Tier 1, 2, and 3 Risk Assessment For Burial Ground Development

The burial of corpses and their subsequent degradation may potentially cause groundwater pollution. Burial Ground Developments (new or extended) are therefore controlled by the Local Authority through the Planning Process, with the Environment Agency (EA) as key statutory consultee. On 2nd October 2023 the EA introduced a revised approach to the regulation of new cemetery developments under the Environmental Permitting (England and Wales) Regulations 2016. The approach is detailed within their guidance “Protecting Groundwater from Human Burials” (October 2023).

BOLD Environmental provides our Clients with the Specialist Technical Advice and Groundwater Risk Assessment Services to enable the EA to establish the potential pollution risk to groundwater from a specific cemetery development, and to aid determination of planning applications. BOLD uses the three tiered approach to assessing the risks from potential cemetery sites as defined within EA guidance “Cemeteries and Burials: groundwater risk assessments” (2017, updated 2023). Our assessments also address the requirements for groundwater protection, as detailed in “The Environment Agency’s approach to groundwater protection” (EA, 2018).

Each tier of assessment can be summarised as follows:

  • Tier 1: Risk Screening – A preliminary desk based assessment to provide a site specific Conceptual Model detailing the environmental setting of the site. Tier 1 includes the identification and assessment of hazards, and a qualitative assessment of hazard significance with reference to the scale and location of the proposed development.
  • Tier 2: Preliminary Quantitative Risk Assessment – Comprises a detailed desk study and (where appropriate) a preliminary site investigation. Completion of this tier is required when an individual site is designated as presenting an “Medium Risk” to Controlled Waters (groundwater or surface water); or in cases where the risks are not clearly defined. Tier 2 requires more detailed knowledge of soil type, geological strata, groundwater levels and potential contaminant loading. Tier 2 should enable determination as to whether potential impacts are acceptable; and enable conditions to be put in place to ensure pollution does not take place.
  • Tier 3: Detailed Quantitative Risk Assessment – This tier of assessment is required if risk is considered “High” or if further information is required. This tier requires groundwater modelling and assessment, for which we typically use the ‘Annex J5: Infiltration Worksheet v2.0’ (EA, 2014), a technical annex within the EA’s H1 Environmental Risk Assessment framework.

The extent to which all tiers are required depends on the nature of the proposed development, the environmental setting, and whether or not baseline groundwater quality is readily available.

For further information and a no obligation consultation please get in touch.