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For: (x) Agenda Item Number: 16 Executive X CLMT

Meeting Date: 29th July 2013

Report of: Head of Community Living

Report author: Michael McMahon

Subject: Outcome of the Library Review Public Consultation

Consultations: (x) Councillors X

(For Executive Only) Scrutiny X Lead Executive Member(s): Cllr M Ashraf Stakeholders X Wards Affected: ALL Others Recommendations Executive is requested: 1) To note the outcome of the public consultation set out at Appendix A to C. 2) To commend revisions to the current library service as set out in either of Options 1 and 2

as described in paragraphs 19 and 20. 3) That LCST be asked to give further consideration to the provision of additional Library

Access Points. 4) LCST, be asked to develop an implementation plan for the programme of closures and

revisions to the Library service; and deliver a pub lic awareness campaign on the impact of the new Library offer prior to any of the changes o r closures being implemented .

Background 5) The Executive meeting on the 3rd December, 2013 received a report which outlined various options for changes to the current cultural and Library offer delivered by LCST. The prompt for this report was an indication from members as part of the Budget Prioritisation, a willingness to consider alternatives to the existing level of provision of the Library service. 6) There is a statutory requirement on the Council under the provisions of the 1964 Public Librariesand Museums Act to ensure the provision of a comprehensive and efficient service across the TownTherefore the Council, must be satisfied before any changes are made to the provision of the Library service that there has been transparent consultation with users, stakeholders and partners about any changes and the new service meets the statutory requirement. The current position 7) Following on from the decision of Executive at minute EX/177/12, the Council lead on the consultation which commenced at the beginning of January 2013 and concluded on the 24th April 2013. The consultation comprised 3 elements:

• 2 separate questionnaires, one aimed at children and young people, the other at adults both of which could be completed on-line or via hard copy;

• Direct communication with 119 stakeholders which included local voluntary sector interest

groups, schools, internal departments, trade unions, LCST staff as well as agencies; and

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• 2 public meetings held at the end of the consultation period.

8) In addition a petition signed by 752 local residents has been received objecting to any closure of the Sundon Park Library 9) The consultation was also covered in the local media prompted by press releases from the corporate communications team. 10) The reports on the outcome of the various elements of the consultation are attached at Appendix A, Results from the Consultation BMG Research Report Luton Libraries Review 2013; Appendix B Children and Young Peoples survey results and Appendix C Stakeholders survey results Goals and Objectives 11) From the Council’s perspective the overriding objective must be for the Library service to continue to be provided in the town that meets the statutory requirements to provide a comprehensive and efficient service across the Town. 12) Supporting and under pinning that statutory requirement, the Council’s aims are: • to ensure that the maximum coverage of the service is achieved in terms of closeness and

accessibility of libraries to local people; • minimising the negative impact to the lowest numbers of Library users; • that the areas of the Borough with the highest levels of deprivation continue to have a service; • that the overall costs of the service are reduced; • changes have a positive impact on the corporate estate renationalisation; • links to the Local Development Framework Local Plan 13) The Council expects, therefore, that any options for changes to the service shall satisfy these aims, and withstand the robust scrutiny of a Integrated Impact Assessment. Proposal 14) Four options have been developed and details of these are set out in Appendix D. Options 1 and 2 are supported by the Board of LCST, with an expressed preference for Option1. The Board expressed reservations that Options 3 and 4 would provide a comprehensive and efficient service. Summary of Options 15) In summary all the options developed, provide for the retention of the Central Library, a strategic Library at Leagrave, and community libraries at Lewsey and Stopsley, and the Home Library Service and the introduction of a new provision in the form of Library Access Points (LAP) in varying locations. The Marsh Farm Library would be closed and replaced by LAP in options 3 and 4. Bury Park Library would close under options 2 and 4 and replaced by LAP. Across all 4 options, closure is proposed for Sundon Park and Wigmore, with the exception of Option 4, the removal of the mobile Library service, and adjustments to hours of openings (both increases and decreases). Set out in Appendix E is a definition of the different levels of Library service. Preferred Options and Justification

