Horizon Cremation Ltd

Oxted Crematorium, Barrow Green Road, Oxted

The Need for a Crematorium in Tandridge

February 2021

This report has been reviewed and approved for submission by Peter Goatley QC

Table of Contents

1 Introduction ...... 1

2 Executive Summary ...... 2

3 The Demand for Cremation ...... 5

4 Assessing Need - Methodology ...... 8

5 Quantitative Need In & Around Tandridge ...... 19

6 Qualitative Need ...... 40

7 Conclusions ...... 61

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1 Introduction

1.1. This Need Statement has been prepared by Horizon Cremation Limited in support of a full planning application for a Crematorium on Barrow Green Road, just off the A25, Oxted Road, Oxted.

1.2. The application is for a single ceremony hall crematorium set in 4.45 hectares of surrounding landscape. The description of development is:

“Construction of a Crematorium with Ceremony Hall, memorial areas, garden of remembrance and associated parking and infrastructure.” Oxted.

1.3. An application for this same proposal was submitted in March 2020. Unfortunately, the application (ref 2020/690) was refused planning permission on the 2nd October 2020 with three reasons given: inappropriate development in the Green Belt without there being very special circumstances to outweigh the harm; the development would fail to respect or reflect the character of the site and its surroundings and potential harm to the landscaping and views into the Surrey Hills AONB. There were however no technical reasons given for the refusal.

1.4. This report has been updated and revised in the light of further analysis of available information both in Tandridge and nationally.

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2 Executive Summary

2.1 Horizon Cremation builds and operates crematoria in areas of the country where current facilities are over-stretched. The firm has submitted a planning application for a new crematorium off the A25, between Oxted and Godstone.

2.2 Cremation became particularly popular following the Second World War. We now cremate 81 percent of people in England, and the trend is increasing. With the number of deaths set to rise over the next thirty years, the demand for new crematoria will continue to rise.

2.3 In assessing the need for a crematorium in Tandridge, this document looks at both quantitative and qualitative considerations. Quantitative issues have an automatic effect on qualitative factors, so both should be assessed.

2.4 The capacity of a crematorium is calculated by multiplying the number of services per day by the number of working days. This report relies on a methodology established at numerous planning appeals and assumes that the ‘Practical Capacity’ is limited by mourners’ desires to avoid holding services at the beginning and end of the day. It also assesses the Practical Capacity in the peak month to reflect the seasonality of deaths.

2.5 We look at these measures in each of the existing crematoria in and around Tandridge including those at Croydon and Beckenham. In doing so, we also account for the impact of permitted but not yet built facilities, at Oak Tree/Bluebell and Bluebell Cemetery and of the newly opened Wealden Crematorium. The conclusions from that analysis are set out in Table 1 below. Averages 2015-2019 Summary Beckenham Croydon Kent & Randalls Surrey & Sussex Park Sussex Annual cremations 1592 1772 1553 2186 1636 Annual cremation minus directs 1559 1737 1477 2164 1626 Annual burial services 168 0 0 0 0 Total services 1759 1737 1477 2164 1626 Total Slots Available 2520 5040 3024 2520 2520 Technical Capacity 70% 34% 49% 86% 65% Total Core Slots Available 2016 3780 1764 2016 1764 Practical Capacity 87% 46% 84% 107% 92% Average Monthly core slots available 168 315 147 168 147 Average monthly services 147 145 123 180 136 Difference between peak and average 27% 28% 28% 28% 28% month (See appendix one) Calculated peak month services 187 192 157 230 174 Practical Capacity in peak month 111% 61% 107% 137% 118% Table 1 Summary of Cremation Capacity 2015-2019 assuming Wealden and Oak Tree/Bluebell/Bluebell Cemetery

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2.6 Table 1 demonstrates that four of the five crematoria open to Tandridge residents are failing tests of quantitative capacity. The worst performer is Randall’s Park at Leatherhead, which cannot meet practical capacity tests even on an average month, let alone during the busy times of the year. Beckenham, the Kent and Sussex and Surrey and Sussex Crematorium all fail tests of practical capacity in the peak month and do so by some margin. Only Croydon Crematorium has capacity.

2.7 Evidence suggests that Tandridge residents overwhelmingly use Surrey and Sussex Crematorium. Very few of the district’s residents choose to go to Croydon Crematorium even though it has capacity. We believe this is because of the difficulty of the journey through congested roads and a complicated network and because there are cultural preferences for a crematorium that is outside London.

2.8 The capacity at the Croydon Crematorium is having little or no impact on the overtrading of the crematoria to the south, as the difficulties in these facilities have persisted for each of the five years tested with no indication of a migration of funerals from the overtrading facilities in the south to Croydon.

2.9 Alongside these quantitative failings are several qualitative problems.

2.10 A substantial population (125,900 people from a total population of 358,000 in the districts of just Reigate and Banstead, Sevenoaks and Tandridge) live more than a 30-minute drive1 from an existing or permitted crematorium. Within Tandridge Council alone, 64,500 people out of a total population of 87,500 live in an area that is more than a 30-minute drive of a an existing or permitted crematorium. This means that nearly three quarters of Tandridge residents must spend more (and often substantially more) than 30 minutes driving to a crematorium when in a funeral cortege.

2.11 Were the proposed facility at Oxted to proceed, it would bring all but 1,950 Tandridge residents within thirty minutes of a crematorium. In these circumstances, 88% of the population of Tandridge District, 77,379 people - would be within a thirty-minute drive of the Oxted site.

2.12 The proposed crematorium at Woodhatch Road, Reigate would be far less beneficial for Tandridge residents. Were it to proceed, 41,000 Tandridge residents, nearly half the population would remain more than a 30 minute drive from a crematorium.

2.13 Research on the length of time people wait for a funeral, shows that three of the facilities tested, (Kent and Sussex, Randalls Park and Surrey and Sussex Crematorium) are so overcrowded that people are having to wait unacceptable periods to secure a funeral. The average across the year for all three facilities is 25 days, significantly more than the 14 days recommended.

2.14 People are paying more than might be expected in all five of the facilities tested. Three of them, Beckenham, Randalls park and the Surrey and Sussex are operated by one company. They all charge the same price (£1,078) which is the highest price for a cremation registered in the country. Both Beckenham and Kent and Sussex Crematoria charge more than the CMA found was average in areas where populations did not have to travel more than 30-minutes to reach a crematorium.

1 30 minutes assuming the journey of a funeral cortege, at cortege speed avoiding motorways.

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2.15 All five of the facilities are aging, (the newest is 60 years old) and each one has design features that would not be acceptable now – be it inadequate car parking, poor public transport, or prominent religious iconography.

2.16 Two of these crematoria have deep rooted and very significant issues that seem impossible to rectify – Beckenham is not fitted with equipment to abate mercury emissions and Randalls Park has a problem with flooding that has caused it to shut down for extended periods three times in the last eight years.

2.17 The need for a new crematorium in this area is compelling and urgent.

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3 The Demand for Cremation

3.1 In 1885, Mrs Jeanette Pickersgill became the first person in the UK to be cremated in modern times. Hers was the first cremation in the newly-built Woking Crematorium. Take-up was not immediate, though. That year, three people were cremated, out of 596,000 deaths.

3.2 Cremation took time to become popular in the UK and for the first half of the twentieth century fewer than 10 percent of the population was cremated. However, the popularity of cremation rose steadily after World War Two. By 1960, a cremation followed one third of all funerals and the trend continued so that by 1980, nearly 70 percent of people were cremated. In 2019, cremations in England and Wales accounted for 81% of all funerals.

Future Demand for Cremation

3.3 In the UK we are at a tipping point which will see a significant increase in the need for new crematoria in the coming decades caused by 1) an increase in the death rate and 2) the continuing rise in the popularity of cremation.

3.4 Irrespective of the tragic consequences of Covid 19, the ONS predicts that the death rate is about to increase significantly. Because of medical advances, the death rate has been static or in decline since the mid-1970s despite significant population increases. In short, the baby boomer generations lived longer than those that preceded them and as a result, fewer people died each year.

3.5 However, the baby-boomer cohort is beginning to die, which will result in a steady and significant increase in the death rate over coming decades. This trend has already begun. In 2010, 560,000 people died in the UK. By 2014, that number was up to 574,000. By 2018, it was 616,0002 meaning we have seen an increase of over 50,000 deaths per year in the UK in just eight years.

3.6 The National Population Projections published by the Office of National Statistics (ONS) in 2019. projected an increase in the death rate in England of 23 percent between 2021 and 2041.

3.7 ONS projections for Tandridge and surrounding districts show a slightly greater rise over the same period as illustrated in Table 2. The average rise in the death rate in these districts is projected to be 25%.

2 The Cremation Society of Great Britain International Statistics 2010-2018

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Authority Projected Deaths Projected Variation

2021 2041 Number Percent 2,578 3,301 723 28 Croydon 897 1,072 175 20 Mole Valley 1,392 1,766 374 27 Reigate & Banstead Sevenoaks 1,135 1,360 225 20

Tandridge 863 1,091 228 26

Table 2 Projected rise in deaths in and around Tandridge 2021-2041

3.8 Alongside the increase in the death rate, cremation continues to grow in popularity. Much of this seems to be driven by cost. SunLife undertakes an annual report into the components that make up the total cost of dying. Analysis of their reports from 2007-2017 (Table 3) shows that there has been a substantial increase in both burials and cremations over the last decade, but the cost of burials increased at a faster rate than that of cremations. In 2018, a typical cremation cost £832 which was just 38 percent of the cost of a burial (£2,174).

