All the reasons you should intervene, Dear Secretary of State

This blog post includes the text of:

A) Press Statement B) Letter from Maurice Nauta to the Secretary of State 

Also included within the letter, as attachments for download:

– Tim Coates Submission 
– Witness Statement to the 2014 Judicial Review – Councillor Karen Lee 
– Assistant Head, Wendy Carrick’s, Statement – April 2015
– Lincoln City Council – Evidence of Poverty in Lincoln: 2011


Former Head of Lincolnshire Libraries, Maurice Nauta, a leading figure in the Save Lincolnshire Libraries campaign, has responded to the Secretary of State for Culture who, by means of a letter to Councillor Hill dated 26th March, notified that a ‘provisional’ decision not to intervene has been taken. (Read more on this here: #WritetoVaizey)

Because the decision is provisional, intervention from the Secretary of State has not yet been ruled out. Maurice, as the complainant, was therefore asked to respond with further evidence to support his claim that the Secretary of State should intervene. The additional information, which is – to the best of his knowledge – accurate and compelling, is set out in a formal letter that was delivered to the Secretary of State at the Department of Culture, Media and Sport on the 23rd of April.

It includes reference to the areas of highest deprivation in Lincolnshire, where a proportion of the public libraries facing closure (or relegation to what the council describes as ‘Tier-3’ status) are located. Maurice also supplies further data on all the threatened libraries which, he believes, supports the contention that access for many to a public library will be rendered very difficult or impossible under the council’s proposals, with particular reference to journey-times.

Tim Coates, former Managing Director of Waterstones and a prominent advocate for libraries, has provided a submission in support which accompanies the letter. In it Mr Coates analyses the council’s proposals and suggests that they fail to meet statutory requirements.

Other pertinent information is also supplied which, it is hoped, will assist the Secretary of State’s understanding and lead him to determine that an Inquiry is appropriate. We emphasise that Maurice’s letter includes considerably more detail and legal argument than that mentioned above.

Citing all the new arguments and evidence he has presented, Maurice concludes his letter by urging the Secretary of State to reconsider his provisional decision and requests that a Local Inquiry be launched.

We take the opportunity here to salute the 900 Lincolnshire residents who bore testimony as to how the changes to library provision will materially affect them. These statements are recorded on our website. We trust they will be pleased to note that a small selection of these features in the letter to the Secretary of State.


You can download the letter as a PDF here Maurice Nauta Dear Secretary of State – Letter April 2015 or read it below:

To The Rt Hon Sajid Javid MP, Secretary of State, 22nd April 2015

Dear Mr Sajid Javid

Request for local inquiry into library provision in Lincolnshire (Ref: CMS 264190/asg)

I refer to the letter of 26th March from the Culture Minister to Councillor Hill of Lincolnshire County Council (to whom a copy of this letter has been sent), in which the Minister has advised on your behalf that in context of your powers of investigation and intervention under the Public Libraries and Museums Act 1964 (‘the 1964 Act’), and given the information available to you at the time, you are not currently minded to intervene in Lincolnshire.

You have requested that I respond with further evidence, the provision of which is the purpose of this Letter.

Your Department will be aware that, on the 20th inst. I submitted a request under the Freedom of Information Act, asking for details about how your Provisional Decision was reached.

The criteria for DCMS Interventions are based on an “analysis of existing and projected local need for the public library service” which “may include matters such as deprivation indices, rural/urban context, and consideration of vulnerable groups such as the unemployed, elderly, disabled, children and young people, and young families.”
Source: – What We Do: Libraries

I set out below additional evidence to support my case that decisions under way for the restructure of public library provision in Lincolnshire are in breach of the County Council’s duty to provide a comprehensive and efficient library service pursuant to Section 7 of the 1964 Act (interpreted in light of the Human Rights Act 1998 (‘the 1998 Act’) and Article 2 of the First Protocol to the European Convention on Human Rights – Right to Education).