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16) Options 1 and 2 are considered to be the preferred options from both LCST’s and the Council’s perspective, in that they best support the statutory requirements, and are the closest to meeting the goals and objectives referred to in paragraphs 11 and 12 above. 17) The coverage achieved in option 1 is 86.6% (people living within a 1 mile radius of a static Library), which compares very favourably with the current coverage of 88%. The coverage in option 2 remains relatively positive at 81%, whereas with both the other options the coverage falls below 80%; with option 3 – 77.7% and option 4 – 72%. In terms of describing the coverage, by adding the provision of LAPs, the coverage increases to Option 1 – 93% to 96% (dependant on LAP location) and Option 2 and 3 – 90.8% and 4 – up to 100% depending on the mobile stop locations. This is a positive addition, though it must be noted that a LAP is not a library. 18) In addition these option has the impact on the smallest number of Library users Option 1 14% of active users and 12.5% of visits whereas Option 2 affects 16.5% of active users and 13.9% of visits, Option 3 affects 25% of active users and 20% of visits and Option 4 affects 24.9% of active users and 19.5% of visits.. 19) Option 1 Central – there are no proposed changes to the level of service provided at the central Library as it is seen as a key element to meeting the statutory requirements for the service. It is the largest facility in terms of numbers of books, dvds etc., access to IT services and information, it has the greatest usage, covers over 25% of the borough population and accounts for over 50% of library usage in the town. Irepresents the best value for money in terms of cost per visit. It was felt that any Sunday closure would disadvantage many people within the town from ethnic minority backgrounds, which are the main users at this time. Leagrave – the proposal is to retain this strategic Library, but with a Sunday closure. In terms of meeting the statutory requirements, there is a requirement for a strategic Library within the overall Library service to help ensure the provision is still classed as a comprehensive and efficient service. It has the 2nd highest number of visitors, covers 25% of the Borough population and has the 2nd best value in terms of cost per visit. The pattern of use on a Sunday at this Library is different from the Central Library and this closure will not have the same disproportionate community impact. Marsh Farm – the proposal is to retain this Strategic Library but with much reduced hours. This Library is in an area of high deprivation. Whilst public usage of this Library since it transferred from the Purley Centre into Lea Manor High School after an initial drop has regained similar numbers of active users as before the move, it has lost a lot of users from the local area due to the location and people not wishing to use the site whilst the school is open. This option sees a reduction in hours for the public Library with the emphasis on opening when the school is not in use for a majority of the time. To close this public Library and put a LAP into Futures House would see the removal of the newest and most modern Library facility within the corporate estate. This Library was provided as an element within the Building Schools for the Future PFI programme and the redevelopment of the Lea Manor High School, and therefore the Council would continue to incur the cost of this Library space under the terms of the contract. The LAP would only provide limited IT access in comparison and the results of the consultation demonstrated a strong public view that this area required a minimum of a community Library.

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The Lea Manor school Library will remain unaffected by any proposals to the public Library as it will continue to be staffed by the school librarian. Sundon Park – The proposal is to close this Community Library. A petition was received from 752 people who use the Library opposing closure. This closure proposal needs to be viewed in the context of proposals to retain Marsh Farm, Leagrave and Lewsey libraries. There are bus routes to Leagrave, Central Library and Marsh Farm and Marsh Farm is 1.2miles to walk which does include a slight hill at Hill Rise and also on the approach to Marsh Farm Library. Already just under 50% of the users use other sites mainly Central, Leagrave and Marsh Farm This is a standalone building which is not DDA compliant (the upstairs is not accessible for people who use wheelchairs). The area of Sundon Park is not within the high deprivation areas. Wigmore – The proposal is to close this Strategic Library. The coverage achieved by the Wigmore Library is only 9%, second lowest in the town, although the usage is 4th highest in the Borough with 72000 visits. However the Wigmore is not an area which experiences high levels of deprivation. The Stopsley Library is less than 2 miles (walking distance) from Wigmore, the consultation results show that a high proportion of users of Wigmore Library drive to this Library and that over 40% of Library users use alternative libraries. There are bus services from Wigmore to both Stopsley and Central Library for people who do not drive. The Council does not own this building and the proposed closure is due to the lease expiring in 2015 and running costs comparably high. Stopsley – the proposal is to retain this Community Library. With the proposal to close the Wigmore Library, a provision is required in the east of the town. This Library is centrally located within Stopsley village and covers 14% of the Borough population. In addition to mitigate against the Wigmore closure, the proposal is to increase the opening hours at this site and include Saturdays 17% of the current users of Wigmore Library already use the Stopsley Library. The IIA specifically highlighted the negative impact of the closure of Stopsley Library as there is a special needs school nearby which supports children with profound and complex disabilities. The ability to have been able to use another Library in a similar way was not possible due to travel distance. Lewsey Farm – there are no changes proposed to the provision at Lewsey Community Library other than reducing the number of staff to 1 and introduction of self service from equipment used at other libraries that would close which reduces the cost of running this Library. Lewsey is another area with high deprivation in areas and the nearest Library is 2.5m away. There is a provision in the 1 off capital costs for an entry system to be installed that would mean the Library could be open for the same hours as the community centre in the future. Bury Park – there are no changes proposed to the provision at Bury Park Community Library in option 1. Bury Park is another area with high deprivation in an area with a high demand for IT. There is a provision in the 1 off capital costs for an entry system to be installed that would mean the Library

