DRAFT BURIAL AND CREMATION BILL 2012
LGA SUBMISSION TO THE ATTORNEY-GENERAL
July 2012
Draft Burial and Cremation Bill 2012
Local Government Association of South Australia – Submission
1. BACKGROUND
On 8 May 2012 the Attorney-General wrote to the Local Government Association of South
Australia (LGA) seeking comment on the draft Burial and Cremation Bill 2012 (the Bill) and
the proposed new regulatory regime for the burial and cremation industry. On 10 May 2012
the Attorney-General released the draft Bill for public comment. The LGA sought feedback
from Councils by Circular 19.17 (10 May 2012) and wrote to the Attorney-General advising
of the LGA’s intention to provide him with a submission following endorsement by the LGA
State Executive Committee on 19 July 2012.
The LGA welcomes the opportunity to comment on the Bill and the regulatory regime and
makes the following points in submission to the Attorney-General.
2. GENERAL POLICY COMMENTS
The LGA has a number of concerns about the broader policy underpinnings of the Bill. In
essence, the Bill places increased responsibility for matters relating to the establishment,
management and compliance of cemeteries and natural burial grounds on Local
Government.
Councils are responsible for approximately 350 cemeteries in South Australia and three
crematoria (in Whyalla, Mount Gambier and Centennial Park). Of the 350 cemeteries on
community land, Councils either operate the cemeteries, lease them or, in some cases,
transfer the running of the cemeteries to a Trust (for example, West Terrace and Smithfield
cemeteries).
Potential Need for Increased Resources
Although Councils currently have responsibility for cemeteries under the Local Government
Act 1934 (the 1934 Act) this Bill places many additional responsibilities on Councils, for
example to establish natural burial grounds as well as cemeteries. The Bill anticipates that
Councils will be able to undertake additional responsibilities for which they may not be
resourced. It is not clear whether a natural burial ground, in which bodies may be buried
without chemical preservatives and contained in a shroud or biodegradable coffin, will be
required to meet additional public health standards.
The LGA notes that under the 30 Year Plan for Greater Adelaide, for example, the State
Government has already identified much of the available land and set it aside for future
housing development, potentially leaving Councils with insufficient land to meet the
obligations proposed under this Bill.
Authorised officers
The LGA notes that an ‘authorised officer’ is defined as a police officer or a person
appointed by the Minister. The LGA seeks clarification as to whether Environmental Health
Officers (EHOs) will be expected to carry out the duties of authorised officers, as outlined in
the Bill.
If the expectation of the State Government is that Environmental Health Officers will
undertake certain duties as expressed in clause 55, the skills and training needs of EHOs
will need to be addressed as this appears to be a new area of responsibility. While in
general terms EHOs have a broad skill set and specified qualifications, questions remain
about the capacity of EHOs to undertake work which includes dealing with the deceased.
Due to the time constraints of consultation, the LGA has not had the opportunity to discuss
fully with its member Councils the likely resourcing implications from administering the
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legislation and associated regulations. However, the LGA submits that this is likely to be
resource-intensive for Local Government.
Retrospectivity and Record-Keeping
The LGA notes that the legislation is intended to apply retrospectively, notwithstanding the
transitional provisions at Schedule 1, Part 3 of the Bill. The LGA seeks clarification on
whether the clauses outlining the obligations on relevant authorities to keep particular
records of interment rights and other relevant records will be retrospective in nature. A
retrospective application of these provisions will pose a significant problem for Councils
particularly in the case of renewals of interment rights, where the original details are often
difficult to obtain.
The LGA is also concerned that Councils responsible for heritage listed cemeteries may
have difficulties in complying with the requirements of Part 3, of the Bill in relation to record
keeping and register requirements if these provisions operate retrospectively.
In addition, the Centennial Park Cemetery Authority has raised concerns in its submission in
relation to the implications of retrospectivity on interment rights issued prior to the
commencement of the legislation. The LGA endorses those concerns.
Creation of offences under the legislation
The Bill creates a number of offences, most of which result from a relevant authority not
furnishing specific information within a specified time frame. The penalties for these
offences are considered to be overly harsh. Given that a number of cemeteries in the State
are small and administered by small regional Councils it does not seem appropriate for them
to be subject to such a regime, especially one that is retrospective in application. A number
of cemeteries, particularly older heritage listed cemeteries may not have accurate or
comprehensive records of the kind required by this Bill and there is no exemption or
qualification granted in these circumstances.