Relative Cost of UK Burials over Cremations Source: SunLife Cost of Dying 2019 2500

2000

1500

1000

500

0 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Burial Cost Cremation Cost

Table 3 Relative Cost of UK Burials over Cremations

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3.9 The high cost of burials seems to be a simple result of a shortage of supply. Burials are very land- hungry and, in much of the UK, the cost of land restricts the provision of new burial grounds.

3.10 What do these two trends mean for the provision of crematoria in the coming years? In 2017, 467,748 cremations were conducted in 289 facilities across the UK: an average of 1,618 cremations per crematorium3. Let us assume that the ONS projections for deaths in the UK over the next 18 years are correct and that, in 2037, there will be 777,000 deaths. If we further assume that the historic compound annual increase in the cremation rate of 0.33%4 continues for the next 20 years, this will result in a cremation rate of 82.3% of all deaths by 2037.

3.11 If no new crematoria are built, this would mean that the average number of cremations being conducted in 2037 would be 2,205 per crematorium. This represents a rise of 36 percent in demand over the next 18 years alone.

3 Cremation Society of Great Britain, Table of Cremations 2017 4 Cremation Society of Great Britain, Table of Cremations 2017

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4 Assessing Need - Methodology

4.1 There are two broad methodological approaches that together ascertain whether there is need for a new crematorium. The first is a quantitative analysis of whether current providers are meeting need now and will be able to in the future. The second is a qualitative assessment of the facilities, which looks at factors such as waiting times, service lengths and the everyday experience of mourners.

4.2 In practise, it is difficult to disentangle the impact of qualitative and quantitative factors upon the experience of crematoria users. A quantitative undersupply of chapel slots has a direct impact on how long people must wait for a service, how far they must drive to get to a crematorium and the length of the funeral service. Consequently, an understanding of both the quantitative and the qualitative need for a proposal is required to reach a valid conclusion.

Quantitative Analysis

4.3 Quantitative analysis of need in a crematorium is achieved by its measuring capacity relative to the number of cremations required to be undertaken in its catchment area. At its simplest, the overall capacity of a crematorium can be calculated by reference to the number of cremations it can perform in a year. However, the calculation of practical capacity of a crematorium involves a wider number of factors.

4.4 First, a crematorium has two component parts, both of which affect its capacity: the cremator and the chapel. The cremation process typically takes between 70 and 90 minutes. Because this is longer than a typical service, cremations in a busy crematorium can continue later into the day than services and can sometimes be carried over to be undertaken the following morning.

4.5 The capacity of a chapel, on the other hand is fixed, as services can only be held at times that are suitable for mourners. In consequence, it is the number of chapels that has a much greater influence on the capacity of a crematorium, rather than the number of cremators.

4.6 Second it is necessary to establish the theoretical capacity of a crematorium. This is the total number of services that can be held over a year, assuming it operates between 9am and 5pm Monday to Friday excluding bank holidays, giving 252 operating days per year.

4.7 The number of services in a day is directly related to the length of time allocated for a service – each cremation service is referred to as a ‘slot’. Some busy crematoria in the UK operate slot times of 30 minutes (sometimes even less).

4.8 The professional bodies of the industry believe that a slot time of forty-five minutes should be the minimum to allow the arrival of the coffin, entrance by mourners, a meaningful service and a procession out. The Charter for the Bereaved produced by the Institute of Cemetery and Cremation Management (ICCM) states: “The burial or cremation ceremony should be considered a highly individual and important occasion. Each funeral should arrive and depart without seeing other funerals, neither should they be delayed by the late arrival of other funerals. To help achieve this standard a minimum service time of 40 to 45 minutes should be an objective”. 5 The National

5 Charter for the Bereaved, ICCM. p47. Standards E and F.

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Association of Funeral Directors in evidence given to the Ministry of Housing, Communities and Local Government’s ‘Crematoria Provision and Facilities Review’6 in 2018 stated “gradually crematoria are reacting to the belief that the 30-40 minute window offered to the bereaved is no longer fit for purpose”. The Federation of Burial and Cremation Authorities in evidence to the same review said, “we would hope to see the funeral service intervals set at around 45 minutes giving the mourners a much more appropriate time during which to say farewell to a loved one.”

4.9 Using a slot time of 40 minutes it is theoretically possible to hold 11 services a day between 9.30am and 5pm. However, in practise this does not happen. The majority of funerals take place in the middle of the day between 10.30am and 4.00pm. This is because operating outside these hours: 1. requires funeral directors and families to travel to and from services in rush hour traffic conditions. Driving at cortege speeds through the rush-hour is not popular and, in practise, it is difficult to keep cortege’s together. 2. Funeral directors require time to prepare for a funeral before a cortege can set off in a dignified and orderly manner. 3. Early slots mean mourners (beyond simply the immediate bereaved family) must travel through rush hour traffic causing stress as they strive to arrive on time. People travelling from outside the immediate area need time to get to a crematorium particularly if they are navigating roads they do not know.

4.10 As a result, planning appeals have for some time recognised the utilisation of these ‘core hours’7 when assessing the capacity of a crematorium. On this basis, the number of slots that can be used for services during a day is eight assuming a 40-minute slot time and if you operate based on a one-hour slot, the capacity reduces to six.

4.11 So, the ‘Practical Capacity’ of a crematorium with one chapel is found by multiplying the number of cremation days (252) by the number of Core Hour slots using the minimally accepted slot time of 40 minutes (8). This results in a figure of 2,016 slots a year.

4.12 These calculations are best illustrated in the table 4 which shows the total and core slots available in single chapel crematorium: Interval between Funerals Service 30 minutes 40 minutes 45 minutes 60 minutes Funeral Start Times 1 9.30 9.30 9.30 9.30 2 10.00 10.10 10.15 10.30 3 10.30 10.50 11.00 11.30 4 11.00 11.30 11.45 12.30 5 11.30 12.10 12.30 13.30 6 12.00 12.50 13.15 14.30 7 12.30 13.30 14.00 15.30

6 Crematoria Provision and Facilities. Government Response to the Review, Ministry of Housing Communities and Local Government. pp13-14 7 See, among others, the following appeal decisions: Halstead APP/G2245/A/13/2210128 of February 2014 (at DL paragraph 23): Cambourne APPDO840/A/09/2098108, August 2009 (at DL paragraphs 23 and 49): Swanwick APP/M1005/A/12/218880 July 2013 (at DL paragraph 31).

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8 13.00 14.10 14.45 16.30 9 13.30 14.50 15.30 10 14.00 15.30 16.15 11 14.30 16.10 12 15.00 13 15.30 14 16.00 15 16.30 Per Day Total Slots 15 11 10 8 Core Slots 11 8 7 6 Per year Total Slots 3,780 2,772 2,520 2,016 Core Slots 2,772 2,016 1,764 1,512 Core Slots 73% 73% 70% 75% Table 4 Total and Practical (Core) Capacity at a Single Chapel Crematorium

4.13 For a crematorium with two chapels the available slots are shown in table 5 below: Interval Between Funerals Service 30 minutes 40 minutes 45 minutes 60 minutes Funeral Start Times Chapel 1 Chapel 2 Chapel 1 Chapel 2 Chapel 1 Chapel 2 Chapel 1 Chapel 2 1 9.00 9.15 9.00 9.20 9.00 9.15 9.00 9.30 2 9.30 9.45 9.40 10.00 9.45 10.00 10.00 10.30 3 10.00 10.15 10.20 10.40 10.30 10.45 11.00 11.30 4 10.30 10.45 11.00 11.20 11.15 11.30 12.00 12.30 5 11.00 11.15 11.40 12.00 12.00 12.15 13.00 13.30 6 11.30 11.45 12.20 12.40 12.45 13.00 14.00 14.30 7 12.00 12.15 13.00 13.20 13.30 13.45 15.00 15.30 8 12.30 12.45 13.40 14.00 14.15 14.30 16.00 9 13.00 13.15 14.20 14.40 15.00 15.15 10 13.30 13.45 15.00 15.20 15.45 16.00 11 14.00 14.15 15.40 16.00 12 14.30 14.45 13 15.00 15.15 14 15.30 15.45 15 16.00 16.15 Per Day Total Slots 15 15 11 11 10 10 8 7 Core Slots 11 10 7 8 7 7 5 6 Per Year Total Slots 3,780 3,780 2,772 2,772 2,520 2,520 2,016 1,764 Core Slots 2,772 2,520 1,764 2,016 1,764 1,764 1,260 1,512 Total Slots 7,560 5,544 5,040 3,780 Core Slots 5,292 3,780 3,528 2,772 Core Slots 70% 68% 70% 73% Table 5 Total and Practical (Core) Capacity at a Twin Chapel Crematorium

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4.14 However, this calculation is only part of the story, for two reasons:

1. In practise, it is impossible to fill every Core Hour slot because of the difficulties of co-ordinating funeral directors, families and celebrants with the crematorium’s available slots. 2. Death rates throughout the year are not even though they do follow well marked seasons. There is normally a large bulge of deaths in the winter months.

4.15 These factors have an impact on capacity that has been established at appeal. In particular, Mrs Justice Patterson, when reviewing a Judicial Review claim against a crematorium that had been granted permission in Gedling, upheld the view of the planning officer, who had applied an annualised figure based on a peak month in which capacity was 20 percent higher than the average for the year. Mrs Justice Patterson said,

“As the claimant recognises, the capacity of a crematorium is fixed. To provide for sufficient capacity in the peak month or months the crematorium required will have the same capacity throughout the year. The use of an uplift figure was appropriate for the reasons set out above. If a figure for a month of lesser demand was used, then there will be insufficient capacity for the peak month of January.”8

4.16 Consequently, the concept of the ‘Quantitative Standard’ of a crematorium has become established. This states that a crematorium is operating above capacity (over its Quantitative Standard) if it is operating a single chapel at more than 80 percent of its Practical Capacity. The use of the 80 percent figure to establish the Quantitative Standard was confirmed in an appeal decision in South Staffordshire which was recovered by the Secretary of State. He endorsed the Inspector’s view that practical capacity must be measured in the peak month of demand. The Inspector wrote,

“The parties agree that the best measure for assessing whether a crematorium is meeting a quantitative standard is its practical capacity in a peak month. In 2015, Bushbury operated at 115% of practical capacity in a peak month. The Council accepts that operating above 80 percent of practical capacity places a crematorium under pressure to offer a cremation service that meets an unacceptable quantitative standard.”9

4.17 Thus, the Quantitative Standard for capacity of a single chapel can therefore be calculated by 1) looking at the core slots available in a year (2,016 – assuming the minimum acceptable slot of 40 minutes) and 2) multiplying it by 80%. This sets the Quantitative Standard at 1,613 cremations a year.

