You asked for my views…
Mark Hourahane, Vice Chair of New Folkestone Society responded in a personal capacity to the KCC consultation on their proposals to close Folkestone Library. He gave us permission to reproduce his comments here.
Introductory comments
You have a responsibility to 2 Grace Hill as a Grade II listed building, which you have failed to maintain in good order. You have a responsibility per your Asset Management Strategy to keep the building “safe, warm, dry and proactively compliant”; you have failed on every count (and your management team forgets the proactively compliant part when reminding people the building has to be “warm, safe and dry”).
A historic library
This is the oldest purpose-built library in Kent that it still “open” (used loosely), which has a Carnegie-funded extension (quite a rarity in itself) opened in 1910. It features in H G Wells’ Kipps, had an early lecture on the theory of television with practical experiments and hosted a women-only talk by Elizabeth Macadam, billed as the Secretary of NUSEC (the Suffragists), but she had also helped create the first Government training schemes for social workers. Not to mention other celebrity visits, such as Terry Nation (creator of the Daleks), Loyd Grossman and Millicent Martin (who featured in an episode of Moon and Son shot in the library). It has considerable intangible cultural heritage that should be celebrated and advertised, and indeed its location was carefully selected to be of benefit to the townsfolk. Kipps was not set in Folca – move out of the building and the town (and KCC) loses that intangible cultural heritage asset.
Investment in opportunity
Other libraries have had multi-million Pound regeneration schemes in the past 15 years such as the Dover Discovery Centre, the Amelia Scott Centre in Tunbridge Wells, the Beaney in Canterbury and Herne Bay library. When I visited Dover library, the staff told me they weren’t sure why the Discovery Centre needed refurbishment! Conversely, Folkestone library has had issues with the gutter and roof since at least 2018. KCC is sadly unwilling to consider a reimagining of Folkestone library as a community hub; whilst this would undoubtedly cost more than simply fixing the leak, more funding would have been available such as the Libraries Improvement Fund and potentially the National Lottery Heritage Fund, National Lottery Community Fund and Arts Council grants.
An ambitious project might even have considered purchasing the land behind the library when it was for sale and extending so there is an entrance at street level opposite F51 skate park. This would have better linked the library with the sporting community as well as the nearby Folkestone Bookshop and Quarterhouse… plus the opportunity to bypass the steep hill would have been attractive, bringing more people through the door! Grace Hill is an exciting location between the town centre, Creative Quarter and some of the most deprived wards in Kent, plus the Bus Station is moving nearer to Grace Hill as part of the (now not called!) Levelling Up scheme, so it makes sense to retain it there. You have failed to take into account the happenings around the library, as evidenced by your inaccurate map (figure 1) showing the current Bus Station location. This is not where buses will operate when the library is reopened.
Neglect & a legacy of poor maintenance
Your properties team has shown repeated disregard for procedures to maintain a Listed building, including installing Perspex sheets on the windows without Listed Building Consent, followed by the installation of CCTV without LBC. Stains from the 2018 leak were still visible in the former museum when the building closed. And indeed the Heritage Room remained open to the public when water was dripping into buckets in the corner in 2018, yet we are told the library had to close immediately due to safety concerns. Except it wasn’t immediately, it was the end of the day (and members of the public remained in the building when men in Hazmat suits were allowed to inspect the building, which was quite alarming to them). It is highly amusing that you now try to tell us that you have to think about every minute detail in the building “because of the listing” when you have never shown any regard for its heritage features in the past. You state that: “We are continuing to survey and monitor the building to protect it as a historic, listed building.” Monitoring does not protect – action based on what is observed does. You have taken no action; in fact, your properties team leader admitted to me that you have turned the heating off and vacated the building, which does the opposite of protecting it.
