Chapter 5 Social Infrastructure

5.1.1 Social infrastructure covers a range of services and facilities that meet local and strategic needs and contribute towards a good quality of life. It includes health provision, education, community, play, youth, early years, recreation, sports, faith, criminal justice and emergency facilities. There are a wide variety of providers delivering these services, from large state-funded organisations, public and private institutions and specialist providers, to charitable trusts, the voluntary sector, community and faith groups, and individuals. Alongside more formal provision of services, there are informal networks and community support that play an important role in the lives of Londoners. This chapter primarily addresses the delivery of social infrastructure facilities. Many service providers may operate from or require other types of space, for example cultural facilities (addressed in Chapter 7) or offices (addressed in Policy E1 Offices). Green infrastructure in all its forms is also a key component of social infrastructure, and is addressed separately in Chapter 8, Policy G3 Metropolitan Open Land and Policy G4 Open space.

5.1.2 Social infrastructure plays an important role in developing strong and inclusive communities. It can provide opportunities to bring different groups of people together, contributing to social integration and the desirability of a place.

5.1.3 Planning for social infrastructure in London is complex. There are a wide range of providers and stakeholders and the degree of clarity around future provision and funding varies. It is therefore important that boroughs work collaboratively with service providers and other stakeholders, including the local community, to fully understand existing and future social infrastructure needs and plan appropriately for these, including through their infrastructure delivery plan and the Community Infrastructure Levy. This will also help facilitate an integrated approach to service delivery.

5.1.4 Needs assessments should be informed by both an understanding of the demographic make-up and socio-economic data required by Policy D1 London’s form, character and capacity for growth as well as an audit of existing facilities and services. Supplementary Planning Guidance will be developed to inform this.

5.1.5 The loss of social infrastructure can have a detrimental effect on a community. Where possible, boroughs should protect such facilities and uses, and where a development proposal leads to the loss of a facility, require a replacement that continues to meet the needs of the neighbourhood it serves. A realistic proposal for replacement social infrastructure should be able to demonstrate funding, appropriate site availability and timely delivery of adequate facilities. To further protect against the loss of social infrastructure that is valued by a local community or group, boroughs should consider approving the designation of a facility as an Asset of Community Value (ACV) if put forward by the local community.

5.1.6 In cases where social infrastructure premises may be deemed redundant and a replacement facility is no longer necessary or appropriate, other forms of social infrastructure should be considered for the site or part of the site to help meet other community needs, before alternative uses are pursued.

5.1.7 It is recognised that there will be cases where social infrastructure providers are undertaking an agreed programme of social infrastructure re-provision or service reconfiguration, such as has been seen within healthcare. Where social infrastructure premises are deemed redundant as part of this process, such losses may be acceptable in line with Parts D and F of Policy S1 Developing London’s social infrastructure and Policy S2 Health and social care facilities and any related information or guidance to achieve the overall aims of the programme and to continue to meet the needs of Londoners.

5.1.8 In all cases, where housing is considered an appropriate alternative use, opportunities for affordable housing provision should be maximised.

5.1.9 Social infrastructure should be easily accessible by walking, cycling and public transport in accordance with the Healthy Streets Approach.

5.1.10 It is important to consider the way that social infrastructure integrates with other facilities and the way people who live or work in the area want to access it. Shared use and co-location of facilities should be encouraged, to align service provision, use land more efficiently and facilitate opportunities for different groups of people to come together, encouraging further inclusion and community participation. Shared use and co-location will help facilities and service providers work in a more coherent and joined-up way, and share maintenance and management costs. It could reduce the need to travel thereby improving accessibility. Examples of this include schools opening their facilities out of hours for use by the community, the co-location of health and sports facilities, or the co-location of facilities with housing to ensure effective usage.

5.1.11 Voluntary and community groups often find it difficult to find premises suitable for their needs. Unused or underused facilities should be brought into use, where possible, to help address these needs. The additional use or reuse of places of worship should be considered for providing accommodation for other traditions or faiths and/or wider community functions.

5.2.1 London’s health care services are vital to maintaining and improving Londoners’ quality of life. The health service is also one of the capital’s major employers, with over 200,000^[82] people working in the NHS in London. Several factors affect the demand for health services and facilities. These include a growing and ageing population, an increase in complex and long-term health conditions that need an integrated approach, and changes in patients’ personal preferences. New treatments and technologies are also transforming the ability to predict, diagnose and treat conditions. Policies throughout the Plan seek to support preventative health measures and contribute positively to the wider determinants of health. This policy facilitates this by supporting the integrated service delivery of health and social care facilities and services.