8 Timmins, R (on the application of) v Gedling Borough Council and Anor, [2016] EWHC 220 (Admin) 9 Appeal reference APP/C3430/W/15/3430/W/15/3039163 in relation to an Appeal by Westerleigh Group following refusal of application 14/00906/FUL, land off Broad Lane Essington. Decision issued 6th November 2017.

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4.18 This report has gone a step further and considered for each of the existing crematoria, the difference between the average number of deaths in a month and the number of deaths in the peak month for every local authority within each crematorium’s catchment for the past five years in which data is available (2015-2019). This allows greater accuracy in estimating the number of cremations that took place in the peak month for each of the last five years and so gives a more informed consideration of the facility’s capacity to cope with seasonal variations.10

4.19 The failure of a crematorium to meet its Quantitative Standard results inexorably in a diminution of the quality of the experience for mourners. Crematoria operating above their Quantitative Standard can try to:

1. encourage people to take slots outside the Core Hours, 2. reduce the length of slots, or 3. spread the load in busy times by delaying services causing families to wait until more convenient core slots are available.

These affects were noted by the Inspector at the Essington appeal who, in paragraphs 126-128 of his report said,

“It is important to note that the need is not simply demonstrated by a blackletter calculation which demonstrates that Bushbury is trading at 80% of its practical capacity. Rather the need is also demonstrated by the unsatisfactory (to put it mildly) qualitative situation at Bushbury, which demonstrates that qualitative issues are a manifestation of quantitative deficiencies… Bushbury was developed in the 1950s to cater for a primarily Christian population. It was designed as a single chapel scheme with a second chapel being grafted on in 1970. Given that slot times are 45 minutes, it is likely that there will often be four funeral parties on site at any given time. This results in a conveyor belt experience for mourners.

Further, the over-trading has led to unacceptable delays between the date of death and the date of cremation. Analysis undertaken by Dignity (and unchallenged by any party at the Inquiry) shows that the average waiting times between date of death and date of cremation are materially longer than either Telford or other crematoria in this area. This is a very clear qualitative deficiency which has resulted from the quantitative over-trading.11

4.20 There is one further nuance to this methodology to be accounted for which has recently become relevant – direct cremation. Direct cremations do not involve a ceremony and consequently they are offered at a reduced fee. They have become increasingly popular in the last two or three years. Many crematoria will offer direct cremations, usually doing so in the early morning or late afternoon. Whilst not presently particularly numerous, they should now be taken into account when assessing capacity.

10 The data sets used to make these calculations are taken from the ONS Monthly Figures on Deaths Registered by Area of Usual Residence 2015-2019. Data sets for each of the crematoria considered in this report are at Appendix One

11 APP/C3430/W/15/3039163 Land off Broad Lane, Essington, South Staffordshire. It is worth noting that the eventual decision was quashed and is subject to redetermination

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4.21 The Cremation Society of Great Britain began capturing data on direct cremations only in 2018. That year direct cremations accounted for only 3.1% of UK cremations, but the following year, 2019, it had risen to 5.3%. For the crematoria in the area around Tandridge the 2019 figures on direct cremation are shown in table 6 below. In calculations later in the paper direct cremations are excluded from the total number of cremations to make calculations on current and future capacity more robust. Crematorium Total Cremations Direct Cremations Beckenham 1,520 92 6.0% Croydon 1,661 82 4.9% Kent and Sussex, Tunbridge Wells 2,288 337 14.7% Randalls Park, Leatherhead 2,068 114 5.5% Surrey and Sussex, Redhill 2,930 89 3.0% Table 6 Proportion of Direct Cremations in 2019 in Facilities local to Tandridge

Drive Times

4.22 A central aspect of the assessment of the need for a crematorium is a calculation of the population within a reasonable drive time of a proposed site. Several appeal cases12 have now considered what constitutes a ’reasonable drive time’ and these have resulted in an accepted methodology for assessing the size of a crematorium’s catchment area.

4.23 Underpinning this is the recognition that a funeral cortege should not have to travel more than 30 minutes. This represents the time a cortege will take from the start of the final journey to a crematorium. It is regarded as being a period which should not be lightly exceeded. This is not a journey time comparable to any other because it involves a potentially highly charged conjoined drive for the bereaved, often in the principal limousine of the funeral cortege. Studies show that such journeys, beyond 30 minutes, materially exacerbate the sense of stress felt by the bereaved. This issue has been the subject of consideration at numerous inquiries and accepted by Inspectors and the Secretary of State. It also appears in the Companies and Market Authority Report, which identifies the significance of the 30-minute drive time.

4.24 Also accepted at numerous appeals is the fact that families driving to funerals do not travel at normal traffic speeds. Funeral corteges drive slowly as a mark of respect to the deceased, but also to ensure that family members travelling in a procession behind do not get lost and to ensure that the cortege stays together as they negotiate traffic lights, junctions and roundabouts. Corteges can often stop to allow the cars within the procession come back together.

4.25 But how fast do corteges travel? The applicant in one of these appeals13, Westerleigh Group, went so far as to hire a hearse for several days and recreated several funeral routes to assess how much slower corteges travel than normal traffic. They concluded that cortege journey times are 1.8 to 2 times longer than normal journey times.

12 For instance, see Appeal Reference APP/C3530/W/15/3039163 in relation to the appeal by Westerleigh Group - land at Broad Lane Essington: and Appeal Reference APP/D0840/A/09/2098108 land north of Castle Eden Brewery in County Durham (APP/C1355/A/14/2221052): and the decision in Burgess v OFT and Austin and Sons – Competition Appeal Tribunal [2005] Cat 25 Case No 1044/2/1/1104. 13 Appeal Reference APP/C3530/W/15/3039163 in relation to the appeal by Westerleigh Group - land at Broad Lane Essington

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4.26 Consequently, while not enshrined in planning policy, it is clear that numerous planning appeals have accepted that corteges travel at about two-thirds the speed of normal traffic and that a 30-minute drive time based on these speeds is appropriate in the context of seeking to establish the quantitative need for a new crematorium.

4.27 While the appropriateness of the 30-minute drive time at cortege speed has been very widely accepted, it may be noted that at one appeal, regarding a crematorium at Garforth, the Inspector (who was dealing with a written representation appeal) concluded that a 45-minute drive-time might be appropriate in rural areas. In assessing the materiality of this decision, it is important to note among other things that there are significant material differences between the area around Garforth and that which conventionally arises, and specific significant material differences between the area around Garforth and Tandridge.

4.28 In particular, the population density of Tandridge, while not urban, is more than double that of Selby, the rural area to the east of Leeds considered in the Garforth inquiry, as table 7 shows. Population Area (Ha) Pop/sq/km Selby 89,106 60,222 148 Tandridge 87,496 24,819 353 Table 7 Relative Population Densities between Tandridge and Selby

4.29 It would not be appropriate to assume that a drive time of 45 minutes is an appropriate measurement for people living in and around Tandridge.

4.30 Furthermore, the application of a difference in approach to rural areas is not a feature of any national or local policy. It is inevitable that most new crematoria will also serve a rural (as well as urban) catchment as, by reason of the restrictions arising from the operation of the Cremation Act, they will most likely be rural or semirural areas on the periphery of main built-up areas. That was precisely the position in respect of the two proposed crematoria considered in the Essington inquiry (both of which were in the green belt) where a 30-minute drive time was accepted as appropriate.

Catchment Analysis

4.31 We have also analysed need using a Catchment Analysis. This has been undertaken by Carter Jonas LLP, led by Chartered Geographer Andy Williams FRGS, who has over 20 years of experience in geospatial analysis for decision making.

4.32 The system used by Carter Jonas was ArcGIS from the world’s leading GIS provider ESRI, population and death data were from the Office for National Statistics (ONS). To calculate catchments based on drive time, the road network was Ordnance Survey’s highways data set which incorporates the integrated transport network and urban paths. Impedance values are based on the average time to pass along a road segment by car users of Tom Tom satellite navigation devices. The network and the impedance values operate together in ArcGIS service area solver tool.

Variations in Death Rate

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The office for National Statistics (ONS) produces annual figures for deaths by area of usual residence. These show local variations in death rate resulting from demographic and environmental factors; for example, average age and age distribution, alongside diet and air quality. When predicting future demand for cremations these local variations can make a significant difference, in 2016 the UK death rate was 9.1 deaths per 1,000, but the district death rate varied from 3.5 to 15.3. Carter Jonas methodology accounts for local variations in death rate and population density.

Figure 1 Service Areas

4.33 In drive time analysis, the ‘service area’ is an area around a facility that can be reached within a given time. For analysis of a single facility in isolation, the outer edge of the service area would be an isochrone. Figure 1 shows the 30-minute isochrones around the proposed crematorium for a standard car and for a funeral cortege travelling at 2/3rds of the speed.

