Select Committee on Environment, Transport and Regional Affairs Memoranda

Memorandum by the Home Office and the Department of the Environment, Transport and the Regions (CEM 49)


  1.  Central government responsibility for cemeteries (and crematoria) within England is shared. The Home Secretary is responsible for burial and cremation law, and related matters concerning the disturbance of buried human remains. The Secretary of State for the Environment, Transport and Regions has responsibilities by virtue of the fact that most burial and cremation authorities are local authorities and are organised and funded accordingly. He also has an interest arising from land use and regeneration considerations and implications for environmental protection.

  2.  The Home Secretary is also responsible for exhumation and cremation law in Wales, but burial law has otherwise been devolved to the Welsh National Assembly and the Northern Ireland Assembly. Separate arrangements apply in Scotland. The Home Office has no general information about cemeteries in these territories.


  3.  Cemeteries and burial grounds are provided by burial authorities,[3] private companies and religious bodies, including the Church of England.[4] Burials have also taken place in prisons, hospitals and other privately-owned land. Other, forgotten, cemeteries may be discovered in the course of building and other site development work. There are no central records of all places which have been used as places of burial and the total numbers of burial grounds are not known. (However, according to statistics from the Chartered Institute of Public Finance, in 1998 local authorities in England were responsible for 1,124 cemeteries).

  4.  Until the early part of the 19th century, burial facilities were provided by the Church of England in parish churchyards, and by other religious bodies. The population increase following the industrial revolution meant that the existing churchyards were unable to cope with the numbers of dead for disposal. Initially, a number of private cemetery companies were established by statute but with the increasingly scandalous conditions at many urban churchyards, where existing burials were frequently disturbed by new graves, and with the consequent risks to public health, a string of new burial laws were passed. These not only tightened the regulation of burial but also provided for cemeteries to be established by local burial boards, and subsequently local authorities, in response to local needs. The Local Government Act 1972 consolidated much of the preceding legislation to reflect the new local government organisation it introduced.[5] While regulations under that Act (the Local Authorities' Cemeteries Order 1977) set out the general powers and responsibilities of the statutory burial authorities.

  5.  The Church of England and other religious bodies continue to provide burial facilities but these and private cemetery companies are not subject to the local authority legislation. The great majority of operational cemeteries are run by the statutory burial authorities. The Church of England, and other religious bodies, are understood to have a significant number of disused burial grounds.[6] There is provision for responsibility for the maintenance of Church of England churchyards to be transferred to the local authority.[7] Similarly, where private cemeteries have become full, most have been transferred to local authority control and are maintained in the interests of the community.


  6.  The Home Office has long been responsible for cremation law (the Cremation Act 1902, and the Cremation Regulation 1930, as amended) and such burial law as relates to the exhumation or removal of human remains (eg section 25 of the Burial Act 1857, the Disused Burial Ground Acts, and relevant regulations under the Town & County Planning Acts). Since 1995, however, responsibility has been assumed from the then Department of the Environment for the remaining burial legislation (including extant provisions of the Burial Acts 1851-1906, relevant provisions of the Local Government Act 1972, and the Local Authorities' Cemeteries Order 1977, as amended).

  7.  In view of the wide discretion for the management of cemeteries granted to burial authorities under the 1977 Order, neither the Home Office nor its predecessor department has issued guidance or has otherwise sought to intervene in the day-to-day management of burial grounds. A similar approach has been adopted towards private cemeteries and churchyards. Nevertheless, in response to any enquiries about developing new cemeteries, a memorandum providing basic information about planning permission, choice of site location, cemetery size and management, will normally be provided.

  8.  The Government has no general responsibility for the protection of cemeteries in terms of their security (other than in respect of confirming any necessary cemetery bylaws), or the protection of memorials, headstones or monuments (except to the extent that provision is made in relevant legislation for the authorised disposal of such memorials and monuments—see footnote 10 below). These are matters for the burial authority and, where appropriate, the owners of the memorials or buildings. The architectural or historic importance of some buildings and monuments in cemeteries is recognised by their being protected as listed buildings. This means that the owners are required to obtain listed building consent for any works which affect them. The statutory list of buildings of architectural or historic importance is maintained by the Secretary of State for Culture, Media and Sport; he is advised on these matters by English Heritage, his statutory adviser on the historical environment. It is understood that English Heritage will be submitting to the Select Committee further evidence on these aspects.