5.2.2 The NHS Long Term Plan^[83] builds on the NHS Five Year Forward View, which identified the need to prevent avoidable illness and transform the way that care is organised and delivered to meet increasing demands for healthcare within the resources available. It describes the following priorities:

• increasing support for people to manage their own health better, for example through diabetes prevention and management and online therapies for common mental health problems
• undertaking a higher proportion of healthcare in community rather than hospital settings
• redesigning and reducing pressure on emergency hospital services establishing digitally-enabled primary and outpatient care across the NHS
• making best use of available assets, including more flexible approaches to how facilities are used and the overall configuration of the health estate, which requires a mix of dis-investment in older, out-of-date facilities and re-investment in more modern, fit for purpose estate
• ensuring that models of care change and continuously evolve
• ensuring that existing and planned new health infrastructure supports and facilitates change.

5.2.3 There are currently four broad types of health infrastructure provision:

• primary care – GP practices, plus community pharmacists, dentists and opticians
• community healthcare – this covers a wide range of diagnostic and healthcare services, including non-acute mental health services, which provide a means of delivering care closer to home than from a hospital setting
• acute provision
• specialist provision.

5.2.4 Sustainability and Transformation Plans (STPs) were produced by the NHS and local Government in 2016 to set out how local health and care services would evolve and become sustainable by 2020/21. Five sub-regional STPs were developed in London. These five-year plans set out in varying levels of detail the proposed changes to NHS hospital estates and primary care facilities in each area. Local NHS organisations will increasingly focus on population health and partnerships with local authority-funded services through the development of new integrated care systems (ICSs) that will emerge from sustainability and transformation partnerships. ICSs will deliver the integration of primary and specialist care, physical and mental health services and health and social care.

5.2.5 Whilst there is no one-size-fits-all model of care, and an increasing blurring of the boundaries between primary, secondary (acute) and tertiary (specialist) health services, there are some broad underlying principles that underpin the planning of new facilities or changes to existing facilities. The NHS General Practice Forward View^[84] and the NHS Long Term Plan support the provision of primary care at greater scale, with larger practices and/or more joined up networks of GPs offering a wider range of services to patients, including extended opening hours and widespread use of digital consultations. This means fewer GP practices serving larger patient catchments (perhaps 10-20,000 people per practice) and operating from larger premises than is the norm at present. Models of community healthcare are based around larger population catchments (50,000 or more people) or localities to ensure individual services are viable, and to maximise the benefits of integrating and/or co-locating services in community healthcare centres or hubs, or in more flexible ways across localities or networks of service providers.^[85]

5.2.6 In assessing the need for new health and social care facilities, consideration should be given to the location, scale and timing of new residential development, and the quality, capacity and accessibility of existing health and social care facilities to meet some or all growth. Joint Strategic Needs Assessments produced by local Health and Wellbeing Boards describe the current and future health and wellbeing needs of the local population and identify priorities for action which are set out in more detail in the Boards’ Health and Wellbeing Strategies. These documents are valuable sources of evidence to inform the development and review of Development Plans.

5.2.7 Where population growth and change is taking place at modest levels, it may be possible to accommodate this through a combination of efficiency savings, service reconfiguration and small adjustments in capacity, for example through the conversion of non-clinical space to consulting or treatment rooms. In areas of high or concentrated population growth, particularly in Opportunity Areas, it is more likely that new primary and community facilities or capacity will need to be provided. Boroughs have a key role to play in ensuring that the need for health and social care facilities is assessed, that sufficient and appropriately-located sites are allocated for such facilities, and that mechanisms are in place to secure their provision through, for example, Section 106 or Community Infrastructure Levy contributions.

5.2.8 The co-location of facilities with other uses, such as other forms of social infrastructure or housing, is encouraged to use land more efficiently and to enable a more integrated service delivery.

5.2.9 Development and regeneration proposals for an area provide an opportunity to re-think how land and buildings are used and whether there is a more optimal configuration or use of that land. Hospital reconfigurations are an example where more intensive and better use of a site can lead to a combination of improved facilities and the creation and release of surplus land for other priorities. The London Estates Board aims to improve the way surplus and underused NHS assets are identified and released, and provide a single forum for estate discussions in London, ensuring early involvement of London Government partners. Membership includes NHS partners, local Government, the GLA and national partners (central Government, NHS England, One Public Estate and the national NHS property companies).