4.34 In circumstances where multiple facilities operate and it is important to identify the nearest facility for every resident, then a set of non-overlapping service areas is created. In this case the bounding line of the service area is not necessarily an isochrone. The concept can be further explained: if two people leave facility A and Facility B simultaneously and each drive towards the other’s origin along the shortest route, then they will meet at a place which is equal time from each facility. The midpoint

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Figure 2 Barrow Green Road catchments - Constrained versus unconstrained. Each person in the yellow area lives nearer to Barrow Green Road than any other Crematorium. A person living outside the yellow area may reach other facilities within 30 minutes between A-B may be 15 minutes, but the time between A-C, A-D and A-E may be 17, 19, and 22 minutes respectively; the bounding edge of facility A’s service area is not an isochrone. Exceptionally, if A is far enough away from all the other facilities that you could drive 30 minutes in any direction without coming to another facility, then its bounding edge would be a 30-minute isochrone.

4.35 In the absence of other known gravitational factors, it is assumed that each deceased would be taken to the nearest facility to their home location, and so a set of non-overlapping polygons, or unique catchments, was produced with a maximum drive time of 30 minutes at cortege speed. Figure 2 shows the unique catchment of the existing crematoriums with an overlay to show the effect of adding a crematorium at Barrow Green Road.

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Motorways

4.36 It is not normal practise for Funeral Directors to use motorways when taking a cortege to a funeral, therefore motorways have been excluded from the road network when calculating the constrained catchment for crematoria.

MAUP and Edge Effects

4.37 Having defined service areas for each crematorium we need to calculate the number of deaths within that boundary. A classic problem of geography is called Modifiable Area Unit Problem (MAUP), where statistical bias is created by aggregating point data into districts. To count the number of deaths that occur in a catchment it is desirable to have the deaths recorded as close to individual points as possible; in reality, it is accepted that individual points would give away personal data so aggregation to some level is expected.

4.38 The ONS records the number of deaths in England and Wales by area of usual residence at Lower Super Output Area (LSOA) level. Previously, deaths had been recorded at district level while population is recorded using the more granular geography of the census areas. Part of the census geography; LSOA are designed to contain the same number of households and are roughly equivalent in size to postcode sectors (AB1 2XX) although there are 11,211 postcode sectors and 34,753 LSOA. Being smaller in size it is easier to fit whole LSOA within the bounding line of a service area, whereas districts would be bisected to a greater extent.

4.39 Even with the lowest level of aggregation, it is inevitable that there will be some edge effects, that is where the bounding line of the service area intersects the bounding line of a district. As the whole district represents one data point, this presents the problem of how to deal with apportionment either side of the intersection. Two possible solutions are 1) Create two data points by splitting the data in proportion to the slivers of area that fall either side of the line; 2) Allocate the data point to one side or the other. Provided that the two datasets have been generated independently so as to mitigate MAUP then there may be an assumption that an individual catchment will have losses and gains that balance out. In this instance it was preferable to choose to allocate the data to whichever catchment the centroid of the LSOA was within. The reasons for this choice were computational ease and clarity, plus statistical accuracy in that the global number of deaths would be preserved exactly and expressed in whole numbers.

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Figure 3 Edge Effects – Example showing which LSOA are counted within catchment based on where the centroid falls in relation to the bounding edge of the service area.

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5 Quantitative Need In & Around Tandridge

Scope of the Report

5.1 The officer’s report into Horizon’s previous planning application for a crematorium on this site lodged in March 2020 was critical of the decision not to examine capacity at Beckenham and Croydon Crematoria (paras 121 and 122). The officer also claimed that insufficient weight had been given to the new Wealden Crematorium (para 123); the approved, but not yet built, facility at Oak Tree/Bluebell to the south of Orpington (para 124); a permitted but not yet built facility where the M25 meets the A2 in Darenth (para 124); and a proposed application at Turners Hill in Mid Sussex (para 125).

5.2 For completeness, we also note two further sites that on one reading could be included in consideration of need in this area. These are Kemnal Park Natural Burial Ground and Bluebell Cemetery. These are both unusual facilities in that they offer ‘cremation’ services from chapels on site but use existing traditional crematoria elsewhere to undertake the cremation itself. From one perspective, therefore, they are not crematoria and should not be included. However, much of the consideration of crematorium quantitative capacity is based around whether the number of crematorium chapels can cope with the number of services generated in a catchment rather than the whether the number of cremators can cope with number of cremations and, in any event, we understand that Bluebell Cemetery has recently secured planning permission for a cremator at Appeal.

5.3 We also note a further site, the Woodhatch Road site that is subject of a planning application submitted by Reigate and Banstead District Council to Reigate and Banstead District Council in February 2021. This is not a permitted site so there is no reason to assess its impact on existing crematoria – the applicant will seek to do that. However, in the light of comments by Tandridge officers in the report to a planning application on a site at Old Farleigh Road we have considered it to some degree.

5.4 We have dealt with each of these sites in the following manner:

Beckenham Considered in this report.

Bluebell Accounted for in this report. Bluebell Cemetery, which opened in 2019 is located about a quarter of a mile away from Oak Tree/Bluebell. Both, therefore, serve one almost identical catchment area. The existence of Bluebell Cemetery will not increase the impact of Oak Tree/Bluebell on surrounding facilities. The impact of a facility at Oak Tree/Bluebell and/or Bluebell Cemetery has been carefully considered in this report. They are referred to just as Oak Tree/Bluebell.

Croydon Considered in this report.

Darenth Excluded from this report because of its location. Darenth is situated at the junction of the A2 and the M25 and is in the process of being built. However, it is well over an hour’s drive from Oxted at cortege speeds and between it and Tandridge will be

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the new facility at Oak Tre/Bluebell. The Darenth facility will have no direct impact on Tandridge or any of the existing crematorium considered in this report.

Kemnal Park Excluded because of its location though its impact is accounted for within the figures presented. Kemnal Park is located to the north of Chislehurst and as a result, like Darenth, the catchment of the new Oak Tree/Bluebell facilities are between Tandridge and Kemnal Park. Kemnal Park, therefore, has a negligible impact on crematorium capacity in and around Tandridge. The only facility it conceivably impacts upon is Beckenham and as Kemnal Park has been open since 2013, that impact is accounted for in the figures on Beckenham Crematorium presented in this report.

Oak Tree Farm Considered in this report.

Turners Hill Excluded because the planning application before Mid Sussex Council has been refused planning permission. There is therefore no permitted or existing facility to consider.

Wealden Considered in this report.

Woodhatch Considered in this report to the extent that we have assessed the degree to which it Road would have a positive impact on residents within Tandridge were it to be permitted and compared it to the impact that the application site would have (see paras 6.9- 6.13).

5.5 Should officers conclude that, regardless of these reasons, they wish to see any excluded facilities investigated, or look to rely upon a potential impact from any of them as a reason to refuse our planning application, we would ask that they inform us prior to determination, so further information on these facilities can be presented.

5.6 In table 8, Carter Jonas has estimated the drive time from the centre of Caterham to surrounding crematoria (based on travel at cortege speed and avoiding motorways). This is based upon the routes shown in figure 4: Crematorium Total Minutes Total Miles Croydon 41 8.7 Surrey and Sussex 42 14.9 Oak Tree/Bluebell 46 15.5 Beckenham 54 12.7 Wealden 62 37.8 Leatherhead 63 17.9 Kent and Sussex 69 28.1 Table 8 Drive Times from the Centre of Caterham to Existing and Permitted Crematoria

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Figure 4 Thirty-minute catchments of existing crematoria with boundaries of Tandridge Council shown

5.7 The first point to note is that for the residents of Caterham (and many other settlements in Tandridge) there is no crematorium within a thirty-minute drive of their home. Figure 5 shows the catchments of all the existing crematoria in the area plus Oak Tree/Bluebell assuming a 30-minute drive time. The boundaries of Tandridge Council are superimposed on this map. As can be seen, only Tandridge residents in the south-east of the District are within 30 a minute drive of an existing facility, that being the Surrey and Sussex. A small number of Tandridge residents to the east of the district will be within a 30-minute drive of Oak Tree/Bluebell when built.

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Figure 5 Thirty-minute catchments of existing crematoria plus Oak Tree/Bluebell with boundaries of Tandridge Council shown

Surrey and Sussex Crematorium, Redhill

5.8 Surrey and Sussex Crematorium has two chapels, the larger of which (St Richard’s Chapel) can seat 134 people and the smaller (the Memorial Chapel) can seat 54. It offers direct cremations in the early mornings, but these do not take core slots. It also opens on Saturdays on request. Table 9 illustrates the service times that are available. Monday to Friday Saturday Funeral Start Times Memorial St Richards Memorial St Richards Key 8.15 Unattended direct cremation 8.20 Attended direct cremation 8.25 Reduced fee 8.30 Core slot 8.35 8.40

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9.00 9.00 9.00 9.300 9.30 9.45 9.45 10.15 10.15 10.30 10.30 11.00 11.00 11.15 11.15 11.45 11.45 12.00 12.30 12.45 13.15 13.30 14.00 14.15 14.45 15.00 15.30 15.45 16.15 16.30 Per Day Total Funeral 10 10 4 4 Slots Core Funeral Slots 7 7 Per Year Total Funeral 2,520 2,520 208 208 Slots Core Funeral Slots 1,764 1,764 Total Funeral 5040 416 Slots Core Funeral Slots 3528 Table 9 Service times available at the Surrey and Sussex Crematorium

5.9 As Table 9 demonstrates, the crematorium has 5,040 weekday funeral slots and 3,528 core slots available each year, excluding the eight direct cremation services that are possible each day.