Recognition of Heritage Listed Cemeteries
The Bill raises many questions about the interaction between the powers and obligations of
relevant authorities and their compliance requirements for State Heritage reasons. Councils
have sought clarification on this interaction and specific questions are listed separately under
each provision.
It is worth noting that a significant number of the points raised in the LGA’s submission relate
to problems with the practical application of the Bill’s provisions to heritage listed cemeteries,
or those parts of cemeteries which are heritage listed and the LGA makes a submission on
this point at part 3 of this document.
Regulations under the new Act
The Bill makes provision for a number of matters to be prescribed by Regulation. These
matters are of significance to the Local Government sector and the LGA seeks a provision to
be inserted requiring consultation with Local Government on the content and form of the
Regulations, in accordance with the State/Local Government Relations Agreement.
3. SPECIFIC COMMENTS ON THE BILL
Clause 3 – Interpretation - township
The clause states that township ‘has the same meaning as in the Local Government Act
1934’ (the 1934 Act).
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Submission
Given the intended imminent repeal of the 1934 Act, the LGA submits that the definition of
township should be inserted into the Burial and Cremation Bill itself.
Clause 18 – Relevant authorities to provide Registrar with information for register
This clause stipulates the details that a relevant authority for a cemetery, a natural burial
ground and a prescribed facility must provide to the Registrar of Births Deaths and
Marriages (the Registrar). This information includes the name and business address of the
authority, the owner of the cemetery and the cemetery itself, a plan of the cemetery and the
business name, if any, of the cemetery. There are substantial penalties for failing to provide
the information within the prescribed timeframes, including an expiation fee.
LGA Comment
In general terms the provision of information is supported. However, the LGA is concerned
about the level of detail that may be required for a ‘plan’ of a cemetery (cl19(1)(d); and a
natural burial ground (cl19(2)(d). For example, does this mean an overview site plan, a
detailed site plan, a management plan, or a plan that must show every plot?
Submission
The LGA submits that:
(a) a cemetery plan should be defined in the Bill to mean an overview site plan only;
(b) the Bill should be amended to place an obligation on the Registrar of Cemeteries to
assist relevant authorities of small cemeteries to comply with the requirements of the Bill.
Clause 20 – Duty of Councils to establish cemeteries and natural burial grounds
Councils currently have a duty, under section 585 of the 1934 Act, to establish a cemetery
where there is no adequate provision (whether within or outside its area) for the disposal of
the remains of persons who die within the area. This duty is retained in the Bill.
However, at clause 20(2) the Bill imposes a duty on Councils to establish a natural burial
ground where there is no adequate provision (whether within or outside its area) for the
disposal, by natural burial, of the remains of persons who die within its area.
LGA Comment
Clause 20 (2) imposes significant obligations on Councils. The current provisions in the 1934
Act, inserted at a time when Councils had significantly more unused land at its disposal, are
no longer tenable for most Councils. The LGA does not support placing additional
obligations onto Local Government to bear the costs of providing new ‘natural burial
grounds’. The LGA notes that the submission from the Cemeteries and Crematoria
Association of South Australia Inc (CCASA) argues that the term ‘cemetery’ should include
natural burial grounds. The LGA supports this submission where it is possible to provide
natural burial grounds in existing cemeteries or in new cemeteries created in the future.
In addition, the LGA is unclear as to what constitutes ‘adequate provision’ for the disposal of
remains, both in terms of the physical capacity of a cemetery or natural burial ground, and in
terms of the distance allowable from a particular Council area. Councils have submitted that
if they are to determine ‘adequate provision’ then this places an obligation on Councils to put
in place processes to monitor the availability and capacity of cemeteries within their Council
area.
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In the context of the Plan for Greater Adelaide, significant development will occur in the
suburbs of Adelaide, placing pressure on Councils to cater for demand to ensure ‘adequate
provision’. For Councils that own only heritage cemeteries, there is no provision to establish
new areas for natural burial grounds within existing cemeteries. This will mean a significant
cost imposition on Councils, particularly those close to the centre of Adelaide, if they are
required to purchase land to satisfy the requirements of clause 20(2).