5.3.1 Access to high quality education and training has a profound effect on people’s life chances and is one of the most powerful ways to break down inequalities and improve social mobility. Every child, young person and adult should be given the best possible chance for success and be equipped to make the most of the economic opportunities the capital has to offer. High quality education and training provision, including the allocation of sufficient sites and the development of childcare facilities, schools, colleges and universities in appropriate places, will not only help to provide greater educational choice but will also improve skills, which is critical in tackling disadvantage. Good quality education and training are vital for supporting people into sustainable employment, which is also essential to London’s continued economic success.

5.3.2 Access to affordable, accessible and high-quality childcare (pre-school and school age) provision can play a significant role in children’s development and positively influence school-readiness, future educational attainment, economic participation and health. Universal, high-quality, early childhood education and care not only benefits the whole population but can particularly benefit children from the most disadvantaged backgrounds. As well as the positive benefit for children, it also helps to enable parents to go back to work.

5.3.3 It is estimated that an additional 100,000 childcare places will be needed between 2016-2041.^[86] The Childcare Act 2006 places a duty on local authorities to ensure that there are enough childcare places to enable parents to work or train, and also to ensure that there are sufficient funded early education places for all three and four year-olds within the local authority area. In consultation with parents, the private, voluntary and independent sectors, and other key partners, boroughs should ensure the location and provision of a range of childcare services in different types of settings to meet the needs of local communities.

5.3.4 Childcare facilities should be safe, accessible for all, and provide both indoor and outdoor learning opportunities and should be provided within new housing and/or commercial developments where there is a need. Nurseries should be incorporated into new primary schools where appropriate.

5.3.5 There is a growing need for school places in London, with projected need for 705,000 mainstream state-funded primary school places required for the academic year 2018/19. This is an increase of 7,000 over the number of places required in 2016/17. The level of need is projected to fall to 686,000 places a year by 2027/28. In 2016/17, there was a need for 403,000 places in mainstream state-funded secondary schools. The number of places required is projected to increase by 65,000, over the period to 2027/2^[87] This need, particularly for secondary school places, requires a strategic approach to delivery, making it harder to quantify within individual boroughs. Boroughs are encouraged to work together to meet the needs for secondary school places. Where possible, sites for schools should be allocated within Development Plans.

5.3.6 There is a need for an increase in Special Educational Needs and Disability (SEND) provision in London and it is important that these places are planned for. Some of this provision will be within mainstream schools and some within specialist schools. It is important that all schools are designed to be accessible and inclusive, meeting the highest standards of accessible and inclusive design (see Policy D5 Inclusive design and Area guidelines for SEND and alternative provision: BB104 ).^[88]

5.3.7 The London Schools Atlas^[89] is an interactive map and dataset enabling users to view both existing patterns of schooling across the capital, and projections of future changes in the school age population. The Atlas is intended to be a resource for both parents and school place planners that supports collaborative working between providers in London.

5.3.8 Higher education in London provides an unparalleled choice of undergraduate and postgraduate degrees, continuing professional development, advanced research, and infrastructure to support business growth, such as incubation space and business support services. It is also a significant employer and attracts major international companies able to benefit from universities’ research reputations, such as in pharmaceuticals and life sciences. Universities also play a vital part in ensuring Londoners have the higher order skills necessary to succeed in a changing economy, and for the capital to remain globally competitive. The Mayor has established a forum for higher education institutions and further education establishments to work with boroughs and other stakeholders to plan future developments, including student accommodation, in locations which are well-connected to public transport.

5.3.9 Access to further education (FE) plays a key role in skills development and life-long learning and assists with Londoners’ progression into, and through, sustainable employment, including apprenticeships. There is a predicted increase in demand for FE provision, due to the growing number of 16-19 year-olds, and the new requirement for all young people to remain in learning until they are 18. Meeting this growing demand will require strategic planning and working across boroughs. FE institutions also provide valuable community facilities and services. The Mayor will continue to support the enhancement of FE colleges and other training facilities through the Skills for Londoners Capital Fund.