5.10 Table 10 shows the levels of technical and practical capacity over the year and the level of practical capacity in the peak month. This information has been updated over that provided in the planning application of March 2020 by the addition of information for 2019 and by a more robust measurement of practical capacity in the peak month as described in para 4.18. Year Surrey & Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 3107 3017 3065 3027 2930 3029 Annual cremation minus directs 3107 3017 3065 3027 2842 3012 Total Slots Available 5040 5040 5040 5040 5040 5040 Technical Capacity 62% 60% 61% 60% 56% 60% Total Core Slots Available 3528 3528 3528 3528 3528 3528 Practical Capacity 88% 86% 87% 86% 81% 85% Average Monthly core slots available 294 294 294 294 294 294 Average monthly cremations 259 251 255 252 237 251 Difference between peak and average 43% 9% 39% 38% 25% 28% month (See appendix one) Calculated peak month cremations 370 273 354 347 296 321 Practical Capacity in peak month 126% 93% 120% 118% 101% 112% Table 10 Capacity Levels at Surrey & Sussex Crematorium 2015-2019

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5.11 The degree to which the crematorium is able to meet tests of Practical Capacity in the peak month changes from year to year as a result of fluctuations in the death rate. In 2016, the facility met this test and operated within Practical Capacity in the peak month. However, in all other recent years it has failed to operate within Practical Capacity in the peak month. On average, over the last five years Surrey and Sussex Crematorium has operated at an average of 112 percent of capacity during the peak month.

5.12 However, this analysis is based on the assumption that two chapels at the Surrey and Sussex – the St Richard’s and the Memorial Chapel - operate with each handling half of the funerals taking place. Mourners choose different chapels because each has a separate character and because they often want a chapel of a size appropriate to the number of mourners expected to attend. Consequently, it is highly unlikely that the split of services between each chapel is equal. To get an indication of what is happening in practise, we have undertaken research into the actual split of funerals that takes place between these chapels.

5.13 Horizon has analysed 692 memorial notices published over five years between January 2016 and December 2020 for services that took place at the Surrey and Sussex Crematorium and recorded which chapels were being used.

5.14 Between 2016 and 2019, the St Richard’s Chapel was used 54 percent of the time. In 2020, this figure increased to 71 percent. However, we suspect that this was a function of the social distancing restrictions introduced in response to the COVID19 pandemic. Consequently, we have decided not to include the 2020 results when drawing conclusions about practical capacity and rely solely on the data from 2016-2019.

5.15 Table 11 shows the significant impact on the capacity at the Surrey and Sussex Crematorium when one chapel handles 54%, rather than 50% of the funerals. Year Surrey & Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1678 1629 1655 1635 1582 1636 Annual cremation minus directs 1678 1629 1655 1635 1535 1626 Total Slots Available 2520 2520 2520 2520 2520 2520 Technical Capacity 67% 65% 66% 65% 61% 65% Total Core Slots Available 1764 1764 1764 1764 1764 1764 Practical Capacity 95% 92% 94% 93% 87% 92% Average Monthly core slots available 147 147 147 147 147 147 Average monthly cremations 140 136 138 136 128 136 Difference between peak and average 43% 9% 39% 38% 25% 28% month (See appendix one) Calculated peak month cremations 200 148 192 188 160 174 Practical Capacity in peak month 136% 97% 131% 128% 109% 118% Table 11 Capacity Levels at Surrey & Sussex Crematorium 2015-2019 assuming 54% usage of St Richard's Chapel

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5.16 It is clear from Table 11 that a more accurate assessment of the usage of individual chapels has a significant impact upon measurements of capacity. St Richard’s Chapel at Surrey and Sussex Crematorium has been performing at an average of 118% of practical capacity in peak months over the last five years.

5.17 Carter Jonas have modelled the impact that a trading Oak Tree/Bluebell Crematorium would have had on Surrey and Sussex Crematorium and have concluded that the diversion of trade would be six percent. Table 12 shows what that impact would have been on Surrey and Sussex Crematorium had Oak Tree/Bluebell been open and trading at mature levels for the last five years. It is clear that the Surrey and Sussex would still have operated over capacity. Year Surrey & Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1577 1531 1556 1537 1487 1538 Annual cremation minus directs 1577 1531 1556 1537 1443 1528 Total Slots Available 2520 2520 2520 2520 2520 2520 Technical Capacity 63% 61% 62% 61% 57% 61% Total Core Slots Available 1764 1764 1764 1764 1764 1764 Practical Capacity 89% 87% 88% 87% 82% 87% Average Monthly core slots available 147 147 147 147 147 147 Average monthly cremations 131 128 130 128 120 127 Difference between peak and average 43% 9% 39% 38% 25% 28% month (See appendix one) Calculated peak month cremations 193 140 181 177 150 163 Practical Capacity in peak month 131% 95% 123% 120% 102% 111% Table 12 Capacity Levels at Surrey & Sussex Crematorium 2015-2019 assuming 54% usage of St Richard's Chapel and Oak Tree/Bluebell Crematoria

5.18 In the officer’s report to the planning application submitted by Horizon in March 2020, it was suggested that the opening of the new crematorium at Wealden might have an impact on the capacity of Surrey and Sussex Crematorium (para 123 of the officer’s report). We have addressed the question of the impact that Wealden Crematorium may or may not be having on Surrey and Sussex Crematorium. Figure 6 below shows the 30-minute catchments of the existing crematorium to the south of Tandridge, including Wealden.

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Figure 6 30-minute drive time catchments of existing crematoria to the south of Tandridge.

5.19 It is clear from Figure 6 that Wealden is too far to the south east of the Surrey and Sussex Crematorium to have an impact on its capacity. Indeed, there is significant population between the two, unserved by existing crematoria. This is the gap that the planning application at Turner’s Hill sought to service. As a result, we can conclude that Wealden Crematorium does nothing to relieve the pressure currently being felt at the Surrey and Sussex.

5.20 The results of these tests of Practical Capacity show that Surrey and Sussex Crematorium is failing against the established bases for assessments or ‘tests’. Even if we assume that both chapels see equal usage, over the last five years Surrey and Sussex Crematorium has operated at an average of 112 percent of capacity during the peak month. If we take the more informed test looking at actual usage of chapels, the facility is at an average of 118% of Practical Capacity in peak months. The yet to be constructed Oak Tree/Bluebell Crematorium will have an impact on capacity at Surrey and Sussex Crematorium but had Oak Tree/Bluebell been open over the five years studied the Surrey and Sussex would still have traded at 111% of capacity.

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Croydon Crematorium

5.21 Croydon Crematorium also has two chapels, the largest of which, East Chapel, can seat 130 people and the smaller, West Chapel, can seat 80 people. Table 13 illustrates the services that are available.

Monday to Friday Saturday Funeral Start Times East West East West 9.00 9.15 9.30 9.30 Key 9.45 10.15 10.15 Unattended direct cremation 10.30 10.00 11.00 11.00 Attended direct cremation 11.15 10.45 11.45 11.45 Reduced fee 12.00 11.30 Core slot 12.45 12.15 13.30 13.00 14.15 13.45 15.00 14.30 15.45 15.15 16.00 Per Day Total Funeral 10 10 4 4 Slots Core Funeral Slots 7 8 0 0 Per Year Total Funeral 2520 2520 208 208 Slots Core Funeral Slots 1,764 2016 Total Funeral 5040 416 Slots Core Funeral Slots 3780 0 Table 13 Service Times Available at Croydon Crematorium

5.22 As Table 13 demonstrates, Croydon Crematorium has 4,536 weekday funeral slots and 3,528 core slots available each year.

5.23 Table 14 shows the levels of technical and practical capacity over the year and the level of practical capacity in the peak month. Again, this information uses the robust measurement of practical capacity in the peak month as described in para 4.18. Year Croydon Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1905 1758 1772 1762 1661 1772 Annual cremation minus directs 1905 1758 1772 1675 1569 1737 Total Slots Available 5040 5040 5040 5040 5040 5040 Technical Capacity 38% 35% 35% 33% 31% 34% Total Core Slots Available 3780 3780 3780 3780 3780 3780 Practical Capacity 50% 47% 44% 42% 45% 46% Average Monthly core slots available 315 315 315 315 315 315

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Average monthly cremations 159 147 148 140 131 145 Difference between peak and average 43% 17% 38% 35% 30% 28% month (See appendix one) Calculated peak month cremations 227 172 204 189 170 192 Practical Capacity in peak month 72% 55% 65% 60% 54% 61% Table 14 Capacity Levels at Croydon Crematorium 2015-2019

5.24 Again, the degree to which the crematorium is able to meet tests of Practical Capacity in the peak month changes from year to year as a result of fluctuations in the death rate. In each of the last five years though Croydon Crematorium has operated comfortably within its practical capacity even in the peak months.

5.25 Once again, this analysis is based on the assumption that the two chapels operate with each handling half of the funerals taking place. We again looked at the actual split between the chapels and analysed 207 memorial notices published over the four years between January 2016 and December 2020 for services that took place at Croydon Crematorium. Once again there was a significant uplift in usage of the larger East Chapel in 2020 which we assume is a direct result of Covid19, so we excluded that year from our results.

5.26 Between 2016 and 2019, the East Chapel was used 51% of the time. However, it is clear from Table 13 that there is significant excess capacity at Croydon Crematorium and the impact of one chapel operating at 51%, rather than 50%, of the total usage would have an insignificant impact on the current situation.

5.27 Carter Jonas has assessed the impact that the permitted Oak Tree/Bluebell Crematorium would have had on Croydon Crematorium had it been open over the last five years and have concluded that it would have had an impact of just one percent, a number that does not materially change the numbers presented.

5.28 The results for these tests of Practical Capacity show that Croydon Crematorium is easily meeting capacity. The facility has an average of 65% percent of capacity during the peak month.