  9.  The Home Office is responsible, however, for the protection of buried remains (including cremated remains) from unauthorised disturbance. The general position is that buried human remains may not be removed or disturbed without a Home Office licence or, in certain circumstances, a Bishop's faculty,[8] or otherwise as may be provided for by statute to enable burial grounds to be developed for other purposes.[9] The effect of the prohibition on the unauthorised disturbance of buried remains is to constrain the sale or development of disused cemeteries because of the additional costs arising from the need, in most cases, to remove the buried remains for re-burial or cremation elsewhere.

  10.  War graves of the Commonwealth forces, wherever they are located, enjoy the additional protection of the Commonwealth War Graves Commission. The Commission was established by Royal Charter in 1917, and its duties include marking and maintaining the graves of the members of the forces of the Commonwealth who were killed in the two World Wars and to keep relevant records and registers. Statutory burial authorities may not take any action in relation to any tombstones or other memorial provided by the Commission, without the Commission's consent.

  11.  Public policy in relation to cemeteries and crematoria is that their provision is a matter for local and commercial decisions in the light of demand. Regulation is light, and designed primarily to uphold the public interest in the decent disposal of the dead, to ensure that proper records are kept and preserved, to avoid public nuisance, and to protect buried remains from unnecessary disturbance. The regulation of municipal cemeteries also seeks to ensure uniform provision of the grant of burial rights and consistent arrangements for the maintenance of graves and memorials.

  12.  Cremtoria and cemeteries are both subject to environmental protection regulations, and there is additional regulation in relation to crematoria in the interests of deterring any attempt to dispose permanently of evidence of crime.


  13.  The Home Office interest in the environmental, historical or cultural significance of cemeteries is limited primarily to where the condition of the cemetery is such that consideration ought to be given to the discontinuance of further burials (in accordance with the provisions of section 1 of the Burial Act 1853) or to the taking of measures in the interests of public protection or public health (section 23 of the Burial Act 1857).

  14.  Nevertheless, the Home Office is also responsible for the provisions of the Open Spaces Act 1906, under which local authorities may enter into agreements with site owners to secure cemeteries for use in trust by the public as open space. The legislative provisions under Local Government Act 1972, which enable local authorities to provide financial support to anyone providing local burial facilities, and require them, on application, to assume maintenance responsibility for churchyards closed to further burials by an Order in Council, are also relevant.[10]

  15.  The Government recognises that cemeteries and burial grounds can be havens of green space and tranquillity in otherwise built-up areas. Although any use for recreation must be clearly subsidiary to and compatible with their main function as places of burial, they are one aspect of the public realm and can provide places for walking or quiet reflection. They can also serve as a valuable habitat for trees and other flora and fauna.


  16.  By virtue of the Home Secretary's general responsibility for burial law, and having regard to the powers available to him, under section 8 of the Burial Act 1855, to appoint a person to inspect a burial ground to ascertain its state or condition, it is the practice of the Home Office to respond to complaints about cemeteries which may be made by members of the public.

  17.  Under the Local Authorities' cemeteries Order 1977, local authorities have a wide discretion as to the way in which they discharge their responsibilities for their cemeteries. The Home Office does not consider it appropriate to seek to intervene in, or comment on, that discretion. Furthermore, it is also a matter for judgement by local authorities as to the priority to be attached to competing demands for expenditure by local services. Normal Home Office practice is therefore to refer complaints direct to the relevant local authority for consideration. Where appropriate, the correspondent's attention will be drawn to the procedures available to pursue such complaints, including reference to the Commission of Local Administration in England. In cases of complaint against private cemeteries and Church of England churchyards, complainants will again normally be referred to the relevant owner or, in the case of churchyards, the incumbent. The Home Office received 38 items of correspondence about cemeteries and burial grounds in 1999-2000.

  18.  The Home Office does not inspect the condition of cemeteries as a matter of routine, nor maintain central records of their condition. Where, however, the condition of a cemetery is reported to be such that consideration should be given to discontinuing burials, or to require work to be undertaken in the interests of public protection or public health, the Home Office will consider the appointment of a suitably qualified person to undertake an inspection of the site and to make a report. Three such reports in relation to six cemeteries (five of which were municipal) have been obtained since 1995. Recommendations arising from the reports have been pursued with the relevant burial authority. In most cases, action has been taken, or is being taken, to address any identified shortcomings. It has not been Home Office policy to publish the reports.