Submission
The LGA submits that, although Councils have managed cemeteries effectively for many
years, the issue of available land has become more pressing. The LGA notes that under the
30 Year Plan for Greater Adelaide, for example, the State Government has already identified
much of the available land and set it aside for future housing development, potentially
leaving Councils with insufficient land to meet the obligations proposed under this Bill.
Clause 23 – Designation of natural burial grounds within cemeteries
This clause provides that a relevant authority for a cemetery may set apart any part of the
cemetery as a natural burial ground.
LGA Comment
The LGA notes that cemeteries that are State Heritage listed do not issue new interment
rights, and only honour existing rights. Therefore, they are not able to accommodate new
‘natural burial grounds’.
Where an authority is not able to set aside a part of a cemetery as a natural burial ground,
questions arise as to practical application. For example, what would happen in the situation
where an interment right belongs to a couple and one chooses to be interred in a coffin and
the other chooses to have a natural burial?
Submission
The LGA requests clarification on the operation of clause 23 in relation to cemeteries that
are State Heritage listed.
Clause 24 – Power to set apart part of cemetery or natural burial ground for particular
religions
This clause provides a Council with the power to set apart any part of the cemetery or
natural burial ground for the interment of human remains in accordance with the customs
and practices of a particular religion.
LGA Comment
The LGA has received representation supporting this provision on the basis that it is a
discretionary power, and acknowledges that it may not be possible for parts of cemeteries or
natural burial grounds to be set apart for the interment of human remains in relation to the
customs or practices of a particular religion. However, the LGA has also received
representation that some cultural practices will require more land or land for longer periods
at a time when land space is already at a premium.
Submission
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The LGA supports this provision.
Clause 25 – Closure of cemeteries
This clause sets out the considerations and procedures for the closure of a cemetery or
natural burial ground. The clause provides where a relevant authority and the holder of an
interment right cannot reach an agreement to discharge an interment right, the relevant
authority may refer the matter to an independent party for mediation. Clause 25(9) provides
that the costs of mediation will be borne by the relevant authority.
LGA Comment
The LGA is of the view that the cost of the mediation should be shared equally between the
parties, as is currently the case under the Local Government Act 1999.
Submission
The LGA submits that clause 25(9) be amended to reflect the cost sharing arrangements for
mediation as is currently required under section 271(7) of the Local Government Act 1999.
Clause 26 – Dedication of closed Council cemeteries as park lands
This clause provides for a closed cemetery, on land held on trust by a Council, to be
dedicated as park lands.
Submission
The LGA seeks clarification as to whether a closed cemetery, which has been turned into
park lands, can later be established as ‘community land’ under the Local Government Act
1999.
Clause 29 – Issue of interment rights
This clause sets out the requirements that a relevant authority must comply with when
issuing an interment right, and details the obligations on the relevant authority when the
interment right has been issued.
LGA Comment
The LGA seeks clarification on whether this clause relates to renewals of existing interment
rights, or whether it only applies to the issuing of new interment rights. If the former,
Councils are concerned about whether they will be required to comply in the case where the
details were not known at the time of the initial issue of the interment right.
Submission
The LGA seeks clarification as to:
 whether clause 29 applies to renewals of interment rights, or only to the issuing of
new interment rights;
 the ability of relevant authorities to provide the information required under clause 29,
in the case of renewals of interment rights, where the information was not detailed at
the time of the initial issue of the right; and
 the ability of the relevant authority to implement periodic payments for interment
rights.
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The LGA also submits that the Registrar should, after consultation with the LGA, prepare
model documentation and guidelines on the issuing of interment rights for use by all relevant
authorities.
Clause 30 – Duration of interment rights
This clause provides for interment rights to be issued for a specified period, or in perpetuity.
Clause 30(2) also provides that an interment right may be issued in advance of the date on
which remains are interred, but the term of the interment right will run from the date on which
the remains are interred or on which remains are first interred, as the case may be.
LGA Comment
The LGA is concerned at the practical implications of clause 30(2). The effect of provision
means that a person could pay for an interment right which would not take effect until they
died, which could be decades later in many cases.
There are burdens and obligations that will fall on a relevant authority in the intervening
period, including the maintenance of the site, possibly over many years, and the accounting
and registration obligations that go along with this.
The provision as it stands creates uncertainty for the relevant authority as it has no way of
establishing or controlling the date from which the right will run, which is likely to materially
affect the relevant authority’s operations.