I find it hard to believe the estimated costs of restoration of 2 Grace Hill have gone up by £1.1 million in a year. It appears, however, that KCC admits culpability for this as they have turned off the heating and dehumidifiers they were running in the building, effectively leaving it to rot. This blatant disregard for a Listed building should not be allowed, nor should KCC be able to walk away from the situation without any repercussions. The list has elements that are not necessary to achieve “warm, safe and dry” status – I highly doubt that 113 windows need repair or replacement, for example… and I am puzzled as to which 86 of these need redecorating, or how it costs £38,700 to paint 86 windows – the numbers don’t appear to add up as you cannot get a number ending in 6 out of items 4.1 to 4.5 and I would expect new windows to be supplied pre-decorated, leaving only 53 casements. No contractor has been approached for quotation, so this surveyor’s estimate may not be accurate. Indeed, suggesting that there are 24 external doors that need to be stripped and redecorated loses all credibility in the document – there are nowhere near 24 external doors on the building. The front doors certainly don’t appear to be in a condition that would warrant having £1,500 spent on them. I cannot believe that the cost of repairs to get the building warm, safe and dry would be £2.9 million.
A flawed proposal to relocate
Conversely, the assumption that it would cost £150,000 to £200,000 to move into Folca seems incredibly low. If you are going to move out of Grace Hill, we would require evidence that the Local
Studies Collection will be correctly stored and available in full to the public, not only part of it as is currently the case at the temporary Hub. If items have to be stored in the stack, they should be fully catalogued, accessible to staff and there should be a suitable number of staff for a member of the public to be able to request an item from the stack at any time. I do not believe this has been factored into the cost. Furthermore, the base rate for rateable values in the pedestrian precinct is likely to be higher than in Grace Hill.
It’s good to talk… so why is KCC so reticent?
Furthermore, members of the Save Our Library group reached out to KCC Officers, requesting to meet to discuss the matter and see if there was a way we could potentially help. We had tradesmen willing to work for cost and members of the public willing to volunteer wherever they might be of service, e.g. picking up a paintbrush, moving furniture etc. The Officers refused our requests for a meeting.
Considerable feedback has been received from the community wanting the library retained and reopened at Grace Hill, including a petition. This has been ignored by KCC.
Closing Grace Hill also means Folkestone loses its largest art gallery, which is a significant space that was very popular prior to the pandemic with its calendar often booked out a year in advance. Since the pandemic, however, it has been poorly advertised and somewhat underutilised – much more could be made of it. It is criminal that KCC has such scant regard for the arts scene in Folkestone that they would deprive us of our only major gallery space and two pieces of art by major artists. Skyladder is not just words – it is the physical installation, whether they be painted or stuck on the wall. It is impossible to remove it from the wall without damage.
Economical with the truth?
It is clear to me that KCC has given as high an estimate as possible for the repairs to the building, fuelled by years of neglect and lack of maintenance since library maintenance was passed to a properties team in 2011 (presumably when Folkestone library stopped having a caretaker to maintain the building), plus as low an estimate plucked out of the air for moving into Folca as possible in order to make Grace Hill look unattractive and Folca attractive. It does not work.
Despite your claims, no agreement has been made to move into Folca and Folkestone & Hythe District Council want the library to remain at 2 Grace Hill. If the owner of the building does not consider it suitable, it is not an option and should not be presented as the favoured one. The building is old and in need of serious renovations, which will take a long time – leaving us without a library probably for years. It would seem that KCC Officers don’t want the overheads of owning a building and doesn’t care that someone else will have a huge restoration cost, as long as it isn’t them. Unfortunately, as it is owned by another Council, it is the taxpayer who ultimately foots the bill.
KCC appears to place great value in being on the pedestrian precinct yet has presented no evidence that an increased footfall past the door will mean an increase in library visits. In fact, the shared nature of the building will mean the library has far less visual presence on the precinct than it does in its current large, distinctive building. When the Save Our Library team canvassed people attending the Folke About Town food festival in front of the Folca building, many of them said they had no interest in libraries. Being in Folca does nothing to draw those people into the library. It is curious you take this stance when you admit that it is the ninth most-visited library in Kent!