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could be open for the same hours as the Community Centre in the future. 60% of users of this Library do use other libraries, and with the Central Library within half a mile walking distance there is a full provision of books and further IT. However, due to the density of population in the area, retaining it as a library at the relatively low cost of £21,000, pushes the coverage from 81% (as in option 2) to 86.6%. Mobile Library – the proposal is to remove the mobile service. 64.7% of mobile users attend other static libraries across the town. The cost per visit is higher than any other Library and the vehicle will need to be replaced in 3 years at a capital cost of around £120k. The stopping points are Farley, Dallow, Challney, Bushmead and Hockwell Ring. The impact for the areas affected by the loss of this service would be Farley, which could have a LAP installed at the Community Centre but the Central Library is within 1.5m but incurs a hill, Dallow and Challney are within 1.3m of Leagrave and on bus routes. Bushmead would see a loss unless a LAP was installed because the nearest Library Leagrave is 2.2m walking distance. Bushmead is an area that is not affected by deprivation and is on the bus routes 24 and 25 which provide a regular service to the town centre. Hockwell is a mile to Leagrave Library although there is not a direct bus route to Leagrave, there is a bus to the Central Library. LAP – these options allow for the provision of up to 3 LAP’s at locations to be decided but potentially Raynham, Farley, Hockwell, Chaul End or Bushmead could be used. 20) Option 2 The difference between Option 1 and 2 are Bury Park Community Library would close and be replaced with a LAP, but with extended IT facilities, and would achieve an increased overall saving of approximately £25k, otherwise the LCST’s proposal is the same. 21) In viewing and evaluating the options it was considered important that the rational for any changes to the service is clearly defined. The following criteria have been used to help score the individual libraries.

Criteria Issue / Implication Coverage Currently 88% of the population has a static Library within 1 (as the

crow flies) mile; including the mobile service this coverage increases to 100%.

Accessibility The issues raised in the consultation related to both the physical closeness of other libraries, but also the availability of public transport. Although some of the existing libraries are geographically close, access via public transport can be limited. Levels of DDA compliance of the buildings hosting libraries.

Deprivation Luton has some areas of the Borough that suffer very significant levels of deprivation, and maintaining a service in these areas would be seen as a positive action in supporting the priority within the 2013 Prospectus:

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‘……to better equip local residents of all ages to get jobs through investment and training….’

Landl ord’s Issues In parallel a major review of the Council’s corporate estate in underway; there is a clear target to reduce the numbers of buildings owned and operated by the Council. Key factors in determining decisions on disposal / retention are backlog of repairs, opportunities to increase the utilisation of the buildings that are retained and the disposal value of redundant / surplus to requirements buildings. The Transformation Strategy seeks to take services closer to the people the Council serves. Identification of those costs that will continue even in the event of closure

Cost per visit / saving from Closure

Information has been supplied by LCST on the cost per visit of all the Library service. An estimate of the saving to be achieved by closing

Usage of Libraries Information has been supplied by LCST on number of users of libraries and the patterns of that usage including the numbers that visit more than 1 Library.

Impact on the Local Development Framework and the definitions within the Local Plan of District and Neighbourhood Centres

The new Local Plan is under development, adoption will be in the summer of 2014 at the earliest. The Local Plan aims to define District and Neighbourhood Centres and describes the retail and community facilities that would be expected to feature within these centres, which would support the delivery or retention of Library facilities in circumstances where this was deemed appropriate. In the discussions/ consultations so far 5 District Centres and 13 Neighbourhood Centre have been identified.

