Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by Giles Dolphin for the Greater London Authority (CEM 104)

  Giles Dolphin is a Chartered Town Planner and works as the Planning Decisions Manager at the Greater London Authority. Previously, he was Assistant Chief Planner (Environment) at the London Planning Advisory Committee, where he led research into the future burial needs of Greater London. LPAC was abolished on 31 March 2000 and its staff and resources were absorbed into the Greater London Authority. The Mayor of London, Ken Livingstone, has indicated his support for the work undertaken by LPAC and the policies that arose from it. He intends to include appropriate policies in his new spatial development strategy.

  1.  London, a vast urban area of 6.9 million people divided between 33 separate local authorities, has complicated arrangements for burying its dead. Each of the London borough councils is a burials authority, but none has any statutory duty to provide or maintain cemeteries. Nevertheless most do own and operate them, located either within their boundaries, or elsewhere, or both. Some have no burial facilities at all. There are 124 municipal cemeteries in total, including two located outside Greater London. Two are shared between adjacent boroughs. Most were developed by quite different local authorities or 19th century burial boards before the present boroughs were created in 1965. Some were originally private, taken over by the local authorities when the private companies failed. The situation is further complicated by 12 Jewish, three Roman Catholic, one Church of England and one Muslim cemetery, and by nine operational private cemeteries. Of the 133 non-religious cemeteries, 47 are completely full, and seven have less than 50 unused grave spaces. Burials also take place in various churchyards, but not in any great number.

  2.  About 29 per cent of deaths in London are followed by burial. Cremation deals with the rest, at 12 borough councils, five joint boards, and eight private crematoria.

  3.  Since the abolition of the Greater London Council in 1986, there has been no organisation able to take a long-term, London-wide view of future burial needs and supply. In 1975 the London Boroughs Association commissioned a study from the GLC, but its findings had little impact. Londoners today rely on cemeteries dating mainly from the 19th and early 20th Centuries, and only 11 new cemeteries, all small in scale, have been laid out since 1940.

  4.  Given the fragmented nature of the ownership and management of cemeteries in London, planning for the future is uncertain and inadequate, and many boroughs face the prospect of running out of space, thus joining the two that have already done so.4 Too often, local authority cemetery managers are inadequately supported by their council colleagues. Cemetery management has been described as the Cinderella service of local government (more recently this has been denied; it is the Ugly Sister service of local government)—unconsidered, undervalued and unappreciated. For town planners, valuers, property managers and finance officers, burials and cremation is a somewhat embarrassing service. Town planners in particular remain ignorant of the subject. Even though they need to know about it, they prefer not to know.

  5.  It is the function of the town planning system to ensure an adequate supply of land for necessary uses, including cemeteries and crematoria. The burials and cremation industry relies on the planning system for the necessary planning permissions. From the planning point of view, the simple question of land supply is vastly complicated by the need to resolve conflicts. The most basic of these is competition for the use of the same bit of land. But planning also has to accommodate special interests, such as the need to protect buildings, monuments and areas of historic, architectural or nature conservation importance; or the need to prevent atmospheric pollution or contamination to the ground water supply; or the need, since the Rio Earth Summit in 1992, to reduce the amount of travel, including travel to cemeteries.

  6.  There is, of course, nothing new in any of this—but both planning authorities and burial authorities have grown complacent since 1945, thanks to the post-war rise in cremation. This has allowed us to eke out unused land in cemeteries for much longer than anticipated. But that happy situation has already come to an end in parts of London, and will do so elsewhere over the next decade. Sites for three new cemeteries have been identified, and land to extend 12 existing cemeteries is also in the pipeline. But the land in question is presently used for playing fields, allotments, agriculture, woodland, nature study centres and country parks, etc.

  7.  In the past we allowed our city churchyards to fill up and overflow, producing foul scenes of horror so graphically described by Charles Dickens and others. From the 1830s, following the Parisian example, private companies set up the first wave of great cemeteries on the outskirts of London and other cities. These were very successful to start with, but the Victorians, being much more civic-minded than we are now, thought that burials were the proper business of local government. The next wave of cemeteries, this time municipal, were opened from the 1850s. When they filled up, the local authorities simply opened up new ones, only further out from the centre. Always, ample space was available in the countryside.