It is clear from the Wirral Report and from Ed Vaizey’s Early Day Motion (Jan 2009) that two of the 15 libraries marked for closure by Wirral council served “two of the most disadvantaged communities in the UK”.  Ed Vaizey called the closures “cost-driven vandalism”.   It is also clear, from the Church Urban Fund Parish Profiles and from campaigners’ own research that significant areas of deprivation exist in England.

The Welsh government has recognised the particular need for libraries in deprived areas by making available £2.7m of Welsh government funding to help ensure they are accessible to all, particularly to those from more deprived areas.  Source: BBC News Wales – Help for museum and library access in Wales: 17th April 2015

I draw your attention hereunder to deprived areas in the county of Lincolnshire, specifically those whose libraries are earmarked for closure or relegation to ‘Tier-3’ status.


The ‘Most deprived’ quartile is shown in bold type.  Ranking is out of 12,660 where 1 is least deprived.  The following libraries fall into areas of the ‘Most deprived’ quartile:
Source: The Church Urban Fund Parish Profiles
Additional Source:  Campaigner contact made with primary schools affected by changes to accessible library provision.

Alford Library  LN13 9AF – 10603
Contact with Alford Primary School has elicited the following:
The school has a room with books for its pupils, but it is not staffed by a school librarian.  The school and pupils rely on Alford Library. They are regularly taken to Story Time sessions.  The children rely on the public library to borrow books.
The John Spendluffe Technology College is also located in Alford.  They have advised that approximately a quarter of their c.500 students are resident in Alford, whilst others attend from further afield.

Birchwood Library LN6 ONL – 10084
Contact with Birchwood Junior School has elicited the following:
This school serves 270 local children.  The public library is situated on the school site.  The school itself has No school library.  Classes are taken to the public library once a week, accompanied by a teacher, to borrow books.

Boultham Library  LN6 7ST – 11217
Contact with the Sir Francis Hill Community Primary School, which is but one school of several located near Boultham Library, has elicited the following:
This school serves 433 children.  The school has a small room with some books, but no Librarian.  As recently as just before the recent half-term holiday, six classes were accompanied by teachers to attend Story Time at the public library and to borrow books.

Bracebridge Library  LN5 8PE – 10311 
Recent contact with Bracebridge Infant & Nursery School – which has 120 children enrolled – has elicited a dismaying response.  They deeply regret that since Bracebridge Library had its hours reduced, the school can no longer take pupils to Story Times nor to borrow books as it regularly did in the past.

Ermine Library  LN2 2BT – 12039
Recent contact with the Our Lady of Lincoln Catholic Primary School, Ermine, has elicited the following:
There are numerous schools in the Ermine area, but this one is located close to the public library.  We were unable to learn whether pupils rely on Ermine Library, as the individual responsible was unavailable – but it was confirmed that this area, in the North of the city, is significantly ‘deprived’.

Kirton Library  PE20 1EF – 10235
Contact with Kirton Primary School has elicited the following information:
There are currently 450 pupils enrolled, but we are told that this number will increase during the next 3 or 4 years.  The school has a small in-house library, but no Librarian.  The public library and primary school are located in this small village outside Boston.  Pupils are all residents of the village.  The school takes children, from time to time, to attend Story Time sessions at the local library.

Long Sutton Library PE12 9BN – 9169
This area is in the second quartile, but is very close to ‘most deprived’
Contact with Long Sutton Primary has elicited the following:
There are c.380 children enrolled.  Staff “regularly” accompany groups of between 10 and 20 children to the public library to familiarise themselves with it and to borrow books.

Spilsby Library  PE23 5ED – 10207
Contact with Spilsby Primary School has elicted the following:
This primary school has 187 pupils.  Two classes are taken every week to the public library, accompanied by a teacher.  No class is left out of this arrangement.  The school has a very small in-house library, but no Librarian.
‘Eresby Special School’ in Spilsby was unwilling to discuss its activities over the telephone.  However, one could assume that Special School pupils might have a particular need for access to their local public library.