5.3.10 The design of education and childcare facilities is critical to the creation of a good learning environment. Education and childcare facilities should be in locations that are easily accessible on foot, by cycling or using public transport. The design of entrances to schools and playgrounds is important in ensuring that children are encouraged to walk and cycle to the school gate and can do so safely. Facilities should be located away from busy roads, with traffic calming at entrances, to benefit from reduced levels of air pollution, noise and road danger. Where possible, natural features such as trees, greenery, forest schools and spaces for food growing should be incorporated into playgrounds and school sites, recognising both the health and educational benefits these can provide. Healthy and safe routes to education and childcare facilities, should be considered through the design process.

5.3.11 The Department for Education gives area guidelines for mainstream schools.^[90] Accepting that these guidelines can sometimes be difficult to achieve in London, innovative design solutions should be considered in order to meet the needs of the school, including the provision of outdoor space.

5.3.12 School and college facilities – in particular sports, play, training and meeting facilities – should be capable of use by the wider community outside their main operating hours. They can provide venues for a range of community activities, including nurseries, children’s centres, cultural, youth and sports activities. Designing schools and colleges with this shared use in mind, and ensuring they are safe for a range of uses, also allows for more adaptability around changing work and lifestyle patterns, and extended childcare and holiday provision. Sharing of facilities such as sports pitches and multi-use games areas and locating schools next to parks and open spaces can also further encourage the shared use of space, particularly where space on a school or college site is limited. Education and childcare facilities could also be co-located with other uses such as housing and mixed-use developments at higher densities.

5.4.1 Safe and stimulating play is essential for children and young people’s mental and physical health. It is not just an activity confined to playgrounds and play areas but is something that can be done in all aspects of a child’s life, in a wide variety of locations and environments. Accessing a variety of opportunities for play and being able to be independently mobile within their neighbourhood, is important for children and young people’s wellbeing and development. When preparing needs assessments, boroughs should consult with children and young people to ensure their needs are understood in terms of existing and future provision.

5.4.2 Many children and young people, however, find that there are limited opportunities for them to play in their local neighbourhood. This is often not because of a lack of formal play provision, but due to restrictive street design and layouts, poor links between spaces for play and recreation, and the threat of busy roads and traffic. Developments should encourage children and young people to move around freely through safe streets and footpath networks that connect to more formal play provision, green spaces and parks, and that follow the Healthy Streets Approach.

5.4.3 It should be recognised that children play in all sorts of spaces, including playgrounds, playing fields, skate parks and other recreation areas and this should generally be encouraged and taken account of in the design and layout of development. Where formal play provision is provided in new developments, it should be free, well-designed, accessible, inclusive and stimulating, and should balance the need to be safe whilst also providing an element of risk, which is important for children’s development. It should integrate into the wider network of public open spaces and not be severed from the rest of a neighbourhood by physical barriers such as main roads. Play provision should be overlooked in some way to allow for a level of informal community supervision and generate a sense of safety and security. Integrating natural environments into play provision is encouraged, acknowledging the benefits to learning, and to help to support a green infrastructure network across the city.

5.4.4 There should be appropriate provision for different age groups, including older children and teenagers. Particular consideration should be given to consultation with children and young people in the design of new provision to understand their changing needs. The needs of parents and carers should also be considered in the design of these spaces. Appropriate arrangements for management and maintenance of play and communal facilities should be provided. Youth facilities for young people should also be incorporated where possible to ensure that young people have suitable spaces to meet and play and feel welcome and included in developments and the public realm.

5.4.5 Formal play provision should normally be made on-site and provide at least 10 square metres per child to address child occupancy and play space requirements generated by a development proposal. Supplementary Planning Guidance will provide additional detail on the application of this benchmark and other implementation issues. Where development is to be phased, there should be an early implementation of play space.

5.4.6 Off-site provision, including the creation of new facilities or improvements to existing provision, secured by an appropriate financial contribution, may be acceptable where it can be demonstrated that it addresses the needs of the development whilst continuing to meet the needs of existing residents. This is likely to be more appropriate for the provision of play facilities for older children, who can travel further to access it, but should still usually be within 400 metres of the development and be accessible via a safe route from children’s homes. Schools, school playing fields and other facilities can also provide an important contribution to play and informal recreation facilities and should be encouraged to allow community access to facilities out of hours.