  8.  But in the middle of the 20th century, two things happened. Firstly, the Metropolitan Green Belt was clamped around London. This immediately increased the pressure on remaining open land. Secondly, cremation boomed. In London the cremation rate was a mere 4 per cent in 1945. Over the next 40 years it grew to over 70 per cent. That growth has slowed down, and might even be about to decline. This is due partly to an increase in religious groups that reject cremation. It might also be due to changing fashion, as pointed out by the social research think tank, Comedia.5 Whatever the reason, the slowing down of the rise of cremation is coinciding with the filling up of London's cemeteries.

  9.  To make matters worse, London is now faced with two new phenomena. Firstly, most redundant industrial and utilities land will soon have been re-cycled. Secondly, 629,000 new households will be formed in London over the next 20 years or so,6 creating yet more demands on land. Cemetery managers face insuperable odds competing with the house builders and superstores for the ever reducing supply of land.

  10.  Together with the Confederation of Burial Authorities and the Institute of Burial and Cremation Administration, with extra funding from the Corporation of London, LPAC decided to assess the scale of the problem, and to think about some solutions. Already, the need to allow old graves to be re-cycled had been raised.7 Research by Professor Davies of Nottingham University showed that a large proportion of the population would accept the re-use of graves once 100 years had passed since the last interment. It was clear, however, that the necessary legislation stood no chance of securing Government approval unless a compelling case could be made.

  11.  LPAC and its partners therefore appointed planning consultants Halcrow Fox and York University's Cemetery Research Group to do three things. First, they were asked to quantify the demand for burial in the foreseeable future. Using census statistics, the average number of deaths in each London borough up to 2016 was calculated. This is declining, from about 78,000 in 1981 to 53,000 in 2016, but it will start to grow again after the decline has bottomed out. In the absence of any robust evidence to the contrary, it was assumed that the burial/cremation ratio rate would not change significantly. If the cremation rate does begin to fall, the situation for cemetery reserves will be worse than the research shows.

  12.  Certain assumptions were then made about the number of burials that would take place in existing family graves, using recent rates as an example.

  13.  An allowance for religious or cultural groups which don't practise cremation was then attempted. Clearly, concentrations of, say, Muslims in a particular part of London would result in a higher demand for burial spaces. Also, Jews and to a lesser extent Roman Catholics tend to be buried in separate cemeteries, and thus municipal cemeteries in areas with concentrations of these groups might experience a lower demand for burials. Other groups have different characteristics. The Greek Orthodox community prefers separate sections of cemeteries. Some growing Protestant groups, such as Pentecostal churches that are popular amongst the African and West Indian communities, also tend to reject cremation, and this would have consequences for certain parts of London. Unfortunately the census contains no information about religion. One can only guess at the number of Muslims, Jews, Roman Catholics and Protestants. Some information was obtained from church authorities regarding the number of adherents, but this was unreliable. A religious question will be asked in the 2001 census, and it will be worthwhile to repeat the calculations when the data becomes available in 2005 or so. Meanwhile, people of Pakistani and Bangladeshi origin were identified as a proxy for the Muslim population, and the necessary allowance in the projected death rates for each borough was made.

  14.  In parallel with this research into deaths, the amount of space left in London's cemeteries was investigated. This proved to be no easy task. It was impossible, for example, to measure or even estimate the reserves in existing family graves. Hence, recent data on re-openings from CIPFA statistics10 was used to make projections of re-openings. Fairly accurate data was received from cemetery managers on the area of unused land set aside in cemeteries for non-denominational burials, together with data on the area in proposed extensions to cemeteries, and in proposed new cemeteries. Borough planning departments provided information on present land uses, and whether it had planning permission for burials, or was designated in development plans for cemetery use. Maps 1 and 2 of the LPAC report11show respectively the area of cemeteries in London and their remaining capacity; the differences are instructive.

  15.  It then remained to put the two sets of data together—the demand, in terms of the average number of deaths each year, and the supply, in terms of the amount of land available. The result is the number of years each borough has before it will run out of burial space.

  16.  The data is published in detail in the report "Burial Space Needs in London" available from LPAC. The data was subsequently tested by LPAC against several scenarios to take account of variables such as the distance between where people live and where the burial space is. This is contained in the report "Planning for Burial Space Needs in London." 12 The results are encapsulated in Table 1, attached. It does not include denominational space.