22) To make the use of the criteria more robust, a weight the individual elements was developed: . 22a) Proximity to another substantial community facility (library & accessibility by public transport) (x3) Within a mile of another library (walking) scored -2 Within 2 miles of another library (walking) scored -1 Over 2 miles of another library (walking) scored 0 22b) Number of users per annum (x1) Top Quartile scored +1 Bottom Quartile scored -1 Middle Quartile scored 0 22c) Running Costs (x1) Top Quartile scored +1 Bottom Quartile scored -1 22d) Co-Location of other services (x1) If library is co-located scored +2 A standalone building scored +1 22e) Repairs Backlog (x1)

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Top Quartile scored -1 Bottom Quartile scored +1 Mobile Library replacement every 7 years @ 120k scored -1 22f) Local plan of District and Neighbourhood Centres (x1) District Plan scored +1 Neighbourhood Plan scored 0 22g) Deprivation (x1) Highest scored 0 Medium scored -1 Lowest scored -2

23) Applying this weighing to the current libraries resulted in the following ranking:

Library

Proximity - treble weighted Users Cost

Co-locations of other services

Repairs Cost

Local Plan Deprivation

Final Score

Marsh Farm -3 1 1 2 1 1 0 3 Lewsey 0 0 -1 2 1 1 0 3 Leagrave -3 1 1 1 -1 1 -1 -1 Stopsley -3 0 -1 1 1 1 -1 -2 Central -6 1 1 2 -1 1 0 -2 Wigmore -3 0 1 1 -1 1 -2 -3 Sundon Park -3 0 -1 1 1 0 -1 -3 Bury Park -6 -1 -1 2 1 1 0 -4 mobile -3 -1 1 1 -1 0 -1 -4

24) Impact on Service Users; A comprehensive Integrated Impact Assessment (IIA), and a significant amount of local consultation has been undertaken, all of which can be found at Appendix G, G.1 and G.2. The impact considered options one and two, but has also considered all options that had been put forward during the process. The options and mitigations have come from extensive consultation and outcomes of the draft IIA. Timescales for Implementation 25) Which ever option is preferable, there is a lead time on the implementation of the revisions, full details of which will need to be developed by LCST following consultation with staff. Budgetary Implications 26) Reference is also made in Appendix D (Options table) to additional costs ranging from £99k to

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£107k to meet the costs of setting up the LAPs, closure costs and some additional investment in infrastructure costs. Full details of these costs is set out in Appendix H. Whilst there is no budgetary provision to meet these costs, there is considered to adequate provision with the HCL base budget to meet these costs. Impact of Corporate Estate Rationalisation 27) Members must be mindful of the dependence of any closures prompted by the Library service review may have on the parallel reviews affecting the corporate estate rationalisation. The impact and outcome of this rationalisation exercise may require members in future to request LCST to further review the options around the delivery of the Library Service. Any building closures will be subject to at least a 6 month notice period from either party. 28) However, the proposals outlined in either option 1 or 2 have positive impacts on the Council’s estate rationalisation programme:

• results in the closure of a building that the Council owns ( Sundon Library ) that has a backlog of repairs, is non DDA compliant and offers the potential for the building and / or site to be disposed;

• results in the closure of Wigmore Library, which the Council does not own and occupy on an expensive lease; and

• In relation to Stopsley Library provides certainty in terms of it being required for service provision.

Key Risks 29) That a legal challenge is made to the assessment that the future service, does not meet the statutory test. The legal definition of ‘ a comprehensive and efficient service ‘ is not prescribed in detail in statute, and therefore, in theory any changes could be challenged. However, the greater the level of coverage and range of services provided reduces the risk of a successful challenge being made. 30) There will be a negative public reaction to any service reduction plans. However, the emphasis of this review is about re-provision of service which will provide some mitigation for this. An awareness raising campaign will be developed to inform both users and non users of the Library service of the changes. 31) There is evidence that a reduced Library service does have a negative impact on educational attainment, and it particularly adversely affects children, the elderly and the disadvantaged. Data supplied to a recent Parliamentary enquiry on libraries showed that 44% of children stopped using the Library service when their local Library closed. The coverage of service within the preferred options is at 87% (option 1) and 81% (option 2) (within 1 mile as the crow flies) compared with the current coverage of 88%. This coverage will be increased by the introduction of LAPs. In addition all the local high schools have their own Library. However, all the remaining static libraries will continue to have homework clubs which are successfully supporting educational outcomes for young people, and the young children activities and rhyme times will also continue, as will the school Library service. 32) The impact of the removal of the mobile Library service should this proceed, is mitigated by the evidence that 65% of users use an alternative Library, the introduction of LAPs and the retention of the Home Library Service.