  19.  Some cemetery buildings and monuments are listed on the English Heritage Buildings at Risk Register.


  20.  There is no obligation on the Home Office (or central government as a whole) to provide cemeteries or to require others to do so. The absence of such a responsibility reflects the fact that provision of facilities for the burial of the dead had long been accepted as a responsibility of the Church of England and other religious bodies. With the development of local authorities in the 19th century and their assumption of many of the powers and duties of the Church, responsibility for burial was in due course transferred to local authorities. The decision as to whether a burial ground was needed, however, was always one for local decision.

  21.  Since assuming responsibility for burial legislation, the Home Office has maintained that policy. There are therefore no central records of the location or remaining capacities of burial grounds, whether municipal, private or belonging to the Church of England.[11] The Home Office understands that cemeteries continue to be established by local authorities and others, and that the process is consequently responsive to demand. The Home Office also understands that new ideas for the provision of burial space are also being introduced in some areas.[12] These developments are being kept under review. In some areas, it has been claimed that there is nowhere suitable for new burial grounds (see paragraphs 22-24 below), but the Home Office is not aware of any communities which have been unable to provide themselves with, or have access to, burial facilities, even if not always as conveniently located as they might wish.[13]

  22.  It should also be noted that, since cremation was legalised and relevant legislation enacted at the beginning of the last century, the choice between burial and cremation has grown steadily in favour of the latter, especially since the war.[14] This has inevitably mitigated the demand for new burial space. The question as to whether there was a need for longer term planning for new cemeteries, and by whom, has thus only emerged in the last few years, mainly as a result of concerns expressed by representatives of the burial industry and the then London Planning Advisory Committee, primarily in respect of the position in London. [15]

  23.  Because of the Home Office responsibility for exhumation law and practice, however, its central interest in the claimed shortage of land for burial has been focused on the implications of the proposed solution. This is because it is proposed that existing cemeteries should be re-used by disturbing existing burials and burying the remains at a deeper level. While such proposals have obvious attractions from the point of view of effective use of land, especially within urban areas, authority to disturb buried human remains for this purpose would be entirely new departure, requiring new legislation and procedures to regulate the process in order to provide, amongst other things, public reassurance as to the propriety with which the development was to be carried out.

  24.  Because of the sensitivities of the proposed solution, and questions about its practicality, it has been felt that consideration should be informed by a wider public view. At this stage, although work has been undertaken on behalf of the burial authorities to estimate realistic available land for burial (see footnote 17), and some research has been carried out to ascertain public attitudes, [16] it is not clear that the facts have been fully established and more work on this seems likely to be required. No decision has yet been taken on how consultation might be most effectively undertaken.


  25.  Burial authorities are authorised, but not required, to provide burial grounds. [17] The Church of England and other religious bodies may also make burial ground available. Private companies, which may or may not be established by Act of Parliament, also offer public burial facilities. New cemetery facilities will be subject to any necessary planning consents (see paragraphs 35-40 below).

  26.  Regulation of cemeteries is diverse. Burial authorities are subject to the provisions of the Local Authorities' Cemeteries Order 1977. Church of England churchyards are subject to ecclesiastical law. Private burial grounds may be subject to the Cemeteries Clauses Act 1847, if incorporated in any Act of Parliament which established the cemetery company, or otherwise to such provisions as may be included in such Acts. If the cemetery is owned by a private company not established for the purpose by an Act of Parliament, no cemetery-specific regulations will apply.

  27.  Whether to offer exclusive rights of burial[18] is a matter for the cemetery authority, but where such facilities are provided by burial authorities under the Local Government Act 1972 they are regulated in accordance with the Local Authorities' Cemeteries Order 1977. The Order similarly regulates depth of burial, the need for grave and burial records and their storage, and the management of memorials (including their removal). The Order also empowers statutory burial authorities to manage, regulate and control their cemeteries, to lay out, repair and provide access to the cemetery, apply for part of the cemetery to be consecrated or set apart for particular denominations, to provide chapels or mortuaries, to set certain fees and charges, and to maintain graves.