Randall’s Park Crematorium, Leatherhead

Randall’s Park Crematorium has a single chapel and offers 45-minute service slots. The times on offer at the facility are shown in Table 15.

Funeral Start Key Times 08.15 Unattended direct cremation 08.30 Attended direct cremation 09.00 Reduced fee 9.30 Core slot 10.15

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11.00 11.45 12.30 13.15 14.00 14.45 15.30 16.15

Per Day Total Funeral Slots 10 Core Funeral Slots 8 Per Year Total Funeral Slots 2520 Core Funeral Slots 2016 Table 15 Service Times Available at Randall's Park

5.29 As Table 15 demonstrates, Randall’s Park Crematorium has 2,520 weekday funeral slots and 2,016 core slots available each year.

5.30 Table 16 shows the levels of technical and practical capacity over the year and the level of practical capacity in the peak month. This information has been updated over that provided in the planning application of March 2020 by the addition of information for 2019 and by a more robust measurement of practical capacity in the peak month as described in para 4.18. Year Randall’s Park Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 2253 2182 2282 2147 2068 2186 Annual cremation minus directs 2253 2182 2282 2147 1954 2164 Total Slots Available 2520 2520 2520 2520 2520 2520 Technical Capacity 89% 87 91% 85% 78% 86% Total Core Slots Available 2016 2016 2016 2016 2016 2016 Practical Capacity 112% 108% 113% 106% 97% 107% Average Monthly core slots available 168 168 168 168 168 168 Average monthly cremations 188 182 190 179 163 180 Difference between peak and average 44% 12% 32% 34% 32% 28% month (See appendix one) Calculated peak month cremations 271 204 251 240 215 230 Practical Capacity in peak month 161% 121% 149% 143% 128% 137% Table 16 Capacity Levels at Randall’s Park Crematorium 2015-2019

5.31 In each of the last five years Randall’s Park Crematorium has failed tests of Practical Capacity to a significant degree. On average it has operated at 107% of its Practical Capacity and at 137% of its Practical Capacity in the peak month.

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5.32 Carter Jonas have studied the impact that an operational and mature facility at Oak Tree/Bluebell would have had on capacity at Randalls park and concluded that it would have had no impact – it is just too far away for Oak Tree/Bluebell to register.

Kent and Sussex Crematorium, Tunbridge Wells

Kent And Sussex Crematorium has one chapel and, again, offers 45 minutes service times. However, the crematorium sits within the grounds of an original cemetery and, consequently, visitors to the facility are able to use the cemetery chapel for services if it is not being used for a burial. In this analysis, for the purposes of robustness, we have assumed the free use of the cemetery chapel would be available for the relevant times on offer at the facility, as shown in Table 17.

Funeral Start Times Crematorium Cemetery Key 09.00 Unattended direct cremation 09.30 Attended direct cremation 10.00 10.00 Reduced fee 10.45 10.45 Core slot 11.30 11.30 12.15 12.15 13.00 13.00 13.45 13.45 14.30 14.30 15.15 15.15 16.00 16.00 16.30 Per Day Total Funeral Slots 12 9 Core Funeral Slots 7 7 Per Year Total Funeral Slots 3024 2268 5292 Core Funeral Slots 1764 1764 3528 Table 17 Service Times Available at Randall's Park Crematorium

5.33 As Table 17 demonstrates, Randall’s Park Crematorium has 5,292 weekday funeral slots and 3,528 core slots available each year.

5.34 Table 18 shows the levels of technical and practical capacity over the year and the level of practical capacity in the peak month. This information has been updated over that provided in the planning application of March 2020 by the addition of information for 2019. Year Kent and Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 2338 2346 2414 2572 2288 2392 Annual cremation minus directs 2338 2346 2414 2199 1951 2250 Total Slots Available 5292 5292 5292 5292 5292 5292 Technical Capacity 44% 44% 46% 42% 37% 43%

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Total Core Slots Available 3,528 3,528 3,528 3,528 3,528 3,528 Practical Capacity 66% 66% 68% 62% 55% 64% Average Monthly core slots available 294 294 294 294 294 294 Average monthly cremations 195 196 201 183 163 188 Difference between peak and average 45% 14% 34% 37% 22% 28% month (See appendix one) Calculated peak month cremations 283 223 269 251 199 245 Practical Capacity in peak month 96% 76% 91% 85% 68% 83% Table 18 Capacity Levels at Kent & Sussex Crematorium 2015-2019

5.35 On the assumption that both chapels at the Kent and Sussex Crematorium host an equal number of funerals, then Table 18 would appear to show that the facility is comfortably meeting tests of Practical Capacity. However, in a need document supporting a planning application for a facility in Mid Sussex, consultants Peter Mitchell Associates quotes a Freedom of Information Act response they obtained from Tunbridge Wells Borough Council that indicates that in 2019, 80,7% (1,614) of cremation services were held in the Main Chapel and 19.3% (387) were held in the Cemetery Chapel.

5.36 Table 19 shows the significant impact on the capacity at the Kent and Sussex Crematorium when one chapel handles 80.7%, rather than 50% of the funerals. Year Kent & Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1887 1893 1947 2076 1846 1930 Annual cremation minus directs 1887 1893 1947 1775 1614 1823 Total Slots Available 3024 3024 3024 3024 3024 3024 Technical Capacity 62% 63% 64% 59% 53% 60% Total Core Slots Available 1764 1764 1764 1764 1764 1764 Practical Capacity 107% 107% 110% 101% 91% 103% Average Monthly core slots available 147 147 147 147 147 147 Average monthly cremations 157 158 162 148 135 152 Difference between peak and average 45% 14% 34% 37% 22% 28% month (See appendix one) Calculated peak month cremations 228 180 217 203 165 195 Practical Capacity in peak month 155% 122% 148% 138% 112% 133% Table 19 Capacity Levels at Kent & Sussex Crematorium 2015-2019 assuming 80.7% usage of Main Chapel

5.37 It is clear from Table 19, that an accurate assessment of the usage of individual chapels has a significant impact upon the measurement of capacity and, in reality, Kent and Sussex Crematorium is significantly failing the tests of both Practical Capacity and Practical Capacity in the peak month.

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5.38 In May 2019, Wealden Crematorium opened. Its catchment will eat into the edge of the southern catchment of Kent and Sussex Crematorium and so Carter Jonas has modelled the impact that Wealden Crematorium will have on capacity of the Kent and Sussex going forward. They estimate that, when mature, Wealden Crematorium will attract 15% of the cremations that until June 2019 were going to the Kent and Sussex. The facility had some impact on the Kent and Sussex in 2019 probably to the extent of diverting 5.25% of cremations away (calculated by assuming 7 months of trading at Wealden with it operating at 60% of capacity). Table 20 shows how the Kent and Sussex would have performed over the last five years had Wealden Crematorium been operational and diverting 15% of funerals (with it diverting 9.75% of funerals in 2019 to account for the 5.25% diversion already in the numbers). Year Kent & Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1603 1514 1655 1765 1666 1641 Annual cremation minus directs 1603 1514 1655 1508 1457 1547 Total Slots Available 3024 3024 3024 3024 3024 3024 Technical Capacity 53% 50% 55% 50% 48% 51% Total Core Slots Available 1764 1764 1764 1764 1764 1764 Practical Capacity 91% 86% 94% 85% 88% 88% Average Monthly core slots available 147 147 147 147 147 147 Average monthly cremations 134 126 138 126 121 129 Difference between peak and average 45% 14% 34% 37% 22% 28% month (See appendix one) Calculated peak month cremations 194 144 185 173 148 165 Practical Capacity in peak month 132% 114% 126% 118% 101% 112% Table 20 Capacity Levels at Kent & Sussex Crematorium 2015-2019 assuming 80.7% usage of Main Chapel and addition of Wealden Crematorium

5.39 Table 20 shows that Wealden Crematorium will have a beneficial impact on capacity at Kent and Sussex Crematorium and allow it to operate within its Practical Capacity on average throughout the year. However. the facility will still fail tests of its Practical Capacity in failing to meet the need arising in the peak months.

5.40 Carter Jonas have also modelled the impact of a mature Oak Tree/Bluebell on the Kent and Sussex and concluded that the combination of Wealden and Oak Tree/Bluebell together will have an impact of 19% of cremations at Kent and Sussex per annum. Table 21 models that scenario on the past five years performance at the Kent and Sussex.

Year Kent & Sussex Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1528 1533 1577 1682 1477 1563 Annual cremation minus directs 1528 1533 1577 1438 1307 1477 Total Slots Available 3024 3024 3024 3024 3024 3024

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Technical Capacity 51% 51% 52% 48% 43% 49% Total Core Slots Available 1764 1764 1764 1764 1764 1764 Practical Capacity 87% 87% 89% 82% 74% 84% Average Monthly core slots available 147 147 147 147 147 147 Average monthly cremations 127 128 131 120 109 123 Difference between peak and average 45% 14% 34% 37% 22% 28% month (See appendix one) Calculated peak month cremations 187 146 176 164 133 157 Practical Capacity in peak month 127% 100% 120% 112% 90% 107% Table 21 Capacity Levels at Kent & Sussex Crematorium 2015-2019 assuming 80.7% usage of Main Chapel and addition of Oak Tree/Bluebell Crematorium

5.41 Table 21 shows that had Wealden and Oak Tree/Bluebell been present and operating at capacity during the previous five years, Kent and Sussex Crematorium would still have failed the test of Practical Capacity in the Peak month and operated on average at a figure of 107% of capacity. It is true that the impact of direct cremations in 2019 meant that for that one year the facility operated within capacity. However, there is no evidence to suggest that this trend will continue and even if it does the coming years will see increased pressure on this facility given the rising death rate and the steady increase in the popularity of cremations.