5.4.7 Through the development of play strategies, boroughs should ensure the integration of play provision and child-friendly neighbourhoods into other borough strategies. Boroughs are encouraged to collaborate when developing strategies to ensure play spaces are provided in an integrated way and to help create child-friendly neighbourhoods across borough boundaries.

5.5.1 Sport and recreation facilities are important components of social infrastructure. Both formal and informal facilities should be provided, to encourage physical activity and deliver a range of social, health and wellbeing benefits to communities. People take part in various forms of sport and recreation which require a number of different types of facility. Many activities require minimal facilities, and often an open space or community hall can be sufficient.

5.5.2 Current provision of swimming pools, artificial grass pitches (AGPs), and sports halls is not meeting demand.^[91] The need is most significant for AGPs where only 55 per cent of demand is currently being met. Swimming pools currently meet 93 per cent of total demand across London and sports halls meet 85 per cent of demand. For all types of facilities, the level of unmet demand is projected to increase by 2041 if no new facilities are provided. Increasing the catchment areas of existing facilities by improving public transport accessibility and access by walking and cycling, plus extending their opening hours, could increase their availability and potential number of users. Where new facilities are to be provided, they should be located in accessible locations, with the ability to maximise opening hours.

5.5.3 It is essential that boroughs plan strategically for future provision of these core sports facilities. Boroughs should assess the need for sport and recreation facilities to ensure appropriate levels of provision and help tackle inequality of access in London, particularly in areas or for groups with low participation. By their nature, sports facilities often form a part of open space, so sports and open space needs assessments should have regard to one another. Built sports facilities should only be accommodated on green open space if that area has been identified as surplus to requirements as per an open space strategy or the development is for alternative sports and recreation provision, the needs for which clearly outweigh the loss of green open space.

5.5.4 Up-to-date playing pitch strategies can be used to protect and enhance the use of existing playing fields and help to plan for where more are needed. Sport England provides guidance on the preparation of these strategies, which underscores the importance of a strategic approach to provision to take account of demand for facilities crossing borough boundaries, particularly in relation to specialist activities.

5.5.5 Specialist sporting venues and stadiums also have a role to play in providing facilities and enabling wider access to sport, as well as having an important cultural value.

Figure 5.1 - Walk London Network

5.5.6 The co-location of sports facilities should be encouraged, particularly within new and existing schools, colleges, commercial schemes and community centres. This will help ensure the right mix of facilities in the right places to meet sporting demand and to increase participation.

5.5.7 Lighting can be important for the accessibility of outdoor sports facilities and can help to improve their use. The form of lighting required will depend on the facility and its use, but efforts should be made to minimise the impact on the surrounding areas, and not to cause a demonstrable harm to the local community or biodiversity. The hours of use of lighting should be agreed early in the process.

5.5.8 Places that are designed for people to be active and to move around freely will also encourage more physical activity in people’s daily lives. Existing networks, such as the Walk London Network, also help to encourage this further.

5.6.1 Public toilets are a vital facility, both for Londoners and visitors to the city. They are especially important for certain groups including disabled people, older people, people with babies and young children and pregnant women, as well as tourists and visitors who may be less familiar with their surroundings. Public toilets can support businesses in boosting customer footfall, by giving people more confidence to move around the city and spend more time in a place or space, as well as helping to keep London clean.

5.6.2 Public toilets should be provided as part of large-scale developments that are open to the public, such as shops, sport, leisure and health care facilities, transport hubs, cultural and civic buildings and large areas of public realm. Boroughs should define ‘large-scale’ for their local circumstances. Where no local definition is given, ‘large-scale’ should be taken to mean developments that come under Category 1B, Part 1 of The Town and Country Planning (Mayor of London) Order 2008.

5.6.3 In smaller developments, and subject to local evidence and Development Plan policy, boroughs may secure access to toilet facilities as part of a community toilet scheme, or secure provision of public toilets through CIL or planning obligations.

5.6.4 Taking into account the needs of all Londoners, and to provide suitable levels of choice, a range of toilet facilities should be provided. They should include unisex disabled persons’ toilets, separate accessible baby change/family toilets, and cubicles for people with ambulant mobility impairments which can also be suitable for some older people or people who require additional space. Further guidance on the provision and design of these facilities can be found in British Standard BS8300-2:2018 (Design of an accessible and inclusive built environment, Part 2: Buildings – Code of practice). Where gender-specific toilets are provided, a gender-neutral option should also be provided wherever possible (in addition to unisex disabled persons toilets). Consideration should be given to the capacity of facilities in order to minimise queuing, particularly where female gender-specific toilets are provided. Further guidance for determining the number of toilets needed in a location can be found in British Standard BS6465-4:2010 Sanitary installations Part 4: Code of practice for the provision of public toilets.