The LGA endorses recommendation 21 of the Centennial Park Cemetery Authority
submission in this regard and submits that an interment right should commence from the
date that the right is issued, as is currently the case.
Submission
The LGA submits that clause 30 be amended so that interment rights commence from the
date that the interment right is issued, as is currently the case.
Clause 31 – Renewal of interment rights
This clause provides for the renewal of interment rights and, at clause 31(2), sets out the
notice requirements that the relevant authority must undertake in advance of the expiry of
the interment rights. The clause carries a $2,500 penalty for non-compliance.
LGA Comment
The LGA is concerned about the quality of record keeping in relation to interment rights
already in existence. In some cases, the holders or interment rights (or their families) may
not have kept sufficiently good records, while in other cases records kept in the past by
Councils may not accord with modern standards of administration. This clause appears to
place the onus on a Council (as the relevant authority) to identify 12 months in advance
when an interment right is due to expire and provide notice to the rights holder. There are
many cases where this obligation is likely to be difficult or even impossible to fulfil, leaving
Councils open to prosecution and fines.
The LGA also seeks clarification on retrospectivity on clause 31(2) in those cases where a
Council owns a State Heritage Cemetery and where there has been a history of inadequate
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record keeping. This has resulted, in some instances, in out of date information, and a lack
of contact details for the interment right holder. If this clause is retrospective in nature, it will
place significant obligations on relevant authorities that have historic and potentially
incomplete or inconsistent records.
Submission
The LGA submits that:
 clause 31 be amended to acknowledge the reality that many cemeteries, particularly
Heritage Listed cemeteries, will not have adequate records; and
 clause 31(2) be amended so that the requirements of that clause apply only to future
interment rights issued.
Clause 32– Assignment of interment rights
This clause sets out the conditions under which an interment right may be assigned.
LGA Comment
The LGA requests clarification on the difference between the assignment of interment rights
and the transfer of interment rights.
Submission
The LGA seeks clarification on the difference between an assignment of an interment right,
and the transfer of an interment right.
The LGA submits that relevant authorities be given the same power for assignments of
interment rights as for transfers of rights. This is provided for in clause 29(1)(f), which allows
the relevant authority to specify whether the interment right may be cancelled or transferred,
and set out conditions around this.
Clause 33 – Surrender of interment rights
This clause allows for the holder of an interment right to surrender the right to the relevant
authority that issued it and requires the relevant authority to refund any fees paid.
LGA Comment
The LGA opposes a requirement for a relevant authority to refund fees paid for an interment
right upon the holder of that right surrendering it. Relevant authorities incur considerable
costs maintaining particular sites and incur opportunity costs over the period that the
interment right is active.
Submission
The LGA seeks amendment of the clause so that a refund of an interment right is not
required when an interment right is surrendered.
Clause 36 – Register of interment rights
This clause requires a relevant authority for a cemetery or natural burial ground to keep a
register of all interment rights that the relevant authority issues and must record in that
register the location and identifier of each site in respect of which an interment right is
issued. Both subclauses carry a $5,000 penalty for non-compliance.
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LGA Comment
The LGA is concerned about the retrospectivity of clause 36(1), and whether this provision
applies to all interment rights and renewals issued prior to the legislation taking effect. As
expressed previously, the quality of historical record keeping in relation to interment rights
already in existence is a concern and the ability of relevant authorities to comply while not
incurring penalties may be an issue. There are many cases where this obligation is likely to
be difficult or even impossible to fulfil, leaving Councils open to prosecution and fines.
Submission
The LGA submits that the requirement for a relevant authority to keep a register of interment
rights issued by the relevant authority apply to interment rights issued from the date the
legislation comes into operation.
Clause 38 – Ownership of memorial
This clause clarifies that a memorial to a deceased person in a cemetery, natural burial
ground or other place of interment is the personal property of the person who paid for the
memorial to be constructed and erected. The clause also provides for a relevant authority to
deal with and dispose of the memorial in accordance with the Bill, and states that the clause
applies to memorials erected before or after the commencement of the legislation.
LGA Comment
The LGA raises the following issues relating to the personal ownership of a memorial:
 the ability of future generations of the deceased’s family to update the memorial;
 the potential for feuding family members requiring multiple memorials on one burial
plot;
 the fact that many authorities would not hold records of who owns particular
memorials in order to ascertain who can authorise work on that memorial; and
 the implications for a Council in maintaining memorials for State Heritage compliance
requirements where the memorial has been abandoned.