Beckenham Crematorium

5.42 Beckenham Crematorium has one chapel. Table 22 shows the service times that are available there. Funeral Start Key Times 08.15 Unattended direct cremation 08.20 Attended direct cremation 08.30 Reduced fee 09.30 Core slot 10.15 11.00 11.45 12.30 13.15 14.00 14.45 15.30 16.15

Per Day Total Funeral Slots 10 Core Funeral Slots 8 Per Year Total Funeral Slots 2520 Core Funeral Slots 2016 Table 22 Service Times available at Beckenham Crematorium

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5.43 As Table 22 demonstrates, Beckenham Crematorium has 2,520 weekday funeral slots and 2,016 core slots available each year. However, not all of these slots are available for cremation services as the chapel also undertakes funeral services for the burials taking place in the cemetery.

5.44 It has not been possible to obtain data for the number of cemetery-related funeral services that take place at Beckenham. However, it is possible to make an informed estimate. Only 19% of deaths in England resulted in a burial in 2019 – the majority were cremated. Not all the local deaths resulting in a burial would have required a service in the crematorium chapel as families can opt for a service in a church with a committal ceremony at the graveside. According to a former Manager of Beckenham Crematorium, who confirmed the number with local funeral directors, between 45 and 50% percent of the burials that take place at Beckenham use the chapel facilities.

5.45 Consequently, we have estimated the number of burials as follows. We have assumed burials represent 19% of the deaths in catchment and that 45 percent of these required a service in the chapel.

5.46 Table 23 shows the levels of technical and practical capacity over the year and the level of practical capacity in the peak month. Again, this information uses the robust measurement of practical capacity in the peak month as described in para 4.18. Year Beckenham Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1677 1653 1502 1606 1520 1592 Annual cremations minus directs 1677 1653 1502 1519 1428 1559 Annual burial services 177 174 158 170 160 168 Total Services 1854 1827 1660 1776 1680 1759 Total Slots Available 2520 2520 2520 2520 2520 2520 Technical Capacity 74% 73% 66% 70% 67% 70% Total Core Slots Available 2016 2016 2016 2016 2016 2016 Practical Capacity 92% 91% 82% 88% 83% 87% Average Monthly core slots available 168 168 168 168 168 168 Average monthly services 155 152 138 148 140 147 Difference between peak and average 37% 17% 27% 32% 22% 27% month (See appendix one) Calculated peak month services 212 178 175 195 171 187 Practical Capacity in peak month 126% 106% 104% 116% 102% 111% Table 23 Capacity Levels at Beckenham Crematorium 2015-2019

5.47 Table 23 shows that over the last five years, Beckenham Crematorium has failed the test of Practical Capacity in the Peak Month every year and on average has operated at 111% of capacity.

5.48 Carter Jonas have modelled the impact of the Oak Tree/Bluebell on Beckenham Crematorium and concluded that there will be an impact on the Kent and Sussex of 12% of cremations per annum. Table 24 models that scenario on the past five years of performance at Beckenham. Year

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Beckenham Crematorium 2015 2016 2017 2018 2019 Average Annual cremations 1476 1455 1322 1413 1338 1401 Annual cremations minus directs 1476 1455 1322 1337 1257 1372 Annual burial services 177 174 158 170 160 168 Total Services 1653 1629 1480 1507 1417 1540 Total Slots Available 2520 2520 2520 2520 2520 2520 Technical Capacity 66% 65% 59% 60% 56% 61% Total Core Slots Available 2016 2016 2016 2016 2016 2016 Practical Capacity 82% 81% 73% 75% 70% 76% Average Monthly core slots available 168 168 168 168 168 168 Average monthly services 138 136 123 125 118 128 Difference between peak and average 37% 17% 27% 32% 22% 27% month (See appendix one) Calculated peak month services 189 159 156 165 144 163 Practical Capacity in peak month 113% 95% 93% 98% 86% 97% Table 24 Capacity at Beckenham Crematorium assuming Oak Tree/Bluebell had been Open and Trading Maturely

5.49 Oak Tree/Bluebell, when built, will reduce the immediate over-trading at Beckenham Crematorium. However, even with this substantial reduction in demand, the facility would still have traded at 97% of capacity over the five-year period. This gives very little leeway for Beckenham Crematorium to cope with the demand increases likely to result in increased population, increased death rates and increased cremation rates predicted by the ONS to occur in the coming twenty years (see paras 5.65- 5.70).

Summary

5.50 Table 25 presents a summary of these findings and shows the degree to which the existing crematoria around Tandridge met tests of Practical Capacity between 2015 and 2019.

5.51 The findings presented below consider the actual usage of chapels in those facilities which have more than one. So, the figures for Surrey and Sussex Crematorium reflect the findings that St Richards Chapel carries out 54% of services and the findings for Kent and Sussex Crematorium reflect the fact that 80.7% of funerals take place in the main chapel. The figures for Croydon reflect the fact that East Chapel carries out 50% of services (rather than 51% supported by the research). Averages 2015-2019 Summary Beckenham Croydon Kent & Randalls Surrey & Sussex Park Sussex Annual cremations 1592 1772 1930 2186 1636 Annual cremation minus directs 1559 1737 1823 2164 1626 Annual burial services 168 0 0 0 0 Total services 1759 1737 1823 2164 1626

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Total Slots Available 2520 5040 3024 2520 2520 Technical Capacity 70% 34% 60% 86% 65% Total Core Slots Available 2016 3780 1764 2016 1764 Practical Capacity 87% 46% 103% 107% 92% Average Monthly core slots available 168 315 147 168 147 Average monthly services 147 145 152 180 136 Difference between peak and average 27% 28% 28% 28% 28% month (See appendix one) Calculated peak month services 187 192 195 230 174 Practical Capacity in peak month 111% 61% 133% 137% 118% Table 25 Summary of Crematorium Capacity 2015-2019

5.52 Table 25 illustrates that four of the five crematoria open to Tandridge residents are operating materially in excess of their capacity. The worst performer is Randall’s Park at Leatherhead, which cannot meet practical capacity tests even on an average month let alone during the busy times of the year.

5.53 The next worst performing facility is the Kent and Sussex Crematorium at Tunbridge Wells. It too fails tests of practical capacity in average months and during peak months. However, here some relief is on the way in the shape of the permitted site at Oak Tree/Bluebell which will reduce capacity by 19%.

5.54 The Surrey and Sussex Crematorium is also failing the test of Practical Capacity in the peak months. There is currently no relief offered for this facility. The new crematorium at Wealden is too far away to assist and the proposed crematorium at Turners Hill was refused planning permission.

5.55 To the north, Beckenham Crematorium is also over capacity. However, one would have expected Croydon Crematorium which is just three miles away to have brought relief to this facility. The fact that it has not done so in any of the previous five years probably has a lot to do with local perceptions of the difficulties of driving on the road network around Croydon.

5.56 Only one facility, Croydon Crematorium has plenty of capacity at present. Here the two chapels and a relatively low throughput of people mean that the facility is able to cope now and should be able to in the foreseeable future.

5.57 Table 26 considers the impact that a crematorium at Oak Tree/Bluebell and Wealden would have had were they trading at mature levels during the last five years. Averages 2015-2019 Summary Beckenham Croydon Kent & Randalls Surrey & Sussex Park Sussex Annual cremations 1401 1772 1553 2186 1538 Annual cremation minus directs 1372 1737 1477 2164 1528 Annual burial services 168 0 0 0 0 Total services 1540 1737 1477 2164 1528 Total Slots Available 2520 5040 3024 2520 2520 Technical Capacity 61% 34% 49% 86% 61%

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Total Core Slots Available 2016 3780 1764 2016 1764 Practical Capacity 76% 46% 84% 107% 87% Average Monthly core slots available 168 315 147 168 147 Average monthly services 128 145 123 180 127 Difference between peak and average 27% 28% 28% 28% 28% month (See appendix one) Calculated peak month services 163 192 157 230 153 Practical Capacity in peak month 97% 61% 107% 137% 111% Table 26 Summary of Crematorium Capacity 2015-2019 with Addition of Oak Tree/Bluebell and Wealden

5.58 Table 26 shows that Oak Tree/Bluebell will have some impact on Beckenham, Kent and Sussex, and Surrey and Sussex Crematoria. However, only in the case of Beckenham will it meant the facility is able to operate within its Practical Capacity in the peak months. The Kent and Sussex and the Surrey and Sussex will still be significantly over-trading. It is also doubtful whether the capacity created at Beckenham will still be there in six or so years’ time (the length of time it is likely to take for the Oak Tree/Bluebell site to trade at capacity) because of projected increases in population levels, the death rate and cremation rates.

5.59 It is worth considering which of these facilities are currently used by Tandridge residents. Carter Jonas has calculated the ‘natural’ catchments of all the existing crematoria in the area (by natural we mean constrained only when a catchment abuts the catchment of another crematoria). We have used then calculated the number and proportion of Tandridge residents who live nearest to each of the existing facilities. These calculations are shown in Table 27. Population Number Percent Tandridge Population in Surrey and Sussex Natural Catchment 41,156 47 Tandridge Population in Croydon Natural Catchment 27,505 31 Tandridge Population in Leatherhead Catchment 14,634 17 Tandridge Population in Beckenham Catchment 4,201 5 Total Tandridge Population 87496 100 Table 27 Proportion of Tandridge residents living in Catchments of Existing Crematoria

5.60 Alongside this work, Horizon has conducted research into the notices of 77 deaths occurring within the Tandridge District Council area published by funeral directors between 1st January 2018 until 31st December 2020. The results are shown at Table 28. Crematorium Percentage Surrey and Sussex, Crawley 91 Kent and Sussex, Tunbridge Wells 4 Croydon 3 Randall’s Park, Leatherhead 1 Beckenham 1 Table 28 Percentage of Oxted Residents using Local Crematoria.

