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Cemetery Asset - Annual Report

Argyll and Bute Council · 18 December 2025
Back to Environment, Development and Infrastructure Committee — 18 December 2025 and its agenda

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ARGYLL AND BUTE COUNCIL                  ENVIRONMENT, DEVELOPMENT AND     
INFRASTRUCTURE COMMITTEE 
ROADS AND INFRASTRUCTURE          18  DECEMBER 2025
SERVICES                     
CEMETERY ASSET – ANNUAL REPORT             
1.0 EXECUTIVE SUMMARY 
1.1  Within the cemetery inventory of 131 locations, 63 cemeteries remain “active”
with lairs spaces available. This report provides the annual update on the
current Argyll and Bute “active” cemetery portfolio - numbers available for sale
of lair certificates and operational timescales within the Cemetery
Development programme, based on data collated to 30th September 2025. 
1.2  It should be noted that the rate of sale of lairs, equivalent to the uptake of
land, differs from the annual rate of interments (coffin burials) as generally,
individual lairs are able to accept 2 or 3 interments. 
1.3  Figures collated after a comprehensive lair survey in 2024 have been updated
this year to indicate that there remains over 12,700 lairs available for sale
throughout our cemetery inventory, sufficient to sustain the burial service
overall, for the next 50 years. However, the number of lairs available varies
from several hundred in larger cemeteries to 10 or less, depending on the
location. These figures are used to prioritise the cemetery development
programme of existing extensions or new cemetery development sites. 
1.4  The timescales from planning an extension to an existing or providing a new
cemetery, through to operational availability varies depending on the
complexity of each project. SEPA ground water management requirements,
which have become far more stringent over the past decades, local
consultations with landowners on the transfer of ownership and the Planning
approval process all contribute to the length of time taken to deliver new
cemetery lairs. Further planning conditions require Soils Management Plans
and Ecology and Archaeology surveys of any potential plot of land. For this
reason, the current priority list highlights development needs in 0-5yrs, 5-
10yrs or 10-20yrs. The 5-year development programme budget requirement
remains at £605k. However, an additional £30k development costs for North
Bute cemetery have been added in anticipation of an early spend, within the
programme period. 
1.5  Activities in the past 12 months have been limited to ground investigation
works. Construction plans for additional lairs space have yet to be approved.
There is a total of £688k in the Capital Environmental Projects Budget which
will cover this cost of £605k-£635k as per Appendix 2 for the next 5 years.

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1.6  Discussions with landowners and community groups continue, on potential
cemetery locations, in association with initial site investigation trial pit
excavations to verify the suitability of land for cemetery development.  
• A formal planning application has been approved for Calgary Cemetery
extension, with conditions. This required additional ground investigation works
which initially uncovered archaeological finds which may restrict the extent of
development. Further investigations are scheduled for November to confirm.
In parallel with this, arrangements are underway with the landowner to
transfer ownership of the selected section of field to the Council. 
• At Cowal Cemetery - Sandbank trial excavations in adjacent Torlochan
extension site, carried out last July were followed up with Ecology and
Archaeology surveys this summer. The site is considered suitable for
development as a cemetery. A formal planning application will be submitted
towards gaining approval to develop within the 5 year programme duration,
phase one of the extension providing an additional 200 lairs or thereby. 
• At Kilkerran Cemetery, Campbeltown, update of the lair spaces available
indicates 113nr remain available for sale, within the property boundary of the
cemetery, with 2nr having been sold in the last year. The Ecological survey of
the adjacent field was carried out this summer, but the Archaeological survey
has been delayed until the farmer has completed the use for grazing in early
November. Negotiations continue with landowners on transferring ownership
of the area. This includes discussions with King’s Harbourmaster (MoD)
Estates section on the area bounding Kilkerran Road. The progress on this
issue has been slow, with no firm written commitment to sell the land to the
Council being received, despite a second letter of support from the MAKI Area
Committee chair. This may compromise the extent of the future development
in part due to the limitations of the existing access track.   
• The existing cemetery at Lismore Church has been improved through the
maximising lair space process, creating up to 60nr new lairs in 2023. The
Council continues to liaise with the local community, on their scheme to
purchase from CoS and develop the church buildings in a sensitive manner,
as it affects the surrounding archaeology, burial ground and active cemetery.   
• Clarifications with the Archaeological consultant confirm that it is not
practicable to develop the footprint of the second Kingarth Parish Church,
Bute, demolished after the 1968 storms, due to sub-structures at shallow
depth. Trial pits in October have confirmed the adjacent field to be suitable.
The Ecology survey did not highlight any restrictions on development and the
Archaeology survey is being scheduled for activity onsite in November.  
1.7  The cemeteries portfolio has been updated to indicate the current status of all
locations which remain “active” with revised comments where appropriate.

