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Is Southwark Council misleading the Environment Agency?

21 September 2015

The Save Southwark Woods campaign (SSW) has discovered that the London Borough of Southwark has misrepresented its plans for new burial at Camberwell Old and New Cemeteries to statutory consultee the Environment Agency (EA).

On Monday 14th September, Southwark planners sent an email to the EA, saying that two planning applications for the Cemeteries had been made for “some groundworks and the laying of paths” and a third one (not sent) “for a fence” (see Southwark’s email attached). Web links to only the first two applications were included.

The email does not mention that all three planning applications relate to developing large new burial sites in drinking water catchment areas, creating possible risks to public health. Nor that they involve felling hundreds of trees and excavating 12,000 tonnes of material, creating possible air pollution and flood risks.

And all three applications involve a material change of use. The site in Camberwell New Cemetery (Area D1) is virgin land, a rare London wooded hillside adjacent to a remnant of the Great North Wood. The site in the Old Cemetery (Area Z) is woodland that has not been used for burial for over 60 years and includes ancient and veteran trees. Both are registered Sites of Importance for Nature Conservation (SINCs).

Camberwell New Cemetery in Nunhead and Camberwell Old Cemetery in East Dulwich are both in Groundwater Source Protection Zones [SPZs] in a catchment area for London’s drinking water.
Camberwell New Cemetery in Nunhead and Camberwell Old Cemetery in East Dulwich are both in Groundwater Source Protection Zones [SPZs] in a catchment area for London’s drinking water.

The first two applications are for development of burial space, in Camberwell Old Cemetery (Area Z) and Camberwell New Cemetery (Area D1).

The third application, which Southwark chose not to send to the EA and described in their email as “for a fence”, is in fact for “boundary works, planting and new fence in preparation for development of new burial space (Area Z).” (Application Form 6, signed by Southwark’s Strategic Director of Environment & Leisure Deborah Collins on 5th August, attached).

“Southwark Council appears to be misleading the Environment Agency.” said Save Southwark Woods spokesperson Blanche Cameron “Why didn’t they say these applications are to create new burial? Does Southwark council think they are above complying with their statutory duties to Public Health, that they can brush the Environment Agency’s procedures aside with a quick email?”

The Environment Agency’s planning advisor responded to Southwark saying: “We do request to be consulted on development relating to using land as a cemetery, including extensions”.

Southwark Council has failed to carry out their statutory duty to consult properly with the EA on plans for development of new burial, with potential risks to public health

There is a Statutory Consultee Form for alerting the EA to development for new burial, which the council decided not to use. Instead, they sent a brief email, misrepresenting the type and extent of the works proposed.

In the email, Southwark say they have not filled in the statutory consultation forms because it would have triggered a delay to the planning application meeting, currently set for 6th October.

Camberwell New Cemetery in Nunhead and Camberwell Old Cemetery in East Dulwich are both in Groundwater Source Protection Zones [SPZs] in a catchment area for London’s drinking water.

They state in the email they are only contacting the EA now because they have had “a number of objections that relate to the site being in a SPZ”. But Southwark has had a statutory duty to consult the EA from the beginning – not because people have now found out about their plans, but because new burial creates potential public health risks.

Southwark already knows that these cemeteries suffer from groundwater contamination by burial

Southwark created new burial areas along the Woodvale boundary in Camberwell Old Cemetery were created in 2013, by cutting down an ancient hawthorn hedgerow and mounding over existing graves. It is believed Southwark did this without planning approval or permission from the EA. They are now using this area for burials.

It is illegal to bury bodies in standing water yet last winter, new burials in the Old Cemetery stood waterlogged for weeks with contaminated surface water flowing directly out onto the streets (see photos attached).

“We will be contacting the EA and Southwark Council to find out what permissions if any were granted for the new Woodvale burial spaces. Burials in this area are possibly illegal. If so they must stop immediately while the Environment Agency investigates potential public health risks,” said Blanche Cameron.

Southwark council has been developing plans for their extensive new burial strategy for over five years but haven’t consulted the EA

These three planning applications are only Phase 1 of a huge scheme to create 4,585 new burial spaces in the Camberwell Cemeteries, as well as excavate thousands of old graves for more new burial.

Southwark has been working on these extensive burial plans for over five years. The council’s planning application consultation period is due to end on October 5th but the Council waited until September 14th to send a brief email that did not mention burial.

“Southwark has contacted the EA for the first time in five years, just before the planning meeting, and don’t even mention the applications are for new burial. No doubt Southwark will now try to pin the blame on a minor officer – but who gave the order not to consult the EA about these major plans?” questioned SSW spokesperson Blanche Cameron.

Save Southwark Woods demand the council stop their unsafe plans.

Nearly 10,000 people want Camberwell Old and New Cemeteries declared nature reserves.