Submission
The LGA seeks clarification on the practical implications of the personal ownership of
memorials, and in particular the ability of Councils to maintain a memorial for State Heritage
compliance requirements where the memorial has been abandoned. Who will be
responsible for costs and how will this be managed?
The LGA believes that public notification, such as through a newspaper advertisement, of a
requirement to repair, remove or reinstate a memorial within the specified period is needed
in cases where there are no contact details available for the owner of the memorial.
Clause 40 – Power to require repair, removal or reinstatement of memorial
This clause outlines the steps that the relevant authority must undertake if a memorial
becomes unsafe, damaged or falls into disrepair.
LGA Comment
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The LGA seeks clarification on the scenario where a relevant authority carries out
monumental maintenance works in order to comply with State Heritage requirements and
whether the permission of the memorial owners is required, in a case where the owner has
not maintained the memorial.
The LGA believes that public notification, such as through a newspaper advertisement, of a
requirement to repair, remove or reinstate a memorial within the specified period is needed
in cases where there are no contact details available for the owner of the memorial. This will
be particularly important given that clause 38 (relating to the ownership of a memorial) is
proposed to operate retrospectively.
Submission
The LGA seeks:
 clarification on the interaction of this provision with State Heritage requirements; and
 an amendment to the Bill to provide for publication in a newspaper as part of the
notification requirements to an owner of a memorial where contact details are not
held by the relevant authority.
Clause 45 – Neglected cemeteries and natural burial grounds
This clause gives Councils (and the Minister, in the case of a cemetery or natural burial
ground in an unincorporated area) the power to require a relevant authority (where the
relevant authority is not the Council) to carry out specified work for the purpose of remedying
a neglected cemetery or natural burial ground.
LGA Comment
The LGA seeks clarification on whether this provision in effect places a duty on Councils to
monitor privately owned burial grounds, issue orders and carry out enforcement procedures.
If so, this may impose powers and responsibilities for which some Councils are not
resourced.
Submission
The LGA seeks clarification on:
 whether the clause imposes a duty on Councils to monitor privately owned
cemeteries and natural burial grounds;
 what the legal implications may be for Councils that do not exercise the powers
under this clause; and
 whether the intention is to create a situation where Councils have an order-making
power in respect of privately owned property.
Clause 48 – Public access to cemeteries, natural burial grounds and prescribed
facilities
This clause requires a relevant authority to allow a person access free of charge at any
reasonable time to a cemetery, natural burial round or prescribed facility for the purposes of
visiting graves, or monuments, or conducting or attending a funeral or religious service, or
for any other legitimate purpose. Failure of the relevant authority to comply with this
subclause carries a maximum penalty of $5,000. Subclause (2) of this clause gives the
relevant authority the power to require a person to leave the cemetery, natural burial ground
or prescribed facility if it is suspected that a person has committed, is committing or is about
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to commit an offence. Failure to comply with a requirement to leave the cemetery carries a
maximum penalty of $2,500.
LGA Comment
The LGA is advised that in order to allow monumental masons vehicular access to
cemeteries, permits are issued, with associated fees, and that this also ensures that public
liability concerns are addressed.
Clarification is sought as to whether this will be a lawful practice under clause 48(1)(b). If
fees cannot be charged for vehicular access, the relevant authority is likely to incur costs
from the need to have a staff member present to lock and unlock gates to allow vehicular
access.
Submission
The LGA submits that a relevant authority (Council) should be able to charge a fee for a
permit to allow vehicular access to a cemetery or natural burial ground for a number of
related activities, such as for a monumental mason.
Clause 51 – Registers, records and plans to be kept by relevant authorities
This clause details the registers that a relevant authority must keep, including those for
interment records, interment rights, memorials erected, reduction processes and cemetery
and natural burial ground plans. A relevant authority must make the registers available for
inspection by the public during ordinary office hours on payment of a fee, and make the
registers available to an authorised officer upon request. Penalties of $5000 are proposed
for a failure of the relevant authority to comply with each of the subclauses to this clause.
LGA Comment
The LGA has received representation that the principal office of the relevant authority is the
appropriate place to enable access to the registers anticipated in clause 51, especially in
cases where a relevant authority (such as a Council) has multiple locations open to the
public, such as libraries and community centres.