  28.  Minimum standards in respect of all burial grounds are maintained by the prohibition on the disturbance of buried human remains, the powers available to the Home Office to require the discontinuance of burials, and commercial considerations. The further Home Office powers, under section 23 of the Burial Act 1857, to require preventative or corrective action to be taken in respect of vaults and places of burial which may be dangerous or raise public health concerns are not known to have been used in recent times, and are likely to be exercised only in extreme cases. If applied in respect of local authority cemeteries, it would cut across local decisions on spending priorities. If applied in cases of private cemeteries, the costs would by default fall to the relevant local authority.

  29.  It is understood to be the practice for burial services in cemeteries and burial grounds to be subject to local requirement. Provisions within the Burial Laws Amendment Act 1880 may also apply so as to require, for example, burials to be conducted in a decent and orderly manner.

  30.  Unless otherwise provided for in any Act of Parliament establishing the cemetery company, the fees chargeable by the company, burial authority or Church are not subject to regulation.

  31.  Professional standards of service and performance in cemeteries are supported through the work of representative bodies, such as the Confederation of Burial Authorities, and organisations such as the Institute of Burial and Cremation Administration. The latter runs training courses, leading to professional qualifications, on the administration of cemeteries, and from time to time issues guidance on specific issues (such as exhumation practice and memorial management). These bodies have also promoted initiatives such as the Charter for the Bereaved, which promotes standards of service.

  32.  The Local Government Act 1999 introduced a new duty on local authorities to secure best value. Best value authorities are required to make arrangements to secure continuous improvements in their services. Key drivers include the use of performance indicators, standards and targets and consultation with the public. Best value authorities are required to carry out fundamental reviews of all their services over a five-year period. Accountability to the public is secured by the publication of an annual best value performance plan.

  33.  Where authorities provide or manage cemetery services, these will need to be subject to best value review (except parish and town councils with a budget of less than £500k. [19]) Reviews provide an opportunity for local authorities to think afresh about how they deliver continuous improvements in providing their services and reassess priorities. Through best value, authorities are being encouraged to adopt far-reaching approaches to procurement and service delivery. This includes, where authorities deliver the same service, exploration of the economies of scale of joint delivery with neighbouring authorities.

  34.  Like cemeteries, provision of crematoria is also a matter for local and commercial decision. It is open to burial authorities[20] to provide cremation facilities, or they may be provided by any company or person by whom a crematorium has been established. Regulation is more coherent. The Cremation Regulations 1930, as amended, apply to all crematoria and require their opening and closing to be notified to the Home Office. The Regulations also require crematoria to be maintained in good working order, to be provided with sufficient number of attendants and to be kept constantly in a clean and orderly condition. Fees and services are not regulated. The Home Office and the Department of Health have powers under the Cremation Regulations to inspect crematoria at any reasonable time.

  35.  For planning purposes, cemeteries and crematoria are not grouped with any other land uses: both are "sui generis". Any attempt to create a new cemetery or crematorium on land previously used for something else would be regarded as a material change of use of land. The developer would have to submit a planning application for consideration by the local planning authority.

  36.  The Development Plan provides the framework for determining the future pattern of development in a local authority's area. Where an adopted or approved Development Plan for the area contains relevant policies, planning applications or appeals must be determined in accordance with the Plan, unless material considerations indicate otherwise. Applications not in accordance with relevant policies in the Plan should not be allowed unless material considerations justify granting planning permission. The planning system is often described as "Plan-led".

  37.  In broad terms, any consideration which relates to planning—that is, to the use and development of land—may be taken into account when an application is being decided. For example, extra traffic, visual impact, fumes and other consequences for local amenity could be material. Relevant national guidance, such as that provided in DETR's Planning Policy Guidance Notes, would also have to be weighted in reaching a decision. PPG2, for instance, says cemeteries can be acceptable in Green Belt. By contrast, matters outside planning, such as the effect of the development on property values, would normally not be material.

  38.  In a cemetery managed by a local authority, however, the authority can carry out certain works, and put up small buildings and structures, without submitting a planning application, by virtue of permitted development rights granted by the Town and Country Planning (General Permitted Development) Order 1995. Similarly, development authorised by a local or private Act or Order would also not require specific planning permission.

