Oxted & Limpsfield Residents

Oxted & Limpsfield Residents P O Box 233 email [email protected] Oxted Post Office Station Road West website www.oxtedlimpsfieldresidents.co.uk Oxted RH8 9EH 17 June 2021 Planning Inspectorate Room Kite Wing Temple Quay House 2 The Square Temple Quay Bristol BS1 6PN RE: APPEAL REF: APP/M3645/W/21/3272384 SITE: Land off Oxted Road (A25), Oxted APPLICATION: TA/2020/690 We write to you as the three District Councillors for the ward where this site is located. This document explains the main areas with which we disagree with the Appellant’s Statement of Case. Councillor Catherine Sayer wishes to speak at the Public Inquiry. 1. It is common ground that the application is inappropriate development in the Green Belt, and so we believe that the key issue is whether the harm to the Green Belt and any other harms are clearly outweighed by Very Special Circumstances, in this case, the need for a new crematorium at Barrow Green Road. 2. The Appellant’s Statement of Case (SoC) paragraph 4.6 confirms that this need is the “nub of the case”, and so we start our representation by explaining why we conclude that the Appellant has not demonstrated a need for a new crematorium at Barrow Green Road. Page 1 of 16 3. We then explain why we conclude that the harms to the Green Belt and any other harms -- which includes harm to the character of the area and to the Surrey Hills Area of Outstanding Natural Beauty (AONB) -- arising from this proposal are more significant than put forward in the Appellant’s SoC and the Document:LVIA. 4. We conclude that there are no Very Special Circumstances that clearly outweigh these harms, and so we believe that the Appeal should be Dismissed. Documents Public Inquiry Documents referenced in this representation: A6: Site Search Appraisal for 2020/690 B3: Planning Officer’s Report dated 20th July 2020 C19: Oxted and Limpsfield Residents Group – 11 May 2020 D1: National Planning Policy Framework D2: Planning Practice Guidance D6: Tandridge District Core Strategy 2008 D7: Tandridge Local Plan: Part - Detailed Policies 2014 F1: Reigate and Banstead Officer’s Report re: objection to Application 2020/690 (Oxted Rd) – 7th July 2020 G14: Need Assessment by Horizon Cremation Ltd – February 2021 G15: Need Assessment Errata – March 2021 G14 and G15 include and supplement the information in A5 and A53 which were the needs documents submitted in the original application 2020/690, and so we focus only on G14 and G15 in this representation. J12: Site Search Appraisal for 2021/258 G2-G8: LVIA and LVIA Appendices Other documents we reference which we have appended to this representation: Appendix A: Catchment Area extract from the Woodhatch Road Need Assessment Executive Summary which is one of the planning application documents for Reigate and Banstead Borough Council Planning Application 21/00192/F. Page 2 of 16 Needs assessment rebuttal 5. We have structured our rebuttal to the Appellant’s Needs Assessment (Document G14) to answer two questions1: a. whether there are a sufficient number of deaths in Tandridge to justify a new crematorium at Barrow Green Road, and if not, b. whether Barrow Green Road is the most appropriate location to meet crematorium need arising in these nearby districts. Is there a sufficient number of deaths in Tandridge to justify a new crematorium at Barrow Green Road? 6. We conclude that the majority of Barrow Green crematorium “slots” will be used by those who are resident in other districts. We show this using the total number of deaths in Tandridge, crematorium capacity, and minimum population viability thresholds. 7. Document G14: Table 2 shows 863 deaths in Tandridge projected for 2021, of which, on average, 81%, or 699, will be cremated using the percentages provided in Document G14: paragraph 3.2. The ONS also projects that the average number of deaths per year in Tandridge between 2019 and 2043 is 9752, which would equal an average of 790 cremations per year. By 2041, the annual number of deaths is equal to 1091, which equals 884 annual cremations. 8. Document G14: Paragraph 4.17 explains that there are two crematorium “capacity” metrics – the core slots available in a year figure of 2,016 and the 80% “peak” adjustment which equals a figure of 1,613. 9. Using these figures and assuming that all Tandridge residents will use Barrow Green Road, the very best case is that Tandridge residents will use between 34% (699/2016) and 43% (699/1613) of the Barrow Green crematorium. 1 We understand that catchment areas are not limited by local authority boundaries. Using these boundaries allows the use of nationally recognised statistics which include population/death projections. This ensures transparency of the figures and any conclusions derived using them. 2 2018 ONS Sub-National Population Projections – Table 5: Components of Change (Births, Deaths and Migration) by Local Authority. Page 3 of 16 Using the projected average number of deaths over 20 years, usage would be between 37% (640/2016) and 39% (640/1613). By 2041, capacity usage would still be between 44% (884/2016) and 55% (884/1613). 