Were the library to move into Folca, it would be more appropriate that Folkestone and Hythe District Council has bookable meeting rooms. It is not for KCC to sub-let the space, and this seems an inappropriate suggestion. Sorry – if you don’t own the building, you don’t get to charge people to use the space! Speaking of hiring out space, how much did you get from letting the Government use 2 Grace Hill as a Covid testing centre and what happened to that money? If it didn’t go towards repairing the building, why not?
Public service: could try harder….
It is incredibly concerning that there is only one mention of the Local Studies Collection being included in the proposed Folca relocation on page 12. It is NOT mentioned in the space section on page 14! There is no guarantee that it would be the full collection, nor that it would remain in Folkestone. Members of staff have told me that parts of it were sent to Canterbury and Dover libraries because they had Canterbury and Dover in their titles. Not only should these documents not have been removed from Folkestone, where they were useful (the respective libraries already had copies), but this is actually untrue as confirmed by staff at Canterbury library – they have not received a single item from Folkestone since it closed. There is no assurance that access will be restored to unavailable items such as the hardcopy newspapers. These are so much more convenient and easier to read than a microfilm screen and there is only one provided in the Hub, meaning only one person may look at anything from the newspaper collection at once. This is unacceptable. It was a waste of money having the items microfilmed – why not have them scanned at Maidstone so they could have been accessed on the computer network, with several users having access at once?
Whilst 5 Grace Hill has been a reasonable temporary provision, it would be unsuited to permanent use. The full library service cannot be run from there and should not be separated from the Local Studies Collection. The hours of operation have been less than those Grace Hill enjoyed, which is far from ideal. In fact, it is almost inaccessible to anyone who works a 9 to 5 job (or 9.30 to 5.30) – it opens at 9.30am, closes for lunch and is fully closed by 4.30pm! Whilst Folkestone Library was one of only four to open on Sundays, the Hub is not. This leaves only Saturdays with a pathetically short 9.30am to 1pm opening time. For shop workers, Saturdays are busy so they may not be able to use the facility at all. Redistributing hours (and staff) to Hythe (5 miles from Grace Hill), Cheriton (2 miles) and Wood Avenue (1 mile) libraries is inadequate as this puts considerable inconvenience on the user, especially if they live in the town centre. This might even result in a user having to travel to multiple libraries in order to access the services usually available to them in a single visit to 2 Grace Hill!
There are no other KCC buildings in Folkestone that I am aware of that are empty and suitable for housing the entire library provision.
As for an alternative town centre location, you have had almost two years to find one. You failed to find another space to temporarily relocate the contents of the Heritage Room for almost a year, despite there being several empty shops in the pedestrian precinct. If they are not suitable for a smaller provision, how are they suitable for the full library service? There is no alternative location, so this option is misleading.
Looking a gift horse in the mouth….
It would seem the option to offer Creative Folkestone a lease on the building, thus saving it and allowing the library to remain on one floor, would have been viable. Sadly, KCC stalled on this and now suggest that the Asset of Community Value status scuppered that option. This is false and it is shameful that KCC would put such misleading information in the document. The Community Right to Bid is only triggered if KCC informs Folkestone & Hythe District Council of their intent to sell the building or lease it for 25 years or more. As grants usually require around 20-22 years remaining on a lease, you could easily have made it a 24-year leasehold without having to trigger the CRB. I am puzzled as to why KCC states they would like to co-locate with other community services yet turned their noses up at such an opportunity in their own building, which would have had no moving costs!
None of the alternative options have been fully costed, so it is inappropriate to be consulting on them at this stage.
As mentioned previously, the Save Our Library team tried to speak to you about other options for 2 Grace Hill, but you refused to talk to us. This included offers from local professionals willing to give their time in order to save the library. KCC has knowingly been negligent to a Listed building and the excuse of not having the funds is irrelevant where people have been willing to contribute to the restoration for free.
Knowing the cost of everything and the value of nothing…..