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1.8  The full list of “active” cemeteries with restrictions on the pre-sale of lairs was
revised and updated in 2024. This now includes locations where historical
local priorities had already reduced the demand on lair sales, as approved at
the 19th Dec 2024 Environment, Development and Infrastructure Committee. 
RECOMMENDATIONS 
The Environment, Development and Infrastructure Committee are asked to:- 
i. Consider the annual lairs sales figures and remaining availability;
ii. Note the updated comments relevant to the Cemetery Development
programme; and 
iii. Consider and note the progress on site selection and approval for
development of new or extended cemeteries within the priority
programme.

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ARGYLL AND BUTE COUNCIL                  ENVIRONMENT, DEVELOPMENT AND
INFRASTRUCTURE COMMITTEE 
ROADS AND INFRASTRUCTURE                   DECEMBER 2025
SERVICES                     
CEMETERY ASSET – ANNUAL REPORT 
2.0   INTRODUCTION 
2.1 This report provides the annual update on the current Argyll and Bute “active”
cemetery portfolio of 63 sites - number of lairs available for sale and operational
timescales within the Cemetery Development programme. 
2.2 The comments against the individual sites have been updated where progress
has been made on the development of extensions or new sites and where
additional lair space has been developed in any existing facility. However, since
the comprehensive survey last year, there is now limited scope to identify further
internal lair space development. Updates are also given where investigations or
consultations may have changed the likelihood of any planned development
gaining SEPA / Planning Authority approval. 
2.3 The report also gives confirmation of the current list of cemeteries subject to
restrictions on the pre-sale of lairs – further to Dec 2024 EDI report – to preserve
the service at local levels as far as is practicable. This highlights that there
remains, 24 sites throughout the portfolio of “active” cemeteries, which are
subject to a restriction on the sale of lairs, either through the shortage of
remaining lair space or to preserve the burial facility for local communities.
These are coloured blue, in the active cemeteries spreadsheet Appendix 1a 
3.0  RECOMMENDATIONS 
The Environment, Development and Infrastructure Committee are asked to:- 
i. Consider the annual lairs sales figures and remaining availability;
ii. Note the updated comments relevant to the Cemetery Development
programme; and 
iii. Consider and note the progress on site selection and approval for
development of new or extended cemeteries within the priority
programme.

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4.0  DETAIL 
4.1  The inventory of “active” cemeteries details the remaining ground, within each
property, which can be used for interments. This is expressed as an equivalent
number of standard lair spaces which are available for the public to obtain the
exclusive right of burial – through the lair certificate purchase process. 
4.2 Members are reminded that the uptake of land, through the allocation of burial
lairs is independent of the number of interments in each individual cemetery. In
most current cemeteries and in the design of any new facility, the expectation is
that a full depth lair will provide vertical space for three interments. 
4.3 As detailed in the report and attachments, the average annual rate of lair sales
is now calculated as approximately 253 lairs per annum, with 224 sold in the last
12 months. However, it should be noted that the average annual rate of
interments (coffin burials) is approximately 530 interments per annum with little
fluctuation +/- 50 per year. 
4.4 In the last 12 months a total of 480nr coffin burials and a further 175nr ashes
interments were carried out within the 131 cemeteries portfolio (Table 1). 
This shows a consistent number of casket interments compared to 2024 but an
increase of 50nr ~ 40%, in ashes interments compared to last year, which may
be considered indicative of a change in the public preference to cremations.
Data indicates a ten-fold increase in ashes interments over the last decade.
Table 1 - Burial Statistics for Period 01 October 2024 to 30 September 2025                 
New = first interment, 
Re-open= 2nd/3rd interments
New Re Open  New Re-Open  
Total all
cemeteries  
252 228 50 125  
1st Oct 2024 - 30th Sep 2025 Casket
Interments 480 Ashes
Interments 175   
4.5  Update of Statistics in Cemeteries programme 
4.5.1 In accordance with the conclusions of the Environment, Development and
Infrastructure Committee of December 2022, annual updates in lair sales are
now recorded through interrogation of the BACAS database, used for the
management of the burial service. 
4.5.2 Annual figures are recorded from the 1st October the previous year to 30th
September, to allow the most up to date figures to be included in the annual
committee report. The average annual rate of sale is now calculated from
available accurate data collected since September 2019.