10. This is the very best case usage because it assumes a completely unrealistic scenario that all residents of Tandridge will use the Barrow Green Road facility, despite the fact that other facilities are closer, such as the Surrey and Sussex, Oak Tree Farm, Bluebell Farm and potentially Turners Hill and/or Woodhatch Road should they be permitted. 11. Furthermore, our reading of a number of Appeal Decision letters includes references to an industry “rule of thumb” 150,000 minimum population viability threshold3. The current estimated population of Tandridge is 87,500, which is just 58% of that minimum viability threshold. While we recognise that viability is not the same as need, this is another factor showing the extent to which the Barrow Green Road facility will be dependent on deaths in other districts. 12. Document G14: Need Assessment: Paragraph 2.10 explains that only 64,500 out of the total population of Tandridge live in an area that is more than a 30- minute drive of an existing or permitted crematorium. This is lower than the more generous total population figures used in the above analysis, and so the results would be even lower, further weakening the needs case put forward by the Appellant. 13. The above analysis confirms that most of the slots will be used by those outside of Tandridge. This indicates that there is an insufficient number of deaths in Tandridge to justify a new crematorium at Barrow Green Road even making the very best – albeit entirely unrealistic -- assumption that all Tandridge residents would be cremated at Barrow Green Road in the future. 3 For example, Appeal APP/N4720/W/19/3233784: Land at Garforth Golf Range, Long Lane, Garforth, Leeds, Paragraphs 13 “the appellants refer to an industry guideline that the population served by a crematorium should be 150,000. I note that this has also been referred to in other appeal decisions.” Page 4 of 16 14. Even if there was a sufficent number of deaths in Tandridge, Document A6: Site Search Appraisal, explains that a location in the north of the district – which is the most densely populated part of Tandridge4 – would better serve Tandridge residents. Document A6: Site Search Appraisal paragraph 3.6 states: 3.6 When looking at sites within Tandridge we concentrated on areas to the north of the District, because the bulk of the population lives in that area and because it is the area least well served. The further south people live in Tandridge District, the easier it is for them to get to Surrey and Sussex Crematorium at Reigate [ed: sic]. It is also the case that a more northerly site in the District captures a greater numer of people who are currently more than a 30-minute drive time from an existing crematorium. 15. These comments indicate that even the Appellant appears to recognise that the Barrow Green Road site is not the most appropriate. 16. For the reasons above, we conclude that there are an insufficient number of deaths in Tandridge to justify a new crematorium at Barrow Green Road. Is Barrow Green Road the most appropriate location to meet the needs of these other districts? 17. This section explains how we conclude that all parts of the Barrow Green Road catchment area are better served by existing/new/pending proposals located in districts adjoining Tandridge. 18. First, Document G14: Needs Assessment, Table 27 shows (reproduced here for convenience) that 100% of the Tandridge population is already covered by existing facilities. 19. Document G14: Need Assessment, paragraph 559 defines “natural catchment” as catchment “constrained only when a catchment abuts the 4 Document B3: Officer Report, paragraph 112 Page 5 of 16 catchment of another crematoria”. This removes the distortion of overlapping catchments by essentially allocating each person in Tandridge to an existing crematoria. This 100% coverage of the Tandridge population improves when newly permitted and pending facilities are considered as shown later in this analysis. 20. Second, we have reproduced (for convenience) Document G14: Figure 2 which shows existing facilities and permitted Oak Tree Farm (but not the now permitted Bluebell Farm crematorium, or proposed Turner’s Hill or proposed Woodhatch Road), the 30 minute cortege catchment area in red, and standard drive time in blue. Figure 1: Document G14: Figure 2 21. There are three points to understand when looking at the above figure: a. First, Document B3: Officer Report, paragraph 111 explains that Tandridge is a rural district with a small population where settlements are scattered within large areas of the Green Belt, particularly in the central and southern areas.

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