5.6.5 Public toilets which are open 24 hours can be of great benefit to people accessing London’s night-time economy. These, whether permanent or temporary, should provide facilities which can be used by disabled people and people of all genders.

5.6.6 Public toilet facilities, whether provided inside buildings or externally, should be safe, well-lit and clean. Surveillance of entrances is an important consideration when planning facilities. Ongoing management and cleaning of facilities should be secured and agreed at the planning stage to ensure long-term provision is achievable.

5.6.7 Standard wheelchair accessible toilets do not meet the needs of all disabled people. People with profound and multiple impairments, learning disabilities, and other impairments such as spinal injuries, muscular dystrophy, multiple sclerosis or acquired brain injury, often need extra facilities to allow them to use a toilet comfortably. Changing Places toilets are different to standard accessible toilets as they are designed for assisted use, are larger, and have additional features. Without Changing Places toilets many people are limited in terms of how long they can be away from home, or where they can go. The provision of Changing Places toilets can open up new areas and experiences for people with profound and multiple impairments, and their companions, removing the barrier that the lack of provision can create.

5.6.8 Further guidance on the design of Changing Places toilets can be found in British Standard BS8300-2:2018. Changing Places toilets are not designed for independent use and should be provided in addition to standard unisex disabled persons’ toilets, baby change and family facilities, not as a substitution.

5.7.1 In assessing the requirements for burial space, a borough’s needs assessment should take account of the fact that different faith groups have different needs for burial provision. In London, the demand for burial space for particular faith groups is not always well matched with the availability of burial space. Some boroughs have little or no burial space available.^[93] For inner London boroughs, this requires them to seek provision in outer London or beyond. This can cause problems of access and cost which has a disproportionate effect on London’s poorest communities. It also risks undermining community cohesion and social integration.

5.7.2 To address these issues, the principle of proximity is supported as a general rule to provide burial space near residents, reducing costs/travel time to visit burial sites. However, there may be cases where meeting the needs of residents in one borough may require burial provision to be located in another borough. This may require a sub-regional collaborative approach to the provision of burial space, which in turn should inform a borough’s assessment of current cemetery demand and site allocations for cemeteries in their Development Plans. The use of cross-borough agreements for collaboration are encouraged.

5.7.3 The re-use of graves can provide some additional capacity. Both Section 74 of the Local Authorities Act 2007 and Section 25 of the Burial Act 1857 allow for the re-use of graves in certain circumstances and boroughs are encouraged to actively examine the potential that re-use offers them. The unique heritage and archaeological qualities of cemeteries should be taken into account when providing additional capacity in existing cemeteries.

5.7.4 Ensuring that community and cultural facilities and services required to meet local needs are planned for and provided is one of the core principles of the planning system. Evidence demonstrates that the shortage of burial space in London is reaching a critical stage in many boroughs.^[94] Boroughs should therefore retain their existing provision, unless it can be demonstrated there is no ongoing or future demand. A borough’s needs assessment should be used to inform this decision. The construction of new buildings in the Green Belt is inappropriate except for a limited number of uses. These include provision of appropriate facilities for cemeteries as long as they preserve the openness of the Green belt and do not conflict with the purposes of including land within it. This also applies to Metropolitan Open Land.

5.7.5 When making new provision, boroughs are encouraged to take into account the Mayor’s broader aims for green infrastructure and the natural environment, including, but not limited to, the creation of new parks and open spaces, the enhancement of existing open spaces and natural environments, and the provision of enhanced links to London’s green infrastructure. New burial provision that supports environmentally friendly burial practices such as woodland or parkland burial grounds can offer broad burial provision as well as wider public access. Amenity provision and environmental enhancements should be encouraged.

5.7.6 Boroughs should continue to make traditional burial provision but innovative approaches to the provision of community burial space, particularly in inner London, may also need to be taken. These could include creating public gardens for the burial of ashes on underused pockets of open land, parkland and brownfield land. Such gardens could also offer broader community utility, improved amenity provision and environmental enhancement.