Submission
The LGA submits that:
 this clause become operative from the date the legislation commences. As
mentioned previously, historic record keeping is not as comprehensive as current
practices, especially in relation to State Heritage listed cemeteries, and to rectify this
would be a significant imposition on relevant authorities; and
 that the clause be amended to clarify that the registers at clause 51 will be made
available at the principal office of the relevant authority.
Clause 54 – Authorised officers
This clause sets out the process for appointing authorised officers under the legislation and
anticipates that a police officer may be appointed as an authorised officer, and that other
persons may also be appointed by the Minister as authorised officers.
LGA Comment
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Clarification is sought on the intention of who will be appointed as an authorised officer (in
the case of a non-police officer).
If the intention is to appoint Council Environmental Health Officers (EHOs) as authorised
officers, Councils are concerned that the appointment process through the Minister is
onerous and unnecessary and creates delays.
Submission
The LGA seeks clarification on the intention for appointing non-police officers as authorised
officers.
Clause 55 – Powers of authorised officers
This clause sets out the powers of authorised officers under the legislation.
LGA Comment
The classes of powers of authorised officers as outlined in the Bill are not dissimilar in
context to the classes of powers of authorised officers under current legislation in South
Australia, such as s261 of the Local Government Act, s38 of the Public and Environmental
Health Act 1987 or s37 of the Food Act 2001. EHOs are likely to be familiar with the process
involved when administering these classes of powers.
The focus of the powers of authorised officers under this Bill relate to the storage, handling
and transportation of the deceased. This is a vastly different focus from the other powers of
EHOs under other legislation as expressed above.
If the expectation of the State Government is that EHOs will undertake certain duties as
expressed in clause 55, the skills and training needs of EHOs will clearly need to be
addressed as this is a new area of responsibility. While in general terms EHOs have a
broad skill set, serious questions need to be asked about the capacity or willingness of
EHOs to undertake such work which in essence will mean enforcing and administering
powers relating to the storage, handling and transportation of the deceased.
Due to the time constraints of consultation, the LGA has not had the opportunity to discuss
fully with its member Councils the likely resourcing or industrial relations implications from
administering the legislation and associated regulations.
The LGA has submitted earlier in this paper that it is not appropriate to make Councils
responsible for the provision of new cemeteries and natural burial grounds. Further, it
seems inappropriate to extend the responsibility for enforcing and administering powers
relating to the storage, handling and transportation of the deceased without discussion
between the State Government and Local Government about the industrial, practical and
financial implications of such activities.
Submission
The LGA submits that:
 if it is the intention of the State Government that EHOs are appointed as authorised
officers, the LGA and the State Government must discuss the industrial, practical and
financial implications of Council Environmental Health Officers enforcing and
administering powers under the Bill relating to the storage, handling and
transportation of the deceased; and
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
the LGA be consulted on the qualifications and training required for Environmental
Health Officers if it is the intention of the State Government that EHOs are appointed
as authorised officers.
Clause 61 – Regulations
This clause provides for regulations to be made under the legislation, and details some of
the topics that the regulations may cover.
LGA Comment
Given the wide ranging nature of the Bill and the responsibilities and powers of Councils in
their own right and in the case where a Council is a relevant authority for the purposes of the
Bill, the LGA seeks to be consulted fully on the content and form of the regulations
anticipated under the Act.
Submission
The LGA seeks a provision in the Bill that Local Government be fully consulted on the
content and form of the Regulations under the legislation, in accordance with the State/Local
Government Relations Agreement.
4. ADDITIONAL SUBMISSIONS ON THE SUBJECT MATTER OF THE BILL
Burial in conjunction with burial of animal remains
One Council submitted to the LGA that it has received requests for human remains to be
buried with animal remains and therefore clarification is sought as to whether this is
anticipated or appropriate under the legislation.
Submission
The LGA seeks clarification whether the legislation provides for animal remains to be buried
with human remains in cemeteries and natural burial grounds.
Recognition of Heritage Listed Cemeteries
A significant number of the points raised in the LGA’s submission relate to problems with the
practical application of the Bill’s provisions to Heritage Listed cemeteries, or those parts of
cemeteries which are heritage listed.
Submission
The LGA submits that, in recognition of the special status of Heritage Listed cemeteries (and
parts of cemeteries) and the valuable part they play in the State’s heritage, that they be
exempted from the provisions of this Bill and be regulated separately.
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