It is incredibly disappointing that you gave a single paragraph – just two sentences – on the history of the building…. and one of those sentences was wrong! The Carnegie section is an extension NOT the original building. You failed to mention its heritage significance, including the Kipps connection and it being the oldest purpose-built library in Kent. Why did you not use your own archive to do even a modicum of research?
The value of the library – both the building and the service – should not be measured in monetary terms and statistics. Its use as a Warm Space is invaluable to many locals, particularly in the neighbouring deprived wards. Many use the computer terminals to access the Internet – the computer provision at the Hub is greatly reduced from that previously on offer at 2 Grace Hill. As I previously mentioned, the Sunday opening may not have had the footfall of weekdays, but it was a vital service to people who work full-time. Those users are now unable to visit any library in Folkestone. Your temporary provision has been wholly inadequate, not “comprehensive and efficient” as required by the Libraries Act 1964.
This consultation fails to give adequate information in that there is an option for an unspecified alternative location and not all options have been fully costed. I also believe that the Equalities Impact Assessment is inadequate, as you will see in the next question. This consultation has also been weighted in favour of your preferred option – you don’t ask the correct questions regarding our preferred option!
Consequently, I believe that KCC is in breach of the Libraries Act 1964. Per the Government’s advice at https://www.gov.uk/government/publications/guidance-on-libraries-as-a-statutory-service/libraries-as-a-statutory-service, I am responding to your consultation and informing you that I believe you are in breach of your duties (see “What to do if I think a council is in breach of the Act”).
I hope that the results of this consultation will be given proper consideration, unlike the petition and other KCC consultations such as the Cheriton Active Travel scheme, which had 73% of respondents in opposition yet it is currently near completion. Likewise, the windmills survey saw 87% of 2,300 respondents say no to selling off the windmills… yet you are now selling off the windmills. In fact, a KCC staff members running the recent Transport Survey in Folkestone was heard saying that it was “just to answer people’s questions” as “the decisions have already been made.” Treating consultations as a tick-box exercise to say you engaged with the public is undemocratic.
I am also concerned that your policy documents have expired. The Libraries, Registration and Archives Strategy 2019-2022 is now two years out of date and your “Asset Management Strategy – A Five-Year Plan 2018 – 2023” is now a year past expiry. Why have these not been replaced with new strategies?
Consequently, I shall be having discussions with the rest of the Save Our Library group about submitting a representation to the Secretary of State.
Equality is not about making a token gesture: it actually matters.
The EqIA is inadequate as it only assesses your preferred option. It should assess every option and the equality impact should have been given weight in assessing each option in the main document.
The EqIA suggests that “there are some limited adverse equality impacts associated with locating town centre library provision at the FOLCA (sic) on the high street (sic), compared with the Grace Hill building” and that these can be “appropriately mitigated”. However, it considers these “justified” as there are positive impacts and “the service-related, financial, deliverability, and environmental considerations”. The service is being downgraded if you leave 2 Grace Hill, so there are no benefits there. There are no financial benefits to the public, only to KCC, so this is not an acceptable consideration. Deliverability has not been proven in Folca (not “the FOLCA”). And I see no public environmental benefits in moving from one old, poorly-maintained building to another. In fact, Folca has cracks you could put your entire hand in and the basement is forming its own swimming pool, albeit with a foul smell… probably more a biohazard! I find it highly inappropriate that any of these points would be considered to justify negative equality impacts.
Moving the split services back into one building could be done in Grace Hill – it is not something unique to Folca. Therefore, it is not appropriate to consider it a positive impact of this option. Likewise, co-location is possible in 2 Grace Hill, as is computer provision, meetings and provision of the Births, Deaths and Marriages department. They were all provided at 2 Grace Hill previously!
Specialist book stock is available at any library – indeed, it was already available at Grace Hill. It is a complete nonsense to suggest that a “town centre location” (by which you mean pedestrian precinct) has anything to do with the availability of books for disabled, foreign or LGBTQIA+ people. As someone who has a disability, I am offended that you would dare to insult my intelligence like that.