Sutton Bridge Library PE12 9SA – 10829 
Sutton Bridge is one of South Holland’s smaller towns, lying to the east of the district.  It is a small but busy port.  To my knowledge, the Westmere Community Primary School is the school located nearest this public library.  Contact with the school is pending.

Wainfleet Library PE24 4DL 11621
The Wainfleet Magdalen Church of England/Methodist School, Skegness, has 200 pupils from 4-11 years of age.  Contact with the school is pending.


Councillor Karen Lee said in her witness statement to the 2014 Judicial Review:

“Around 10,000 Lincoln residents live in areas that are considered to be deprived. One in five people earn less than £10,016 per annum.”

PDF of this statement here: Witness Statement Karen Lee


According to Lincoln City Council’s 2011 Report:

“Around 10,000 Lincoln residents live in areas that are considered to be deprived.  One in five people earn less than £10,016 per annum. Child poverty is particularly high in Glebe ward – 33% (Adjacent to Ermine library); Moorland – 30.9% (adjacent to Boultham library);  Birchwood – 30.4% ( Birchwood library).” Source: Lincoln City Council – Evidence of Poverty in Lincoln 2011. Please note that a copy of the original document is enclosed.

All of those libraries are scheduled for closure or relegation to Tier-3 status.

PDF of this report here: Evidence of Poverty in Lincoln – Lincoln City Council


I have addressed, above, the issue of there being significant numbers of primary school children who will be affected by changes to Library provision, with particular reference to those in Areas of High Deprivation. This, however, ignores the playgroups, nurseries and secondary and primary school students who live in proximity to all 34 (thirty-four) libraries affected by the proposed changes in provision. Their inability to access a professional service locally is likely to impact, similarly, on their happiness, wellbeing, education and literacy.

Many economically disadvantaged people do not even think about buying a computer, much less paying for expensive internet access or buying a mobile phone and accompanying plan, but they can use the public computers in their local library.  So, I believe it is also relevant for the Secretary of State to note that:  “People in the least deprived areas (48.7%) have almost double the digital participation rate of people in the most deprived areas (24.5%)”
Source: DCMS Taking Part Survey


Data in the Tables below is extrapolated from a Report  published in 2012.

The Secretary of State may conclude that significant numbers of Lincolnshire residents already travel for more than 30 minutes, just to reach the libraries that are currently under threat of relegation to Tier-3 status or closure .  Journeys to ‘hubs’ will take considerably longer or be impossible for some users.  This data also suggests that, in many of these small towns and villages, a significant number of users live locally and rely on the library that they can reach on foot.

“Access to libraries to a quarter of Lincolnshire’s population will fall outside a 30-minutes travel time by public transport”
Data Source:  Lincolnshire Research Observatory | Initial Analysis of Lincolnshire’s Library Service: Sept 2012
Building Drive Time and Travel Time Using Public Transport Catchment Areas – p.7
Table – p.51 Lincolnshire County Council, Revised Library Proposals


For ease of comprehension, the data is displayed in two Tables, below:

Data source:  The 2012 Lincolnshire Research Observatory Report, cited above

Table 1 – Tier-3 Libraries in Areas of High Deprivation (2012 figures)

LINCOLNSHIRE  Tier-3 Libraries in Areas of High Deprivation Total Active Borrowers (2012) Within 30 minutes Travel Time %
Alford 1708 634 37%
Birchwood 2858 471 16%
Boultham 2807 2354 84%
Bracebridge 464 433 93%
Ermine 2813 2632 94%
Kirton 1351 931 69%
Long Sutton 1900 56 3%
Spilsby 1448 746 52%
Sutton Bridge Volunteer-run since March 2012
Wainfleet 663 472 71%

Table 2 – The Remaining Twenty-four Tier-3 Libraries (2012 figures)

