Which Reports Do I Need

Supporting documents for a natural burial ground

8 min readBy PlanScope Editorial Team

A natural burial ground has almost no floorspace, so the usual thresholds do not apply. The application stands or falls on hydrogeological risk, access and long-term management.

Natural burial ground planning turns on groundwater rather than on buildings. The document that decides most applications is a hydrogeological risk assessment, because the Environment Agency will object if burials could pollute an aquifer or a watercourse, and no amount of landscape work rescues a site that fails on water. Everything else in the pack supports that central question or deals with access and the change of use of farmland.

A natural burial ground is also an unusual proposal in planning terms. There is almost no floorspace, so the familiar thresholds that trigger a transport assessment or a major application do not bite. The constraints are in the ground and in the access lane.

Changing a field from grazing to burials is a material change of use under section 55 of the Town and Country Planning Act 1990, so it needs express planning permission. A burial ground does not sit within any class in the Use Classes Order, which makes it sui generis, and that has two consequences worth knowing early. There is no permitted development right to fall back on, and any later addition such as a ceremony building or a scattering area is a separate planning question rather than a change within the same class.

Operational development is usually modest: a track, a small car park, a gate, perhaps a timber shelter and a composting toilet. Each is development in its own right. Put all of it on the application drawings rather than leaving it for later.

A private burial ground does not need a licence to open, and no faculty is involved unless the land is consecrated. What the operator does need is a register of burials and an accurate grave plan, kept permanently, because the land stays burdened by the burials long after the business stops trading. Councils increasingly ask how that record will survive a change of ownership, and a sentence in the planning statement answering it is worth writing.

Hydrogeological risk and source protection zones

Start by finding out what is under the field and who abstracts water nearby. The Environment Agency's groundwater protection position statements set out the criteria it applies to new cemeteries and burial grounds, and the figures it has published for many years are strict:

  • No burials within 250 m of any well, borehole or spring used for a potable supply.
  • No burials within 30 m of any watercourse or spring.
  • No burials within 10 m of a field drain or other dry ditch.
  • At least 1 m of unsaturated subsoil beneath the base of each grave, with the base above the highest recorded water table.

Treat those as the opening position and verify the current wording, because the statements are revised. A site inside Source Protection Zone 1 is very unlikely to be acceptable at all. A site in Zone 2 or 3, or over a principal aquifer, needs a quantified assessment rather than a reassuring paragraph.

The assessment itself is specialist work for a hydrogeologist, and it normally involves trial pits or boreholes, groundwater level monitoring across more than one season, permeability testing and a conceptual model of the pathway from grave to receptor. That last point catches people out. Monitoring over a dry autumn tells you nothing about the water table in February, so start the monitoring early. A year of records is not unusual for a site near a river.

Soil depth, water table and the grave specification

The design of the burial area follows the ground conditions rather than the other way round. Where the unsaturated zone is thin, the usual response is shallower graves at a lower density, single depth only, with the deepest part of the site left as meadow or planting.

Set out in the submission the grave depth you are applying for, the soil cover above the coffin, the spacing, the total capacity and the burial rate you expect in the first five years. Councils use that to judge traffic and to write a condition. The Environment Agency uses it to test the risk model. A plan showing phased burial areas, with the first phase on the highest and driest ground, is more persuasive than a single hatched block covering the whole field.

Shrouds and untreated timber or wicker coffins are the norm on natural sites, and they matter to the risk case because embalming fluids and coated caskets are part of what the Agency worries about. Say in the application what the site rules will be, and accept a condition tying them down.

Access, parking and visitor numbers

Funeral traffic arrives in a single tight peak and then the lane is empty for days. That pattern is why a full transport assessment is rarely proportionate and why a short transport statement with a visibility assessment usually is.

Cover five things. The existing access and whether it can achieve the visibility splays the highway authority asks for at the recorded traffic speed. The width of the lane and whether two cars can pass. Parking provision for the largest expected gathering, with an overflow area on grass. Hearse turning, shown with a swept path. And how a funeral cortege will arrive and leave without blocking the highway.

Surfacing deserves a sentence of its own. A bound car park on a greenfield site creates run-off that then needs managing, so most natural burial grounds use reinforced grass or permeable gravel, which also keeps the character the operator is selling.