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4.5.3 Members are reminded from previous reports, that of the portfolio of 131
cemetery locations, 68 cemeteries are considered as “closed”, where all
available land for burial lairs has been allocated. Re-opening of lairs and ashes
interments are however still possible. The remaining 63 “active” cemeteries, are
those where land is still available, for the purchase of the right of burial, and a
lair space can be allocated to the applicant. 
4.5.4 The portfolio of “Active” cemeteries is detailed in Appendix 1a. This details the
number of lairs sold in the last year, from end of September 2024 - September
2025 in each individual cemetery and based on the review of remaining spaces,
the number of lair spaces available for future sale.  Records indicate that 224
new lair spaces were sold throughout the asset in the past year, which is 30
spaces more than the previous period, with a revised assessment of 12,728
spaces remaining available, partly through the “maximizing lair space” process
in current cemeteries, where ground has been brought into operation, including
re-purposing previous hard or soft landscaped areas. For record purposes the
“closed” cemeteries are listed in Appendix 1b 
4.5.5 However, as intimated in previous reports, there remain local pressures on lair
availability, requiring a programme of cemetery extensions or development of
new sites. The overall “operational time remaining” until all lairs are sold, is
based on the annual average rate of sale, which mitigates any localised
increase or decrease in sales in any particular year. 
4.5.6  The completion of the maximising lairs operation at Lismore Church has
provided up to 60nr additional full depth lairs, which should maintain the burial
service at this location for the next 100 years at the current annual rate of lair
sales, restricted to Island Residents only. The Council, as Burial Authority, is
supporting a community-led project to purchase the place of worship from the
Church of Scotland Estate. The project includes additional service buildings for
the church, which are to be located within “non-productive / in-active”, sections
of the Modern cemetery and adjacent historical burial ground. The Council is
liaising with the project manager in their dealings with Historic Environment
Scotland on a sympathetic, acceptable development of the current building and
extension, for multi-purpose use in future years. 
4.5.7 The process of locating suitable sites for cemetery extensions or new
developments is becoming increasingly difficult, due to environmental and
planning constraints. The introduction of the 5yr, 10yr and 20yr colour coding
system was designed to highlight the Cemetery Development programme
sequence.  There are however some statistical variations year on year which
may change the “hierarchy” of cemeteries in need of expansion. Generally, the
list of priorities remains unchanged from that given in the Environment,
Development and Infrastructure Committee in March 2023 report. The annual
cemetery update report allows members to keep track of any changes and
overall progress. 
4.5.8 Comments on the activities to preserve lair availability, or towards developments
or extensions, are updated against the relevant cemeteries within the record. In
some cases, the colour coding may have changed but it should be noted that

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this purely statistical calculation will be affected, where the restriction on pre-sale
has been introduced. The increase in the operational time remaining, being the
object of the exercise. This does not however, change the previous urgency of a
particular site, in the search for additional suitable land. 
4.5.9 The list of cemeteries with pre-sale restrictions has been updated to include
locations where previous local arrangements preserved lair space in parallel
with those “10-year rule” locations  - as ratified at the Dec 2024 Environment,
Development and Infrastructure Committee.  This indicates 24 sites, or over 1/3
of the “Active” portfolio are subject to a restriction on lair sales for one of several
reasons, under section 3 of the updated Cemetery Management Rules. 
4.6  Cemetery Development Programme – progress in last 12 months                   
4.6.1 Cemeteries within the “5 year development programme” remain the focus for the
securing of suitable land, however there has been limited success with
investigations of selected sites in the past year.  
• As intimated in the Nov 2023 paper, trial excavations at the potential site
at Forest View - Strachur proved that the ground was unsuitable due to
the shallow depth to rock.  Contact resumed in August 2024 with local
landowners, to determine if other potential plots were available on land,
south of Strachur at Balliemeanoch and Glen Sluain. In discussions,
these areas were considered essential as productive agricultural land
and were not available for a cemetery development. There is no scope to
develop on the Loch Fyne side of Strachur due to the topography.
Further contact with the Community Council and local landowners is
required early in 2026 to review options for a small, localized cemetery
development site, on suitable land South of Strachur.
• At Kilkerran, a re-assessment of the remaining space confirms 113nr lairs
remain available, two having been sold under the restrictions, in the last
year. The Ecology Survey and Soils Management Plan were completed
this summer but the Archaeology trial trenches have been re-scheduled
until after the livestock have been removed, at the end of the grazing
period. This operation of scheduled for Late November/early December. 
4.6.2 The parallel issue at Kilkerran, land transfer negotiations have seen limited
progress in the past 12 months..
• The strip of land owned by MoD adjacent to Kilkerran Road would be
required, to develop a safe vehicular access. Whilst there was initial
reluctance to release this land, the MoD strategy for Campbeltown later
allowed this area to be considered for sale to the Council. 
• Contact with landowners through Estates and Legal Services is slowly
progressing towards purchasing the land required to provide a new
cemetery with compliant vehicular entrance and parking facilities.
• However, there is no written commitment from KHM to release the land
to the Council. If this is not available, the development of the main field
may be restricted, due to the geometry of the existing track to Knockbay
Farm. Alternative solutions may involve overlapping rights of servitude
between users of the track and access between the existing and potential
new sections of Kilkerran cemetery.

