the Library Project, P140 and P17.

42 Preston is more efficient than Kilburn on every metric except raw Visits (which is the most problematic metric and is not an efficiency measure) and even here the difference is modest. Yet Preston is to close and Kilburn remain. The selection of Kilburn is based on the alleged greater presence there of the old, young and disabled; criteria that only appeared in the final report. But the "supporting" data Brent published was in the form of density maps with no legend and no means of grossing up even had a legend been provided. So the difference between Kilburn and Preston on these criteria remains unknown.

43 However, Brent published an earlier library strategy in 2008. In that document, the proportion of library users in these categories is clearly given in a bar chart form. In each case (under 16, over 65 and disabled) Preston comes second highest with Kilburn well behind. So Brent has perversely chosen to disadvantage the very users it claims to wish to service in order to offer a service to non-users elsewhere.

44 It seems impossible to conclude that Brent is offering a library service which is either comprehensive, efficient, equitable or non-discriminatory. Is this not what the Act is designed to prevent?

45 I ask, therefore, that your Committee recommend to the Secretary of State that he hold a Public Inquiry into Brent Council's decision and that all Brent’s libraries and their facilities be restored until the outcome is known.

January 2012

[1] Logic was found to be absent or unsound.

[1] Needs were inadequately measured although Wirral Council claimed to have done so.



[2] “The Secretary of State will always wish, where possible, to use ways other than a formal inquiry in exercising his statutory obligations.”  (M Hodge, 30 November, 2009)

[3] At present it is too easy for Councils to table a false audit trail as a substitute for analysis. For example, an extensive tick list that purports to demonstrate that an Equal Opportunities Impact analysis has been conducted only demonstrates extensive ticking. There may be no evidence of the analysis that should have preceded the ticks.

[4] This is the case with the Brent Library Transformation (=Closure) Project.

[5] Brent Council has not provided even one metric for either comprehensiveness or efficiency. There are no forecasts of any kind. Brent claims that after closing 6 libraries usage will increase; they do not state how or by when.

[6] Brent Council repeatedly declined to allow for non-library visits e.g. to toilets or to administrative offices.

[7] The only research conducted by Brent consisted of focus groups from which it is not possible to isolate the findings for Under 16s or Over 65s.

[8] Almost all publishers in the US now block access to the ebook editions of either all their titles or the most popular ones. On Nov 21, 2011 Penguin Books US pulled e-books from libraries making them non-available through Kindle.

[9] Brent Council's libraries' Transformation Project leans heavily on the new ' Virtual library' which is planned for the new Super-library' which 'customers will be able to access from the comfort of their own home'. Many of the most needy 'customers' do not possess computers or e-readers. There is no evidence that any of the problems encountered in the 'Libraries Versus Publishers' debacle have been adequately considered. It is understood that the Head of Libraries and her deputy are Archivists, not trained librarians.

[10] Brent’s closures were originally scheduled to take place in June 2011. At the eleventh hour, in response to a plea by the Brent Youth Parliament, they agreed to delay until after A-levels as there was insufficient study space in the remaining libraries. This demonstrates the inadequacy of Brent’s plans and an unwillingness to forecast lest they discover something detrimental to their intent. Kingsbury, the nearest library to Preston, has no room to expand.

[11] This is the case in Brent where those near the remaining libraries may receive a good service while those who live near the closed libraries receive a poor service or none at all.

[12] It is perverse to set as an objective the immediate introduction of a standardized “offering” in a multipurpose building (hub). The needs of residents may differ, especially where there are ethnic communities geographically clustered and such a dogmatic stance discards, without evaluation, all other means of providing the desired services.

[13] A Council could deliberately reduce its number of libraries in order to produce good efficiency ratios from the surviving libraries, conveniently ignoring the lack of service elsewhere.

[14] Brent Council’s Library Transformation Project was predicated on only one metric, cost per visit and offered no forecast of efficiency.

[15] Brent Council has closed six out of its 12 libraries without demonstrating, even as an optimistic forecast, how it will provide service capacity where it is needed. Its one piece of research identified a need for more terminals and more study space. Perversely, both of these have been decimated by the closures. It has since been announced that Willesden Library, the largest in the south of the borough, will be closed for 18 months for a total rebuild. It is difficult to see how service capacity can be sustained in these circumstances.

Prepared 6th February 2012