  17.  There are six scenarios. Column (Scenario) A is geographical, with little relevance for planning purposes. Scenario B includes all of each borough council's own cemeteries, including those located far away outside the borough, plus a proportion of other non-denominational space located in or close to the borough both public and privately owned. Like Scenario A, this disregards proposed new cemeteries, and is the best indication of years remaining on the basis of ownership, but assumes that distance is no problem.

  18.  Scenario C is the same as B, but excludes reserves in existing cemeteries that are located far from the borough. For planning purposes this is the best scenario, as it takes account of the proximity principle, and takes a realistic, perhaps severe, attitude to land identified for new cemeteries.

  19.  Scenario D is the same as C, but includes in addition all reserves in sites identified for new or extended council cemeteries in or near to the borough in question, and a proportion of others as appropriate. It deals with the short term and assumes 2,000 burials per hectare.

  20.  Scenario E is the same as B, but includes all council-owned space in proposed new cemeteries wherever they are, and a proportion of other councils' proposed cemeteries, as appropriate. This also assumes 2,000 burials per hectare.

  21.  Finally, Scenario F is the same as E, but takes a longer term view, and assumes 5,000 burials per hectare, as family graves eventually fill up.

  22.  It was assumed that 100 per cent of burial spaces in each council-owned cemetery located within the borough will be taken by residents of that borough; and that a high proportion of spaces located outside the borough will be taken by residents of the owning borough, with the rest being taken by residents of the host borough and, in some cases, other neighbouring boroughs. Where possible account was taken of the distance of the cemetery from the owning and neighbouring boroughs; the reserves held by the host and neighbouring boroughs in other cemeteries located within their own boundaries; the degree to which the owning borough depends on the cemetery in question; the type, quality and character of the cemetery; and the effect if any of higher burial charges levied on non-residents of the owning borough. It was assumed that burial spaces in private non-denominational cemeteries will be taken by residents of the host and neighbouring boroughs, taking account of the above factors, as appropriate.

  23.  Scenario C showed that on average each borough has 13 years to go before it runs out of burial space, with seven years in inner London, and 18 in outer London. Hackney and Tower Hamlets have no space, anywhere; and Westminster has none within a reasonable distance. Even some outer London boroughs, such as Croydon, Brent, Ealing and Enfield, had only three years or less within a reasonable distance.

  24.  Scenario D, which includes proposed new space in or close to each borough, paints a happier picture. The London average is 36 years—but only eight in inner London.

  25.  Scenario E, which takes account of all potential reserves, including those located far away, has a London average of 50 years, with 28 in inner London. But this includes new land that cannot be relied on. Southwark Council provides a good warning. It plans to reclaim land acquired long ago for cemetery use, but quite properly made available for playing fields in the meantime. Controversy ensued when local footballers, children and dog-walkers found they would have to make way for the dead.

  26.  Other land is used for allotments. Usually the allotment holders understand and accept that their occupation is temporary; but the current search for housing land is leading planners and house builders to cast their eyes on these allotments, and burial managers may well get caught up in a new "protect our allotments" movement.

  27.  Some sites are used as nature study centres for school children. Others occupy beautiful rolling countryside. Some even have commercial operations on them, bringing in valuable income to the Borough Treasurer.

  28.  So, no matter how definite the cemetery managers' plans are, in many cases they will not be able to proceed. In many cases, they should not be allowed to proceed, because existing uses and landscapes have a greater moral claim; and because some of the sites are simply too far from the bereaved. However, there is actually no need to proceed: a sustainable solution—re-use—is available.

  29.  It is the overall picture that matters; and the picture is one of rapidly diminishing burial space reserves. The combined effect of these figures provides the evidence for the systematic re-use of old graves. Like so many other non-renewable resources, land for cemeteries will have to be re-cycled. Already, London's burial land occupies an area greater than a small London borough, and London cannot afford to increase this indefinitely. A halt to cemetery growth is inevitable.