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• Other sites within MAKI area will be monitored and plans will be
developed in parallel with the main cemetery issue in Campbeltown. 
4.6.3  A review of the development plans for Cowal and Bute cemeteries was carried
out in July 2024 to clarify the priorities within the 5 year programme. 
• Trial excavations on Council owned land at Torlochan – Sandbank,
confirmed as suitable by an initial pre-application report accepted by
SEPA in August 2024 has now been subject to an Ecology Survey and
Archaeological Survey. This now allows formalized designs and an
application to the Planning Authority in 2026, to progress this extension. 
• Trial excavations and subsequent advice from the Archaeological
consultant confirmed that the ground within the original Kingarth
Cemetery – Bute on the footprint of the original church building, was
unsuitable for development of additional lair space.  However, the
Ecology Survey and Soils Management Plans were carried out, on the
plot of land in the adjacent field this summer and trial pits in October
confirmed the suitability of the ground. The Archaeological trenches are
scheduled for early November to finalise the investigation works required
as part of a formal planning application. In parallel with this, discussions
will continue with the landowner, towards agreeing the transfer of
ownership of this potential PH2 Kingarth cemetery extension.  
• Consultation with the local team on Bute, identified the requirement to
extend the internal roadways in North Bute Cemetery. In parallel with this
work, the plot of uncompacted fill material, East of the carpark is to be
treated to provide a cohesive, well compacted soil for the development of
full depth lairs within the footprint of the current ownership. 
4.6.4 The main Lorn cemetery at Pennyfuir has sufficient space for 2,000 lairs 
• Footpaths and headstone foundations, continue to be developed within
current section Y, by the cemetery team, as required. 
• The access road network has been developed, from the proposed new
carpark area, along with the first terrace for lair space in the adjacent land
(purchased 2006) in what will become Section AA once completed.   
4.6.5 On Mull, the extension to Calgary cemetery has had to be reviewed, due to the
discovery of historical artefacts and buried structures during the Archaeological
survey, initial trench excavations. This has compromised the initial plans, as a
full scale Archaeological investigation of the site would prove excessively
expensive and compromise the unit rate for development of new lair space.
• A further visit to explore options for a smaller scale development, away
from any archaeology, is scheduled for mid-November.
• The Ecology survey and Soils Management Plans, required as conditions
within the planning approval, were carried out this summer. 
• The potential maximizing of lair space at Pennygowan Cemetery in front
of the exiting cemetery extension, has still to be progressed. 
4.6.6 The cemetery portfolio in Helensburgh and Lomond remains the area with the
highest number of lairs available for sale, with no critical cemetery locations.
This takes into consideration the measures in place to preserve lair space,
through the restrictions on pre-sale of lairs in three cemeteries.