Moving to Folca (which isn’t on the “high street”), is not closer to public transport links. There is a bus stop in Shellons Street, less than 100 metres from 2 Grace Hill and another outside F51, approximately 175 metres away (albeit down a hill). The front door of Folca is 200 metres from the Bus Station and even the side door is 110 metres away. Furthermore, the bus station is moving closer to Grace Hill as part of the (no longer called!) Levelling Up scheme, which will mean the front door of Folca is approximately 250-300 metres from the bus stops. This EqIA has failed to consider what public transport provision will look like at the time of reopening, and for the considerable future. The bus station moving closer will not only make Grace Hill more accessible, but more central and relevant.
There may be disabled users who are unable to walk long distances who will not only be impacted if they have to walk uphill, but by the longer walk. Not everyone is able to afford public transport or indeed is eligible for a free bus pass, plus some prefer to drive. I myself am often unable to walk long distances – even ignoring hills, it is worth considering extra walking distances. I would never use the Bouverie Place NCP car park as it is expensive, which leaves Shellons Street, Foresters Way and Upper Payers Park car parks… plus the APCOA car park in Middelburg Square, which is cheap. However, some might be discouraged by its somewhat secluded nature. At the moment, I can walk 65 metres from Foresters way car park to 2 Grace Hill, 100 metres from Payers Park or 190 metres from Shellons Street. These are 550 metres, 350 metres and 400 metres respectively from Folca’s front door. Middelburg Square is 300 metres from Folca’s front door and 350 metres from 2 Grace Hill. So Grace Hill is considerably closer to all three Council car parks than Folca. And of course some will walk from home and face increased journey times. Indeed, walking up the hill from Grace Hill is awkward as there are few places to stop and sit en route.
The mitigation suggested is laughable. For example, there is an admission that Folca is uphill from the Grace Hill area, so those living there would have to walk uphill. The mitigating action for this negative impact is that “FOLCA is (in) a more central town centre location than the Grace Hill building”. That’s not a mitigating action! Nor is suggesting people use the other libraries, for which you still have to go in the same direction! And saying people can just use your online services is despicable – many people cannot afford to do so, and it is nowhere near the same as the full offer in libraries. The Home Library service is an alternative to visiting the library, certainly, but cuts out the social interaction and being able to use many of the facilities. Again, this is not mitigation. The statement that “the existing building at 2 Grace Hill does have accessibility challenges which it is expected can be improved upon at FOLCA” is not helpful, as it does not describe the challenges nor how they will be mitigated. This EqIA fails to explain mitigation at all.
How on earth does “providing a social story” help provide familiarity? You could have said that a virtual tour will be made available online, as happened at other libraries. That would be more helpful.
You state there are no negative impacts for trans people. If memory serves, Grace Hill has a single toilet (there may possibly be a male and a female, but I seem to recall it being a single lockable cubicle per ‘user’ as opposed to a single sex bathroom with multiple urinals / cubicles). What will the provision be at Folca? Will there not be an impact if it’s a shared male and shared female bathroom? This might make a trans person feel uncomfortable. Might they feel more intimidated also if the area is more populated?
Likewise, you state there are no negative impacts for carers. If they are helping someone walk uphill to Folca, or indeed pushing a wheelchair, it might impact them. I knew someone who suddenly became wheelchair-bound and his wife struggled to push him up that hill. I struggled to push him up that hill, in fact!
Per point i of agenda item 115 of the Policies and Resources Cabinet Committee meeting of 23 November 2022: “officers approving decision paperwork should undertake mandatory training highlighting the importance of considering equalities implications”. I did ask whether the person who wrote the EqIA was qualified at one of the drop-in sessions and got sheepish looks but no answer. Are they? I would suggest not, considering the above. Suggesting that services that were already available in Grace Hill being reintroduced are positives of moving into Folca is shameful.
I do not believe that your EqIA is adequate and will be suggesting this is mentioned to the Secretary of State.