  30.  The maintenance of old cemeteries, particularly full cemeteries, is a closely related issue. Nothing is more depressing than the appearance of Abney Park, Nunhead and Tower Hamlets Cemeteries, three of London's original great seven. Highgate and Kensal Green are not much better. They are derelict; given over to brambles, Japanese knotweed and sycamores; and prey to vandalism, neglect and decay. Coming upon a wonderful old tomb in these or many other cemeteries must be like coming across a Mayan temple in the Central American Jungle. We too, have our jungles. We tend to call them nature reserves, but in truth they often make pretty shabby and uninteresting nature reserves. How exciting, then, is the prospect of re-using the graves in these derelict cemeteries, thus bringing in new income to help defray the cost of restoration and maintenance.

  31.  Hugh Meller illustrates his book on London cemeteries13 with a photograph of the glorious Berens sarcophagus at West Norwood. Scandalously, a substantial sapling was growing through its shattered roof. It was still there in September last year. What a way to treat "one of the finest High Victorian monuments in the country"14 (as described by Lambeth Council itself). No-one imagines re-using the Berens tomb; but countless lesser monuments could be moved carefully aside; any mortal remains exhumed and placed in a small casket at the bottom of the grave space; the space re-used by tomorrow's dead; and the old monument reinstalled. The income from the sale of the re-used grave space could not only ensure the monument was replaced safely and upright; but some of it could be used to save gems like the Berens tomb.

  32.  To what extent would re-use meet burial needs? LPAC's consultants estimated that in inner London there are 80 hectares of land with graves other 100 years old, and a further 70 hectares between 50 and 100. Annually, about two hectares could be added to the stock where the graves exceed 100 years. If a 100-year rule was pursued, 160,000 burial spaces in inner London would be available immediately, and a further 10,000 added each year. This calculation is based on very conservative assumptions, and compares to an annual burial needs forecast in inner London of 5,812. A more robust assessment of the potential of re-use has not yet been produced; but it does look as if existing graves could be re-cycled indefinitely, thus eliminating the need for new cemeteries in London.

  33.  Since LPAC formulated its policies, it has been suggested by the IBCA and others that 75 years would be a more appropriate timescale for re-use. This would virtually guarantee that London could bury its dead within existing cemetery boundaries indefinitely.

  34.  At present, exhumation licences or faculties are required in order to re-use old graves. These are not granted for the purpose of creating burial space. Private cemeteries seem to get blanket permission for area re-use, 15 but this option seems to be unavailable to municipal cemeteries. Legislation is needed to enable cemetery managers to re-use graves without further recourse to the Home Office or ecclesiastical authorities. For this to be acceptable, a management plan would have to be in place for each cemetery.

  35.  In identifying graves for re-use, cemetery managers would have to be selective. Quality tombs and memorials would have to be preserved. Areas of acknowledged nature conservation value would have to be left out. The Royal Commission on Ancient Monuments would have to be satisfied that proper archaeological investigations were accommodated. Burial in a re-used grave would have to be optional. Living relatives would have to have the right to veto the re-use of a grave. The overall character of each cemetery, its wider role in the community and its spiritual dimension would have to be respected.

  36.  There are, of course, other options for dealing with the shortage of space. Intermediate burial is the most widely practised. From the hard pressed cemetery manager's point of view, it can be very useful to squeeze new graves between spaciously laid out 19th century graves, or to rip up ornamental flower beds for new graves, or even to take over cemetery roads and paths for burials. Unavoidable as they may have been to date, these are deplorable practices, as they destroy the character and quality of cemeteries.

  37.  Land raising is another option, but also destroys character. Monuments have to be swept away, then a new layer of top soil is spread over the old graves, anything up to 20 feet deep. This is a short-term expedient, because it is unlikely that land-raising can be repeated more than once; the prospect of burial mountains is not pleasant.

  38.  Re-claiming unused space in family graves after 75 years have elapsed since the last interment has its benefits, but the administrative procedures can be lengthy and expensive; and it prevents full re-use. The process has proved popular in re-using old and derelict private cemeteries for Muslim burials such as at Tottenham Park and Woodgrange Park, but this also destroys character, and prevents any further re-cycling.