LINCOLNSHIRE  The remaining 24 Tier-3 Libraries Total Active Borrowers (2012) Within 30 minutes Travel Time %
Bracebridge Heath 750 686 91%
Branston 1723 1374 80%
Burgh-le-Marsh 466 378 81%
Tier-3 Libraries (cont’d) Total Active Borrowers (2012) Within 30 minutes Travel Time %
Caistor 1370 658 48%
Cherry Willingham 1023 982 96%
Coningsby 1475 460 31%
Crowland 940 788 84%
Deepings 2766 1873 68%
Donington 910 657 72%
Holbeach 2495 211 8%
Keelby 456 306 67%
Metheringham 967 126 13%
Nettleham 1756 1499 85%
North Hykeham 2859 1702 60%
Pinchbeck 308 266 86%
Ruskington 1033 942 91%
Saxilby 980 767 78%
Scotter 448 40 9%
Skellingthorpe 515 53 31%
Sutton-on-Sea 819 737 90%
Waddington 826 492 60%
Washingborough 620 589 95%
Welton 2579 1604 62%
Wragby 649 368 57%

It might also be relevant to note that, since the 2014 Judicial Review judgement, significant cuts to opening hours have, to my knowledge, already been implemented at these libraries.

2.3  STATEMENT FROM WENDY CARRICK – Assistant Head, Gainsborough

Wendy Carrick is Assistant Head of Warren Wood Community School, Gainsborough, and a former Principal of Trent Valley Academy, Gainsborough.  She supplies the following evidence:

“The children of Lincolnshire need the libraries to remain open in their local areas because …”

PDF of this document here: Libraries submission Wendy Carrick

Source: Statement from Wendy Carrick – 17th April 2015.


Campaigners with local knowledge have also sought Statements from vulnerable categories of users affected by the changes in library provision proposed for 34  towns and villages.   Please find below a brief selection from the 900 Statements gathered.

Source: open link in new page: website – Save Lincolnshire Libraries Campaign

Statements from Alford, Birchwood, Spilsby, Kirton, Wainfleet, Long Sutton, Sutton Bridge and Boultham libraries (marked in ‘bold‘) are located in areas of High Deprivation.  Notwithstanding, all the other libraries supported by statements from their users (one statement is from a GP) on this List are earmarked by Lincolnshire CC for closure or to be volunteer-run. Some statements include specific reference to individuals’ inability to access other libraries further afield.

Michelle Tallon, Lincoln

“I am a GP – I know many of my patients depend on the library not only for reading material,but for internet access (which they do not have/cannot afford), access to newspapers and magazines and as part of the community.”

Kerryanne Bates, Caistor, Lincs:

“My husband is disabled and the sole driver in our family. He is unable to walk any distances to attend any other libraries further afield. I also have various medical problems that prevent long journeys travelling out to go to other libraries also. Our local library is a real godsend to us. This is why it should not close.”
Kevin Bates, Caistor, Lincs:
“My local library is very important to me because I am disabled and on a very low income, as a consequence I cannot travel to one of the libraries which is further afield.”

Roger Clarke, Caistor, Lincs:
“I use the library for books, computers, social and café facilities within walking distance of home.”

Gillian Sutton, Swallow (village) 6.4 miles from Caistor:
“I live in a small village and we rely on our local library so that we can run our village book group, a vital asset when we have so little services in our small villlage.”

John Myers, Alford, Lincs:
“Both my wife and I are regular users of the library: I am over 80 and my wife is disabled: we cannot afford nor are we able to travel further distances to larger libraries.”

Julia Richardson, re. Alford, Lincs:
“My parents who are now retired still visit the library weekly and being in a small community, people young and old rely on local services and activities to keep them active and part of the local town life. Public transport is not frequent in small communities so it is not easy especially for old people and families with young children to just hop on a bus and visit a library which would be at least a 30 minute bus journey from Alford to the nearest big town.”

Angie Dewick-Eisele, Alford, Lincs:
“Children are not able to travel after school on buses to an alternative library on public transport, Alford has high level of low income families, youth pass time away here on computers if they were not in the library they would be on the street getting into trouble. it is part of the heart of the community.”