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4.7  Cemetery Development Programme - Priorities for 2026 
4.7.1 The Cemetery Development programme will continue to be delivered within the
list of priorities, as the identification and confirmation of suitable land allows
locations to then be obtained. The parallel measures, to maximise lair space
and when necessary, restrictions on sale of lairs, will be used to preserve the
burial service at as many “Active” cemeteries as practicable.   
4.7.2 The 5 year programme has been expanded and is updated with a revised
budget requirement of £635k Appendix 2.  Notes on activity in the 12 months
since the programme was presented to EDI Dec 2024 have been added. 
4.7.3 The development programme in MAKI will focus on the following
• Pursue the transfer of ownership, design and planning application of PH1
of Kilkerran–North cemetery extension. For completion 2027-28 est
£250k. This is dependent on a successful land transfer process.
• Excavation of rock depth in sections of Achnabreac Cemetery and
pursue a maximizing lair space / depth solution similar to that
successfully completed this year on Lismore est £50k 
• In parallel, investigate options for expansion or new sites at other
cemeteries within the 10year programme. 
4.7.4 In OLI, the development programme will mainly be island focused.
• Carryout further Archaeological investigations towards confirming a
suitable area for development of a Calgary cemetery extension.
• Complete the transfer of ownership at Calgary, obtain revised planning
permission and develop the cemetery  = 50 lairs/35 yrs   Est £30k
• Maximise lair space at Pennygowan and investigate potential additional
new cemetery sites for Salen and Tobermory. 
• Commence process for an extension at Sorobay (Tiree) cemetery.
• In parallel – continue to develop Pennyfuir cemetery as part of
operational expansion of current section Y and infrastructure in proposed
section AA. 
4.7.5 The largest number of “critical” sites are in B&C, where several work streams
are planned to progress in parallel.
• With the assistance of Elected Members, liaise with the local community
and landowners to review potential sites south of Strachur for a new
cemetery Est £75k. The site compliance requirements for SEPA approval
of groundwater management are included for reference in Appendix 3.
• This process could be expanded to review the critical nature of remaining
spaces at Kilmorich, Lochgoilhead and Strathlachan cemeteries, towards
the development of a potential “North Cowal” single main cemetery site.
• Pursue design and planning application of Torlochan extension to Cowal
(Sandbank) cemetery, towards development 2026 – 27 Est £150k
• Complete the “maximise lair space” potential in Kilmun cemetery to
preserve the burial service at this location for as long as practicable.

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• At Kingarth-Bute, complete Archaeological survey, pursue talks with the
landowner, towards potential PH2 cemetery extension. Provide design
and planning application, towards development in 2027 - Est £50k
• Develop next phase of Cnoc-an-Rear cemetery, within existing boundary.
Internal road extension and soils treatments to maximise lair space. 
4.7.6 The cemetery portfolio in H&L, taking into account, the measures already in
place to preserve available lairs, have sufficient capacity at present.
• Potential extension to the front of Arrochar cemetery, within ownership. 
5.0  CONCLUSION 
5.1 The cemetery portfolio has sufficient overall capacity for the next 50 years
operation but locally, restrictions are in place to preserve remaining lair space. 
5.2 The Cemetery Development programme is currently focused on providing
additional cemetery space, based on the most urgent need, subject to the
measure above. However, the site selection and development programme is
now a much longer process than may have been the case historically. 
5.3 The revised estimated budget of £635k still sits within the Capital Environmental
Projects Budget. The updated figures take into account development work which
now shows a profile for estimated costs required over the next 5 years, again
this can only be an estimate until works commence or issues with purchasing
land which can affect costs. There is no requirement at this time for an extra
budget line as the current budget is sufficient to cover the estimated works. 
6.0 IMPLICATIONS 
6.1 Policy – The Management Rules for Burials revised policy 2023, provides a
process where lair sales can be restricted when cemeteries have less than 10
years remaining capacity. 
6.2 Financial – Cemetery extensions and new developments require Capital
funding, to provide “ready to use” infrastructure to sustain the burial service at
local levels.  Est £635K within next 3-5 years. 
6.3  Legal – The Council, as Burial Authority, must provide at least one cemetery.
At present, there is available space for approximately 12,700 lairs, throughout
the portfolio of 63 “active” cemeteries. 
6.4  HR – None known. 
6.5  Customer Service – Cemetery development programme aims to provide and
maintain the burial service at local level wherever practicable. 
6.6  Risk – Land suitability, availability and development costs, may affect the
viability of retaining a local burial service.

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6.7 Climate Change – None known. 
6.8  Fairer Scotland Duty – None known. 
6.9 Equalities - protected characteristics – None known. 
6.10 Consumer Duty – Provision of the burial service at local level sustains the
business models of both the Council and private providers and reduces
the overall cost to customers. 
6.11    Islands – The programme of cemetery development locations, highlights the
desire for the retention of a local burial service, including at least one
“active” cemetery on main inhabited islands, wherever practicable. 
6.12 The Rights of the Child and Wellbeing – None known.   
Executive Director with responsibility for Roads and Infrastructure Services,
Kirsty Flanagan 
Policy Lead for Roads, Transport and Amenity Services, 
Councillor John Armour 
December 2025                                                   
For further information contact:   
Andy Summers, Head of Roads and Infrastructure Services 
Hugh O’Neill, Network and Standards Manager 
Callum Robertson, Assistant Network and Standards Manager 
APPENDICES 
Appendix 1a – Cemeteries – 63 nr Active - Lair Sales and Development programme 
Appendix 1b - Cemeteries - 68 nr “Closed” to lair sales 
Appendix 2 – Active Cemeteries – Capital Programme 2025-30 progress report 
Appendix 3 – SEPA, Checklist for Groundwater management compliance.