  39.  Only re-use makes long-term sense.

  40.  With all this in mind, LPAC, the CBA and IBCA drew up policies, based on certain strategic principles for burial provision. The first is choice: this it is a person's basic right to choose how their body is disposed of. Secondly, cost: unless absolutely necessary, people ought not to be coerced into cremation, or burial far away, if their preference is to be buried locally. Thirdly, proximity: the bereaved, particularly those who are elderly, should be able to visit graves without having to travel unduly long distances, or incur great financial cost. Fourthly, open space: the use of sports grounds, farmland, allotments and woodlands, etc, should be avoided. (London has little enough open space as it is, and what it does have will become more precious as densities increase in order to avoid development on greenfield sites.) Fifthly, conservation: features of architectural or historic interest should be treated sympathetically, including assemblages of monuments. Sixthly, archaeology: clear guidelines are needed to safeguard archaeological remains and to facilitate investigation. And seventhly, biodiversity: the rich archaeological resource of some parts or some cemeteries should be acknowledged.

  41.  Policy 1 is concerned with regulation. The Home Office should introduce further legislation and a regulatory authority to ensure the proper maintenance of all local authority and private cemeteries, including the protection of human remains from disturbance, whether deliberate or accidental. This should include a presumption against the excavation of burial spaces in any part of a cemetery unless it can be demonstrated that no burials have previously taken place there.

  42.  Policy 2 requires all those involved in burial provision to adhere to the strategic principles outlined above. Strategic co-ordination is the basis of Policy 3. In conjunction with LPAC, the CBA's forum of London Cemetery Managers should formulate and then consult further on proposals for the strategic co-ordination of burial space provision and access to it. The objectives should be to make cemetery space in London available to all Londoners, regardless of borough ownership but taking into account the proximity principle, without financial penalty on the bereaved living in boroughs not owning burial spaces; to provide an adequate amount and variety of burial spaces to meet residents' needs; to co-ordinate the provision, allocation and sale of burial space at a strategic level; and to provide impartial advice to the bereaved on the funeral choices available to them, in terms of cost and proximity. In doing so, the possibility of a new London agency, authority or committee of the new Greater London Authority, should be examined.

  43.  Policy 4 urges the CBA to carry out a regular six yearly review of future burial space supply and demand, with a regular two yearly survey of current burial space supply and burials by religion and denomination. It should promote a uniform system for keeping burial space records in London.

  44.  Policy 5 aims to maximise remaining capacity in cemeteries, by digging all new plots to 3.1 metres where soil and drainage conditions permit; selling burial rights for a maximum of 50 years, or introducing other measures having a similar effect, such as ten-year rolling burial rights; reclaiming all unused burial spaces for new burials in private graves where existing burial rights have expired or can be determined; and at the appropriate time, investigating bringing back into use full or disused cemeteries.

  45.  "Green" burial may have some potential in London, and Policy 6 urges the CBA and LPAC to examine this and consult on proposals for woodland cemeteries in the Green Belt and on poor quality open spaces, including derelict or damaged land, to meet both the demand for this type of burial and to improve open space and natural habitats.

  46.  Policy 7, which urges the Home Office to agree new legislation to facilitate the reuse of burial spaces on a systematic basis, is perhaps the most important product of the LPAC study. Policy 8 provides the all-important safeguard: burial spaces should only be re-used in accordance with cemetery-specific "cemetery management plans", containing a schedule for re-use in a phased way, in accordance with their potential for reuse identified in the plan. They should include surveys of the age, distribution and listed status of the graves; other listed structures; conservation area designations; natural habitats and bio-diversity; landscape; potentially important archaeological remains; and scope for the provision of new forms of burial.

  47.  Finally, taking account of religious customs, Policy 9 states that the re-use of burial spaces should only be considered where: records and plans that determine the date and nature of previous burials are available; the graves to be renewed, whether public or private, have been properly reclaimed; at least 100 years (or 75, depending on consultation on public attitudes) have passed since the last burial took place, and the grave is not considered to be of any archaeological importance; it does not cause damage to natural habitats or reduce biodiversity; it does not adversely impact on historic features; and the area to be re-used is covered by a comprehensive cemetery management plan.

  48.  These policies are aimed at local authorities, both cremation and burial managers and town planners, and at the Government. To bring about the necessary legislation, LPAC, the CBA and the IBCA lobbied the Home Office, and were able to demonstrate that the problem was real and urgent, and that the re-use solution would work, and would have public support. By then, it had ceased to be a London issue, as evidence came forward of similar problems across the country, not only in the large cities, but even in rural villages. A Home Office consultation paper was prepared, but a considerable time has passed without further action by the Home Office. The reasons given for shelving the consultation paper are unconvincing.