Landscape, planting and management for the long term

The landscape case is the positive part of the application. A meadow with scattered trees, no headstones above a stated height, native hedgerow restoration and a mown path network is a better use of a tired arable field in many settings, and the application should make that argument with drawings rather than adjectives.

A landscape strategy should show the planting plan, the species mix, the mowing regime, the memorial rules and who maintains what. Where the site sits in a National Landscape or close to a protected view, a landscape and visual assessment with agreed viewpoints will be expected as well.

Management is the part councils probe hardest. Burial grounds outlive their founders, and an officer will want to see a management plan with a funded mechanism behind it, whether that is a charitable trust, a sinking fund or a covenant on the land. Expect a section 106 agreement or a long-term management condition.

Ecology, net gain and the habitat the site creates

Commission a preliminary ecological appraisal before the layout is fixed. Councils expect these to be written by a suitably qualified ecologist and professional review is strongly advised, because the appraisal decides whether further survey work is needed and when. Grassland that looks unremarkable in November can turn out to be species-rich in June, and that changes the scheme.

Mandatory biodiversity net gain applies to this kind of development, so a biodiversity net gain assessment using the statutory metric has to accompany the application along with the information needed for the biodiversity gain plan. Under the Environment Act 2021 regime the metric must be completed by a competent person and the gain plan is approved by the local planning authority after permission, so a draft is a starting point for that professional rather than a substitute.

The good news is that burial grounds usually gain easily. Converting arable to species-rich grassland with tree planting generates habitat units, and the 30 year management obligation is one the operator wanted anyway. The arithmetic still has to be done properly by someone competent to do it.

Broader land use change raises some of the same questions, and our note on reports for a rewilding or land use change scheme covers the overlap.

Agricultural land quality and the sequence of work

If the field is in Grades 1, 2 or 3a it counts as best and most versatile land, and national policy expects poorer land to be used in preference. An agricultural land classification survey by a soil scientist settles the grade, and the published provisional maps are too coarse to rely on for a single field.

Burial is a reversible use in a way that houses are not, and that argument is worth making, though it needs the honest qualification that nobody will plough a burial field again.

Sequence the work like this:

  1. Desk check: source protection zones, aquifer designation, flood zone, land quality, designations and heritage records.
  2. Soil and groundwater monitoring started, because it sets the programme.
  3. Ecological appraisal and the net gain baseline, timed to the survey season.
  4. Access and visibility assessment with the highway authority.
  5. Layout, phasing and landscape design, informed by all of the above.
  6. Planning statement, management plan and the supporting pack.

This is general guidance, not legal advice; the validation list differs between councils and the Environment Agency's position should be confirmed in writing before you commit to a site.

Specialist water, ecology and soils work needs the relevant qualified professional. You can enter your postcode on PlanScope to see the constraints picked up on your site and which of the 66 reports are likely to be asked for. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

Does a natural burial ground need planning permission?

Yes. Changing agricultural land to burials is a material change of use under section 55 of the Town and Country Planning Act 1990, and a burial ground falls outside every class in the Use Classes Order. There is no permitted development route, and tracks, parking and shelters are additional operational development that belong on the drawings.

What does the Environment Agency look at?

The pathway from a grave to groundwater or surface water. Its published position statements set separation distances from potable supplies, watercourses and field drains, and expect unsaturated subsoil beneath the grave base. Expect to provide trial pits, seasonal groundwater monitoring, permeability testing and a conceptual risk model prepared by a hydrogeologist.

How long does the groundwater monitoring take?

Plan for at least two seasons and often a full year. Water levels measured in a dry autumn will understate the winter maximum, and the assessment needs the highest recorded level rather than a snapshot. Starting monitoring before the layout is designed usually shortens the overall programme rather than lengthening it.

Does biodiversity net gain apply to a burial ground?

Yes, the mandatory regime under the Environment Act 2021 applies to this kind of development. The statutory metric must be completed by a competent person and the biodiversity gain plan is approved by the council after permission. Converting arable land to species-rich grassland with tree planting usually delivers the uplift comfortably.

Can the land be used for farming again afterwards?

In law the burials do not stop agricultural use returning, but in practice nobody cultivates a burial field. Councils therefore treat the change as effectively permanent and ask who will maintain the land in perpetuity. Expect a management plan, a funding mechanism and either a planning obligation or a long-term condition.

Sources and further reading

natural burial groundchange of usegroundwaterhydrogeologybiodiversity net gainrural planningagricultural land

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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