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Consultations 33) Paragraph 7 describes the approach to the consultation. The quantum of responses to the consultation particularly in relation to the completion of questionnaires have been extremely positive, in that 770 children and young people’s questionnaires were returned and 2468 adult questionnaires. The results suggest that good coverage of respondents has been achieved from across the town, good representation from the town’s diverse communities and particular interest groups such as people with disabilities and people who were unemployed. 34) The report that Executive agreed in December, outlined 2 options, on which the consultation was based: Option 1 The proposed service would consist of the following Central Library 1 Strategic Library Home Library Service 4 Community Libraries

Leagrave or Marsh Farm Library to close; Wigmore to move into Raynham Way CC; 3 other libraries to be housed in community centres; Stopsley and Sundon Park to close and relocate into a community centre; up to 4 Library Information Points; No mobile service

Option 2 The proposed service would consist of the following: Central Library – with a closure of 1 day a week 1 Strategic Library – with an additional closure of 1 day a week Home Library Service Mobile Library Service 3 - 4 Community Libraries

Reducing the opening hours at the Central Library and the remaining strategy Library by 1 day a week.

From the consultation in overall terms, preferences on these 2 options are about equal. Full reports on the outcome of the consultation are set out in Appendices A B and C Appendices attached: A , B and C – Reports on the outcome of the Consultation D- LCST options and rational E - Definition of the different levels of Library service F – One off costs G- Integrated Impact Assessment

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Background Papers: Luton Libraries Customer Survey 2012 IMPLICATIONS For Executive reports For CLMT Reports

• grey boxes must be completed Clearance is not

• all statements must be cleared by an appropriate officer required

Clearance – agreed by:Legal The Council is the Library Authority for Luton and,

as such has certain statutory requirements under the 1964 Public Libraries and Museums Act to ensure adequate provision of services across the Borough. The governance arrangements here involve LCST as the provider, with the Council in the role of community leader and with the responsibility for ensuring that a service is provided that meets the statutory requirements for Library provision. As a result the Council instigated the consultation in conjunction with LCST and will want to check that the proposals for the future service take into account key issues raised in the consultation and the need to meet the statutory requirements. However, as LCST is the independent provider the ultimate decision on the future shape of the provision is a matter for LCST.

Principal Solicitor (Litigation) 17/07/13

Finance There are no direct financial implications to the council arising from the report. The service is currently provided by LCST, supported by external funding.

Ceri Davies Interim Finance Manager,Housing & Community Living 15 July 2013

Integrated Impa ct Assessment (IIA) – Key Points Equalities/ Cohesion/Inclusion (Social Justice)

A full IIA has been undertaken and can be found appended to this report. Option One and Option Two/ A potential negative impact has been identified in relation to age and disability, as being those who could be disproportionally affected by the Options One and Two. This is due to the fact that in both options, there is closure considered for Sundon Park Library, Wigmore Library and the Mobile Library Service. This could have a detrimental

Social Justice Unit

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impact on those who are less mobile/able to get to another static library. Age: With ageing often comes some physical deterioration of eyesight, hearing and physicality, therefore there is a possible impact on those who are elderly or who have a long term health condition, the ability to walk, or travel, long distances; to carry books for long distances. Also there may be generational difficulties, particularly relating to new technology. If there is no staff, or restriction on staff numbers and availability this could prove problematic if the only service is a Library Access Point These areas will have to be considered in relation to any mitigation ensuring that we do not make any remodelled service difficult to access for older citizens.. It is proposed that for the largest percentage of citizens will not be more than one mile of a local/community library, but this depends on which option is finally agreed. However this will be a map view and will not necessarily identify local difficulties for those with long term health conditions, those who are elderly/infirm/ or those with disabilities, but availability of bus routes can be determined, not all of which are direct routes to another/local static library. The loss of the Mobile library for this particular group, and for parents with young children, was identified in the consultation – and again supports the proposals being put forward which have the greatest reach and the siting of new Library Access points to mitigate where possible these negative outcomes. The view at present is that the outcome may be negative , unless clear mitigation is considered. The availability of bus routes and the recognition of a growing older population will need to be considered. Against this is the greater use of modern technology and the generational shift in using these resources. One of the mitigations is that the Home Library Service will continue, this is a voluntary run service which relies on the goodwill of its volunteers. This service may need to expand in