  39.  Under Article 10 of the Town and Country Planning (General Development Procedure) Order 1995, where an application is made for development relating to the use of land as a cemetery, the Environment Agency must be consulted. The Agency's concern is the effect of burial sites on aquifers, watercourses, springs and boreholes, and as a statutory consultee in a planning case it can provide informal advice about the risk to any of these. The Groundwater Regulations 1998, which are also the responsibility of DETR, regulate disposals to land and provide the Environment Agency with powers to stop or control activities in or on land which could threaten groundwater. Burial grounds fall within scope of these Regulations. In practice, the Environment Agency would aim to avoid the necessity of using its powers under the Regulations by, for instance, liaising with local authorities at the planning stage, to ensure that the siting and operation of the cemetery would minimise any risk to groundwater.

  40.  Council Directive 85/337/EEC as amended by Council Directive 97/11/EC, on the assessment of the effects of certain public and private projects on the environment, requires environmental impact assessment (EIA) to be carried out before development consent is granted for certain types of projects judged likely to have significant environmental effects.

  The Directive is transposed, in the main, by the Town and Country Planning (Environmental Impact Assessment) (England and Wales) Regulations 1999 (SI No. 293).

  While cemeteries and crematoria are not specifically listed as development in the Directive it is likely they would fall within the general heading of "Urban development projects" in Annex II of the Directive (equivalent to Schedule 2 to the Regulations) and may require EIA if the proposed development is likely to have significant effects on the environment.

  41.  Development Plans may make specific provision for cemeteries and crematoria, along with other community facilities. Anyone concerned about the future pattern of development can participate in the preparation of a Plan. Members of the public also have an opportunity to submit their views to the local planning authority on individual planning applications.

  42.  Air pollution emissions from crematoria are regulated under Part I of the Environmental Protection Act 1990, which is the responsibility of the Department of the Environment. Under this provision, crematoria must be authorised. Authorisations must include conditions aimed at securing the use of the Best Available Techniques Not Entailing Excessive Cost, to prevent, minimise and render harmless emissions. The Secretary of State for Environment, Transport and the Regions issues statutory guidance on what constitutes BATNEEC, and is currently reviewing the guidance issued in 1995 concerning crematoria. Local authorities in England are the regulators for both municipal and private crematoria.


  43.  Municipal cemeteries are funded through the normal mechanisms for the funding of local authority services. They are, however, a trading service, and income is derived from fees and charges, sales and other sources. The income may not necessarily recover the full costs to the authority of providing and maintaining burial grounds. This is because the revenue-earning capacity of a burial ground, from burial fees and the sale of exclusive burial rights, is finite as the burial space available is consumed. In contrast, site maintenance costs can be significant and indefinite. Burial authorities may also need to provide for the cost of maintaining local churchyards which have been closed to further burials under the Burial Act 1853. Such a maintenance responsibility may be transferred compulsorily to the parish or district Council, or equivalents, in accordance with the Local Government Act 1972 (see footnote 6 and paragraphs 46-47 below).

  44.  In 1998-9, expenditure on municipal cemeteries and crematoria in England was £132 million, income was £121 million, and the net cost £11 million. In the previous year (when the expenditure and costs between cemeteries and crematoria were last disaggregated), expenditure was £127 million (of which £87 million was spent on cemeteries), income £108 million (of which £47 million derived from cemeteries) and the net cost was £19 million (a loss of £40 million on cemeteries, but a profit of £21 million from crematoria).

  45.  Cemeteries are eligible for funding in accordance with current Heritage Lottery Fund guidelines. In recognition of the fact that they often represent a "green oasis" in urban areas, they have been funded for their importance in terms of nature and habitat conservation, as well as on account of their intrinsic heritage merit, or for their association with well-known individuals buried there. The Heritage Lottery Fund has so far funded 10 projects involving cemeteries in England, totalling nearly £3.2 million. These include both the restoration or repairs of buildings, and more general improvements or restoration plans for the cemeteries themselves.


  46.  As mentioned above, where a Church of England churchyard is closed to further burials in accordance with an Order in Council under the Burial Act 1853, responsibility for maintenance may be transferred to a relevant local authority after three months' notice of the intention to do so. The transfer is compulsory, not dependent on the condition of the churchyard in question (although the parochial church council is under an obligation to maintain the site in decent order and its walls and fences in good repair), and not dependent on the local authority's ability to meet the additional maintenance costs.