Caroline Jesney, Alford, Lincs:
“We live in a small town/village, with little chance of travelling unless you drive which me and my partner don’t, the library in Alford is very important, not only for knowledge but also somewhere for the kids to learn and go during summer holidays, local library’s shouldn’t be got rid of, they are a need!”

Patricia Beard, Birchwood, Lincs:

“I feel a lot of older people could not get into town to use the city library also families with younger children probably couldn’t afford to travel into town.”

Victoria Ayling, Stickford, Lincs:
Spilsby library is too valuable to the community to lose.”

Andrew Cullum, Spilsby, Lincs:
“Village Mobile Libraries are being cut from 400 stops to 150 stops. This will hit the most vulnerable people. Those over 55, those under5, those without transport, those who are generally the most disadvantaged.”

Trevor Beaumont, Spilsby, Lincs:
“I am an avid reader and regularly use the Mobile Library which visits once a month at Ashby by Partney.”

Katharine Bell, Spilsby, Lincs:
“The library is a local resource I and many other people use regularly for a variety of different resources.”

Kerry Clow, Spilsby, Lincs:
“Lincolnshire has large numbers of small communities with little or no access to the services enjoyed by city or town-dwellers. These communities will be the ones most severely affected by library closures – another nail in the coffin for village life.”

Katie Rodriguez:
“Coningsby library is the only one in walking distance, and the only place I can get to to do my university work and access books for research.”

Pauline Fox, Wainfleet, Lincs:
“As a pensioner the library is vital both as a resource for books I cannot afford to buy and for our regular monthly Reading Group.”

Sue Longman, Kirton, Lincs:
“Please don’t remove this valuable asset from our community.”

Karen Smith, Kirton:
“I use my local library a lot, it’s very convenient for me as I live and work in Kirton, its the heart of the community.”

Kathleen Watson, re libraries in Kirton and Caistor:
“My husband takes my daughters to two rural libraries – Kirton in Lindsey, and Caistor every week. They love it. The librarians know them by name and it really encourages them to enjoy books and to read a wide variety of material. Please keep our libraries!”

Peter Hawes, Kirton, Lincs:

“I use our local library a lot.”

Kenneth Snowden, Kirton, Lincs:
“Without this facility in our village young and old people alike will be denied access to the world of literature in the written word, there is nothing like a good book to occupy and educate the mind, If Lincolnshire Councillors where to curtail their year after year increases in expenses, there would be enough money to keep our libraries open.”

Celia Howes, Boultham:
“For personal and community use our library at Boultham gives great added value, worth every penny of our community charge. Its loss would be felt by all ages and deny the community an important place belonging to it.”

Jean Flannery, Boultham:
“Not only I, but many others, value our own local libraries, including mine, Boultham Library, as a true community resource.”

Michael Howes, Boultham:
“Because I regularly use Boultham Library, I value its services to me and its importance to the community.”
Don Robinson, Sutton-on-Sea, Lincs:
“I am a pensioner, like 65% of the population here. There is nothing to do here, especially in the winter only read. The Library is a life-line to me.”

Jean Moss, Sutton-on-Sea, Lincs:
“We have recently moved to this area and having a library within walking distance was very desirable. A lot of people in this area rely on their local library.”

Natalie Copeland, Long Sutton:
“My children love the library as well as my elderly aunt.”

Ena Wyatt, Sutton-on-Sea:
“The local library is a facility needed by the mainly elderly and infirm of Sutton-on-Sea.”

Alison Freame, Sutton-on-Sea:
“Community facilities should not be under threats of closure or replaced with inadequate arrangements. Access to books is so important – libraries need to be freely available for all.”
Lesley Langley:
“The Library in Long Sutton is the hub of the community. Long may it continue!”

Michelle Pearl, Lincoln:
“I represent a young married couple soon to move from Lincoln to a village location. Without a local library I fear for my unborn children’s literary education. Being able to walk to local libraries will be the only service available to us. Travel is not a option.”