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the future due to the changes and a greater number of people having to rely on the service. Disability : Our analysis has shown specific areas for greater consideration, those being libraries that presently support in particular young people with profound and complex disabilities, the library offering both literacy and social inclusion to this group of young people. However, this information help support the final options to be placed in front of executive, but in relation to any remodelling Disability access compliance will need to still be considered as a legal requirement. However, for other disabled people, and those with long term health needs/frail elderly, the ability to access another library if there local library was to close puts them at a disadvantage. As shown earlier, a question was asked during the consultation if people had `specific requirements` in relation to the library service. The main areas of concern are pertinent for people with a disability and those with long term health conditions or older citizens.

Ø Disability Access Ø Doors easy to access Ø Lift or ground floor Ø Toilet facilities Ø Availability of large print books Ø Parking – nearby or on site Ø Accessible by local bus route Ø Within a reasonable walking distance Ø Supportive and knowledgeable staff of

individual needs/disability aware Ø Listening books Ø Valuing continuity and experience of staff

For most libraries these areas will be covered, but for some there may not be a direct bus route, or would be considered to be within a reasonable walking distance for those with some disabilities. However staff with knowledge and experience will remain, as will the availability of large print books and listening books in libraries across both option. A neutral outcome has been found for Gender, Sexual Orientation, Religion/Belief, Gender Reassignment, marriage and civi l partnership. This is because our research shows that there is

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no disproportionate impact on these groups with either of the two remodelling proposals. Social Inclusion: The Options have fully considered all aspects of impact, and have specifically considered the needs of the Town, the use of a library and where they are placed. Social inclusion, means consideration of levels of poverty, low income or areas of deprivation, and the options specifically do this. Luton has areas of the Town which are amongst some of the 10% most deprived lower output areas in the Country, and how libraries connect with the community and enhance learning opportunities for that community is not ignored but understood. Therefore in those areas a more fully functioning service is considered, except in Option Two where it is thought that an LAP could be considered for Bury Park. This is due To how the library itself is used with excellent usage of its I.T. resources and the option considers extending the I.T. provision, but with this library there is clear evidence that presently 60% of users also use other libraries and the Central Library is within 0.5 mile distance. Luton sets out is priority for being a learning Town, this requires support for citizens to achieve their personal learning goals. Libraries as seen as key resources to particularly supporting learning through books, research, I.T. support, homework clubs. These resources are available in our static libraries and with an 86.6% and 81% reach of one mile of a library the service remains supportive of these outcomes. The analysis undertaken by LBC included a weighting, which included social deprivation as a key identifier of need. Further information can be found below appendix G.2 Cohesion: Luton will continue to have a comprehensive and efficient library service, but communities may become resentful at each other due to choices that have to be made. With areas of deprivation being considered as targeted areas for resources, those less disadvantaged may feel they are receiving less and could turn their resentment towards those who retain a full library service, whilst they either lose theirs or have a less of a service than previously. Partners have to be

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mindful of fully explaining decisions to citizens, to ensure they understand the reasoning on each individual library change/overall decision making.

Environment

This report does not contain direct environmental implications. If and when the proposals are implemented buildings might have to be closed which are likely to have some energy / transport cost implications.

Agreed by Strategy & Sustainability Manager on the 11/07/2013.

Health

There is evidence for health benefits for adults and children associated both with libraries such as; general literacy, mental health and wellbeing and with some specific community events or programmes offered by libraries. Closure of libraries or reduction in their funding is likely to lead to a loss of these benefits.

Agreed by Public Health on 15th July 2013

Community Safety Staffing Other FOR EXECUTIVE ONLY - Options: 1. That the recommendations as written be adopted. 2. Any variations from the proposals set out as Options One and Two will require a further analysis statutory compliance, and potentially another period of public consultation. 3. A decision not to adopt any of the recommendations will result in a significant funding shortfall to LCST, which may fall to the Council to rectify.