  47.  Many local authorities are known to be concerned with this obligation and the difficulty of making proper budgetary provision. However, it is a provision which continues a practice dating from the middle of the last century. It recognises that the Church of England has for centuries borne the burden of providing burial facilities for the community, that the Church of England, and parochial church councils, are not generally in a position to meet the costs of maintenance indefinitely, and seeks to return the maintenance burden to the community as a whole. However unwelcome such a burden may be for local authorities, they offer the only realistic source of funding, if the churchyard is not to become overgrown and fall into decay.

  48.  Old private cemeteries may present similar problems to old churchyards. They are normally full and cannot be properly used for further burials. They are uneconomic to operate and no private concern would wish to undertake to provide indefinite maintenance. They have little or no commercial value, although in certain cases the land might be suitable for development, subject to planning permission (and sometimes the need for private legislation). In most cases, the relevant local authority has acquired responsibility for the cemetery, either under the provisions of the Open Spaces Act 1906, or in some other way. In some cases, maintenance responsibility has been undertaken by local trusts, with local authority support. Very few such cemeteries continue in private ownership.

  49.  Unlike old Church of England Churchyards, however, there is no straightforward legislative mechanism to bring them under public ownership or otherwise to provide for public funds for their future maintenance. The Home Office does not consider this to be a satisfactory position since such sites may quickly become a public nuisance.

Home Office

December 2000

3   These are defined in the Local Government Act 1972 as the councils of districts, London Boroughs, parishes and communities, the Common Council, and the parish meetings of parishes having no parish council, whether separate or common. Back

4   The Secretary of State for Culture, Media and Sport is responsible for the management and maintenance of Brompton Cemetery. The responsibility is exercised through the Royal Parks Agency. Back

5   Sections 214 and 215 of the Act, and Schedule 26. Back

6   Home Office records indicate that approximately 4,000 churchyards are subject to Orders in Council discontinuing burials in all or part of the burial ground. Back

7   Under section 215 of the Local Government Act 1972. Back

8   Section 25 of the Burial Act 1857. Back

9   Under the Disused Burial Grounds (Amendment) Act 1981, a disused burial ground owned by or on behalf of a church or other religious body may be built upon or otherwise developed provided the buried remains are removed in accordance with any Home Office directions. Similar provisions are made in respect of redundant Church of England churchyards under the Pastoral Measure 1983 and, in respect of land acquired by local authorities and similar public bodies, under the Town and Country Planning Acts. Local and private legislation may make comparable provisions. If the development will not disturb the remains, the Home Office may issue a dispensation order to relieve the requirement to remove them. The legislation also makes provision for the orderly disposal of memorials and monuments. Back

10   Section 214(6) and section 215(3) of the Local Government Act 1972. Back

11   The Chartered Institute for Public Finance has recorded the amount of land set aside for future use for burial purposes by local authorities (780 hectares in England in 1998). Back

12   For example, so-called "green" burial grounds where graves are overplanted with trees so that in due course the cemetery will become or revert to a wooded area. Another development, so far limited, is the provision of above-grounds catacombs or mausolea. Back

13   It is understood that burial authorities may charge higher fees for the burial of persons from outside their areas. Back

14   In 1960 cremation occurred in 35 per cent of deaths, by 1970 55 per cent and by 1990 70 per cent. Back

15   Burial Space Needs in London, 1997, a study for the London Planning Advisory Committee by Halcrow Fox in association with The University of York's Cemetery Research Group and The Landscape Partnership, and Planning for Burial Space in London, 1997, by the London Planning Advisory Committee in association with the Confederation of Burial Authorities, the Institute of Burial and Cremation Administration, and the Corporation of London. Back

16   Reusing Old Graves, 1995, Davies and Shaw, University of Nottingham. Back

17   Under section 214 of the Local Government Act 1972, local burial authorities may provide and maintain cemeteries either within or outside their areas. They may also contribute to the expenses incurred by others in providing or maintaining cemeteries for the use of their inhabitants. Back

18   The right to determine who may be buried in a particular grave. If there is no exclusive right to burial, it is open to the burial authority to bury unrelated bodies in the same grave, subject to sufficiency of depth and provided any existing buried remains are not disturbed. Such graves are known variously as common, public or "pauper" graves. Back

19   Only 41 parish and town councils have budgets in excess of £500k. Back

20   See footnote 1. Back

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