Susan Payne, Lincoln:
“Our local libraries (mine is Branston) forge links between all our educational resources for all age groups. The provision of local libraries has been a progressive step for self-improvement. Removing them is retrograde and ignores those people who are less well-off and those unable to travel distances.”

Karen Scarcliffe, Canwick, Lincoln:
“They are hubs of our community, children need access to libraries, and some cannot afford to buy books or just would like to borrow and not buy, without travelling miles.”

Lindsey Slapp, Lincoln:
“Library provision is a statutory requirement, and Lincolnshire County Council are abdicating their responsibility to provide a comprehensive and efficient Library Service across the county by cutting Libraries and forcing community groups to provide their own libraries. There has been no consideration given as to the impact on communities of the loss of libraries. Libraries give a safe space for children to study for their GCSEs, provide meeting rooms for community groups, and provide essential access to technology demanded by state welfare providers. The cuts will also adversely impact the disabled and those who do not have decent transport provision to travel to their nearest (post cut) library. There has been no thought or care as to the practicalities of these changes.”

Christopher Gill, Sleaford, Lincs:
“Modern local libraries, especially in rural areas, provide more than just access to books and reading material, which are, of course, very important. However, the community services aspect of libraries, such as internet access for people who need it and don’t have it, children’s education, eg visits to the library as part of the curriculum, and other activities such as being able to go to the library and talk to somebody, is just as important. Having to travel to “bigger libraries” in a rural county is not an option for many people, and, anyway, it totally misses the point, as to what libraries are about!”

Tracey Bendall Holbeach, Lincs:
“The local library offers many facilities as well as books. If it were to close, travel would be difficult for many and an extra expense; my children have found it invaluable for help with their homework and it is where many people can access the internet, which is very important in a rural community, as contrary to popular belief in government, there are still a great many who do not own, or cannot afford a computer.”

Judith Valerie Pitt, Lincoln:
“Libraries are essential in any area, and especially for young people just starting to discover the joy of books. Also hugely needed by the elderly who are not able to travel long distances to change and take out books. Please, please think again.”

Adrian Richards, Market Rasen:

“I go to my library nearly every week for an hour or two at a time mainly looking at microfilms for local history research. If this facility closes where else am I going to be able to do it? If it means I have to travel the 15 miles to Lincoln, then there is more chance that I won’t bother at all. As I am stood in the library i see people come in and out using the facilities, the internet, looking at books in the library. My partner works for a children’s nursery around the corner that bring their children to the library for story time. All of these things must be considered as well as the location of our town. We are at least 15 miles away from a big town should these facilities be lost. How many would be prepared to travel that far to continue to use these services?”


PDF at this link: Lincolnshire libraries – Public Libraries Act – Tim Coates

I refer to a document that is enclosed, as an item of important additional evidence.

3.1  Within his conclusions and recommendations, Mr Coates describes a failure by DCMS and the County Council to comply with Section 1.2 and identifies further examples of Lincolnshire County Council’s non-compliance with Section 7 (Public Libraries and Museums Act 1964).

3.2  I confirm that I agree with all Mr Coates’s arguments therein and wish the enclosed document to be considered as an integral part of the evidence I am submitting here.


A tendering process has recently been launched by Lincolnshire County Council for the outsourcing of its Library Service.  This process should also be vulnerable to the Secretary of State’s intervention, as the issue of the validity of the Council’s second consultation process is to be challenged in Court in further Judicial Review proceedings, a letter before action in relation to which has been served.


The arguments against the adequacy of the County Council’s second consultation are summarised in the Letter Before Action, to which I refer in Point 4 above. It also deals with other matters (PSED, the GLL bid and the Section 7 duty).  I request that the Secretary of State make it clear to Lincolnshire County Council that their proposed reorganisation should not advance further until the new Judicial Review has been adjudged one way or another and that it then be subject to the Secretary of State’s Decision about my formal request for his Intervention.