  49.  Without re-use, Londoners will either have to be buried miles away in the Green Belt; or be buried in landraised or crammed cemeteries where character has been destroyed; or have cremation forced on them, with our entire legacy of splendid cemeteries deteriorating into unkempt, derelict, dangerous, useless blots on the landscape, and Londoners, deserve better.

Table 1

Outer London average48 19185666 136
Outer London excluding the six boroughs with highest reserves1 141110 232743
Barking and Dagenham12 12121212 12
Barnet9511 111621 35
Bexley2424 242424 24
Brent221 322102253 2599
Bromley1716 161616 16
Croydon26 33140 343
Ealing50.5 0.51515 36
Enfield301 13434 84
Greenwich2626 262626 26
Harrow99 999 9
Havering99 94949 101
Hillingdon5656 565656 56
Hounslow15367 67247255 518
Kingston-upon-Thames10 16163434 61
Merton20822 228888 187
Redbridge628 86262 145
Richmond-upon-Thames162 20204343 84
Sutton1321 21103103 226
Waltham Forest1717 171717 17
Inner London average6 117828 51
City of London3
Camden310 101065 149
Hackney00 000 0
Hammersmith and Fulham43 132223 38
Haringey78 888 8
Islington038 3434204 412
Kensington and Chelsea412 7777 7
Lambeth547 777 7
Lewisham66 666 6
Newham6133 333 3
Southwark1111 111919 32
Tower Hamlets00 000 0
Wandsworth51730 141430 30
Westminster014 0317 17
Greater London average30 16133650 100

  1 Different boroughs for each column.

  2 The site of the proposed Kingsbury Cemetery is partly woodland, and burial densities may be lower than the standard rates used here.

  3 No analysis is given for the City, because of its exceptionally low number of deaths.

  4 Kensal Green Cemetery is divided equally between Hammersmith and Fulham and Kensington and Chelsea.

  5 The Lambeth and Wandsworth figures assume 1,000 remaining spaces in Lambeth Cemetery (not 10,000, as suggested in the survey results).

  6 The figures for Newham (and, to some extent, adjacent Boroughs) are under-estimates, as details of remaining space were not provided for the three privately-owned cemeteries in Newham.


  1.  Including Brompton Cemetery, compulsorily acquired by the Government in 1852, and now administered by the Royal Parks Agency for the Department of Culture, Media and Sport.

  2.  Greenlawn Memorial Park Cemetery, in Tandridge District, owned by Croydon Council; and Carpenders Park Cemetery, in Three Rivers District, owned by Brent Council.

  3.  Merton & Sutton Joint Cemetery; and Bandon Hill Cemetery (Croydon and Sutton Councils).

  4.  Hackney and Tower Hamlets.

  5.  Ken Worple, "The Cemetery in the City" (Comedia, 1997).

  6.  Department of the Environment, "Projections of Households in England to 2016" (HMSO, 1995).

  7.  London Planning Advisory Committee—a statutory committee of all 33 London planning authorities, set up in 1986 by the Act which abolished the Greater London Council, and abolished by the Greater London Authority Act 1999.

  8.  Ian Hussein, paper on "Re-use of Graves", Joint Conference of Burial Authorities, 1993.

  9.  Davies D and A Shaw, "Reusing Old Graves: A Report on Popular British Attitudes" (Shaw & Sons 1995).

  10.  Chartered Institute of Public Finance and Accountancy, Cemeteries Statistics, annual.

  11.  Halcrow Fox in association with York University's Cemetery Research Group and The Landscape Partnership, "Burial Space Needs in London" (LPAC, December 1996, CON56).

  12.  LPAC in conjunction with the CBA and IBCA with the support of the Corporation of London, "Planning for Burial Space in London" (LPAC August 1997, CON69).

  13.  Hugh Meller, "London Cemeteries—An Illustrated Guide and Gazetteer" (Scolar Press, 1981; revised 1985, 1994).

  14.  Lambeth Council, "West Norwood Cemetery", 1971.

  15.  eg Woodgrange Park Cemetery Act 1993.

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