I have read the Save Bolton Libraries Campaign’s response of 29 November 2012 to the Secretary of State’s ‘Not Minded to Intervene’ letter (‘the Bolton Submission’),  relating to the reorganisation of Bolton libraries in 2012, a copy of which may be located at DCMS.    I further confirm that I adopt (mutatis mutandis) the legal arguments raised therein, but wish to indicate that my points 7, 8 and 9, below, should supplement them.


Access to public libraries is a basic human right. See e.g. ‘The Human Right to a Public Library’ by Kay Mathieson (cited in the Bolton Submission). This is not to be considered as in any way an abstract concept or academic argument, as explained in the statement of Wendy Carrick, which accompanies this letter, in which she provides significant detail as to why the children of Lincolnshire need the libraries to remain open in their local areas.

In relation to the impact of the 1998 Act upon these matters, I would urge the Secretary of State to consider that:

(a)  There is a positive duty on both Lincolnshire County Council and the Secretary of State to satisfy themselves that the proposed restructuring of the county’s library service does not infringe Convention Rights before that restructuring is allowed to proceed;  and

(b)  Since the lodging of the Bolton Submission, further evidence has emerged as to the negative impact of low levels of literacy (orthodox and digital) on health and employability. I request the Secretary of State to be minded to engage with Article 2 of the First Protocol to the Convention (Right to Education).

I refer the Secretary of State to the Arts Council Report: ‘Health and Wellbeing Benefits of Public Libraries’ and its Advice and Guidance note, both of which may be accessed on their website.

I request the Secretary of State to investigate closely the issue of whether, as I contend is the case, Article 2 of the First Protocol to the Convention (Right to Education) would be breached by implementation of the Council’s proposals.


Important aspects of public policy such as the achievement of the public health-related objectives of the NHS’s Five Year Forward View, which will depend for its effectiveness and financial viability on the reduction of avoidable illnesses, are materially connected with the development of literacy and careful consideration must be given by both the DCMS and Lincolnshire County Council as to whether the proposed restructuring of the library service in the county will impact negatively upon the achievement of such objectives.


Not to be ignored are international agreements and charters on libraries and literacy, both orthodox and digital, including but not limited to those cited in the Bolton Submission to which my Point 6 above refers – as follows:

(i)   International Literacy – Resolution  adopted by the UN General Assembly (1989)

(ii)  The UNESCO Public Library Manifesto; and

(iii) Other material relating to literacy (orthodox and digital) cited in the Bolton Submission

9.1  INTERNATIONAL AGREEMENTS  – Directly Referring to Children’s Rights:

The Geneva Declaration of the Rights of the Child, 26th September 1924;

The United Nations Convention on the Rights of the Child, 20th November 1989;
The European Convention on the Exercise of Children’s Rights, Council of Europe

The Montevideo Memorandum on digital exclusion of Youth

And additional references, as follows:

The UN International Covenant on Economic, Social and Cultural Rights, 16th December 1966, – Article 13 recognizing the right of everyone to education

The Universal Declaration of Human Rights, 10th December 1948 – Articles 25 and 26-3;

The European Convention for the Protection of Human Rights and Fundamental Freedoms, 4th November 1950 – Article 8

The Charter of Fundamental Rights of the European Union, 7th December 2000 – Article 241.

The United Nations International Covenant on Economic, Social and Cultural Rights, 16th

December 1966, – Article 17


In light of all the additional evidence herein supplied, I respectfully ask the Secretary of State to reconsider his Provisional Decision and request that you direct a Local Inquiry – on the grounds that Lincolnshire County Councils proposals for its Library Service will result in a service which does not comply with Section 7 of the 1964 Act (interpreted in accordance with s.3 of the 1998 Act).  I also contend that on the evidence there is a duty to intervene under s.10 of the 1964 Act (interpreted as aforesaid) and under s.6 of the 1998 Act.

I confirm that I reserve right to supplement or otherwise revise these submissions in relation to any future Local Inquiry or legal proceedings.

Yours sincerely,

Maurice Nauta

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