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5.61 Table 28 shows that the overwhelming majority of Tandridge residents (91%) are using the Surrey and Sussex Crematorium and very few (3%) choose to make the journey to Croydon Crematorium even though it has far greater capacity. This is the case even though 34% of the services recorded in the survey were organised by funeral directors in Caterham, for whom Croydon is the closest facility (a slightly greater number of services than would be expected given the proportion - 31% - of Tandridge residents living in the catchment for Croydon Crematorium).

5.62 We accept that this evidence may not be definitive: the sample is relatively small. However, the disparity between the Surrey and Sussex Crematorium and the others is so great that even if a margin of error of 10% or even 20% were assumed, the preference in the sample would still be marked.

5.63 Why then are residents ignoring Croydon Crematorium when it is the nearest facility for 31% of them and has capacity? Why are they choosing the Surrey and Sussex instead? The Surrey and Sussex does not have capacity and so people are, presumably therefore, putting up with long delays for a service and a ‘conveyor like’ experience rather than go to Croydon. We believe that there are two main factors at play:

5.63.1 The journey. As previously established (see paragraph 5.6), Croydon is narrowly the quicker journey for funeral directors in the north of Tandridge district (for funeral directors operating south of Caterham, the Surrey and Sussex can be accessed more quickly). Moreover, the nature of the journeys to Croydon (and Beckenham) is very difficult. The journey to Croydon Crematorium involves driving up the Purley Way, a notoriously busy road, and crossing right through Croydon town centre. It is difficult to accurately predict timings given that any hold up can slow traffic down markedly and the journey involves numerous junctions, traffic lights and roundabouts. Keeping a funeral cortege together through such obstacles and being sure of a timely arrival (vital for a funeral) is very difficult.

5.63.2 Culture. We have no definitive evidence, but it seems that many of the residents of the area south of London in districts such a Tandridge do not feel themselves to be Londoners and so a funeral ceremony in the busy metropolis does not feel appropriate. The choice of a funeral location can be very localised. This might explain why Beckenham Crematorium is so busy while Croydon Crematorium has plenty of capacity when they are only three miles apart – Beckenham residents want their final journey to be to Beckenham Crematorium.

5.64 The fact that there is capacity at Croydon Crematorium (and has been every year for all five of the years considered in this report) is not having the effect of relieving the over-capacity at any of the other four crematoria studied, including Beckenham, which is only three miles away. Capacity at Croydon Crematorium is not the answer to the problems of overcrowding at Surrey and Sussex, Leatherhead and Tunbridge Wells.

Looking Ahead

5.65 As we have demonstrated, there is need for a new crematorium in Tandridge now. However, this situation is going to get still worse. This is the case for three reasons: 1) population growth, 2) an increase in the death rate and 3) an increase in the cremation rate.

5.66 According to the National Population Projections published by the Office of National Statistics (ONS)

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in 2016, the population of Tandridge will grow 13 percent by 2036 from 86,500 in 2016 to 97,600 in 2036. Tandridge already has a higher proportion of people over 65 than the national average and this number is set to grow by 50% Tandridge District has 18.5% of its population aged over 65 compared to 17.2% in Surrey and 16.4% in England as a whole. Between 2016 and 2036 the ONS estimates that the number of 65-74 year-olds will grow from 9.500 to 12,300 and the number of 75-84 year-olds from 5,500 to 8,600.

5.67 According to the ONS, the annual number of deaths will rise by a quarter in the coming years. The ONS’s National Population Projections project an increase in the death rate of 23 percent over the coming 20 years. If the ONS is correct, nearly 800,000 people a year will die annually in the UK in 17 years’ time. Seventeen years later, by 2051, it will be 900,000 per year.

5.68 Since the war, the cremation rate has risen dramatically. In 1945, eight percent of those dying in the UK were cremated. Just twenty years later in 1965, it was 46%. By 1970, it was 57%, and 67% by 1980. In 2019, 81% of those who died chose cremation.

5.69 What do these trends mean for the provision of crematoria in the coming years? In 2017, 467,748 cremations (representing 77.05% of all deaths) were conducted in 289 facilities across the UK: an average of 1,618 cremations per crematorium14 . Let us assume that the ONS projections for deaths in the UK over the next 20 years are correct and that, in 2037, there will be 777,000 deaths. If we further assume that the historic compound annual increase in the cremation rate of 0.33%15 continues for the next 20 years, this will result in a cremation rate of 82.3% of all deaths by 2037.

5.70 If no new crematoria are built, this would mean that the average number of cremations being conducted in 2037 would be 2,205 per crematorium. This represents a rise of 36 percent in demand over the next 20 years alone.

14 Cremation Society of Great Britain, Table of Cremations 2017 15 Cremation Society of Great Britain, Table of Cremations 2017

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6 Qualitative Need

6.1 If a crematorium is failing to satisfy the Quantitative Need in its area, it is highly likely that problems of a qualitative nature will also arise. For instance, a lack of available service slots can lead to long waits for a funeral, or a crematorium that is under pressure might shorten funeral times to provide more services, thereby reducing the quality of the experience for the bereaved. In this section, we will look at various tests of Qualitative Need that have developed in the last decade of planning appeal decisions and measure the extent to which these tests are being met in each of the existing local crematoria. We will look at 1) journey times, 2) the length of time people must wait to secure a service and 3) pricing, before giving an overview of the quality of facilities at each of the existing crematoria.

Journey Times

6.2 As paras 4.3 to 4.11 above have explained, numerous planning appeals have accepted that corteges travel at about two-thirds the speed of normal traffic and that a thirty-minute drive time is an appropriate basis for establishing the quantitative need for a new crematorium.

6.3 In the area to the south of London, there are sizeable areas of land containing many people who are outside a 30 minutes-drive at cortege speed of an existing crematorium. We call these areas ‘white land’ The people who live within them are being qualitatively disadvantaged by the current under- provision of crematoria as they must travel for more, and often significantly more, than 30 minutes to get to a service. This white land – the land between the catchments - is illustrated in figure 7.

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Figure 7 'White Land’ in an around Tandridge assuming a 30-minute drive time to existing and permitted crematoria.

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6.4 Assuming the crematorium at Oak Tree/Bluebell does proceed, the number of people living in the white land encompassed by just the three districts of Reigate and Banstead, Sevenoaks and Tandridge is 125,900. This is 35 percent of the 358,000 people which constitutes the total population of the three authorities.

6.5 Within Tandridge Council alone, 64,470 people (out of a total population of 87,500) live in white land. This means that nearly three quarters of Tandridge residents must spend more than 30 minutes driving to a crematorium when in a funeral cortege.

6.6 Improving the situation for the people living within such white land by opening new crematoria has been established as a desirable outcome in planning appeals. In particular, at the Essington appeal the Secretary of State, after recovering the appeal, reversed the decision of his Inspector and favoured the scheme at Essington over a rival facility, solely on the basis that it would bring a larger number of people within 30 minutes of a crematorium for the first time. He said,

“Para 13: The appeal scheme would potentially provide a facility for 51,695 people within a 30-minute drive compared with 22,726 people for the Wergs scheme. This would relieve significantly the pressure on the Bushbury Crematorium, currently operating above practical capacity at certain times of the year. The Secretary of State therefore attributes significant weight to this factor in determining the appeals and considers that this weighs heavily in favour of the appeal scheme.”16

6.7 The proposed facility at Oxted would significantly improve the current situation. Were it to be built, 77,380 – 88% of Tandridge residents – would be within 30 minutes-drive of the Oxted crematorium and only 1,950 people in Tandridge would still live outside 30 minutes-drive of a facility. This is illustrated in figure 8.

16 Appeal Reference APP/C3430/W/3039163

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Figure 8 White land in Tandridge assuming new crematorium at Oxted

Why the Oxted Site is the best option for Tandridge

6.8 It is worth considering the potential impact on Tandridge residents of one more crematorium site – the proposal from Reigate and Banstead Council for a facility at Woodhatch Road in Reigate. This application has only recently been submitted (January 2021) and no planning permission has been granted. There are substantial planning issues associated with the scheme (the site is in the Green Belt, adjacent to ancient woodland, close to a school, involves the diversion of several public footpaths, requires the relocation of allotments and is subject to flooding).

6.9 As there is no planning permission at Woodhatch Road, we have not measured its impact on existing facilities in the way we have with all those sites that do have a planning permission. That is a job for the applicants to undertake.

6.10 However, we have noted the following comment in the report of Tandridge planning officers into the planning application for a crematorium at Old Farleigh Road.

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“Overall, the Needs Assessment does not demonstrate how it [Old Farleigh Road] fulfils the district’s [Tandridge District] need and nor (sic) demonstrates why the crematorium has to be in Tandridge District, and furthermore this specific location.”

6.11 This report demonstrates that there is a pressing need for a new crematorium in the area due to the inability of existing facilities to meet the stresses placed upon them. This need adversely affects residents of Tandridge. However, there are reasons why a crematorium at Oxted Road would be of greater benefit to the residents of Tandridge than would one at Woodhatch Road in Reigate and Banstead. The reasons are as follows:

6.11.1 Were the crematorium at Oxted Road to proceed, 77,380 Tandridge residents would be within its 30-minute catchment. Were the facility at Woodhatch Road, Reigate to proceed, only 20,678 Tandridge residents would be within its 30-minute catchment. Consequently, 56,700 Tandridge residents - almost exactly two thirds of the Tandridge population - would be better off with Oxted Road than they would with the proposed facility at Reigate.

6.11.2 Were the crematorium at Oxted Road to proceed, it would bring almost all the 64,500 Tandridge residents who currently live in the ‘white land’ within 30 minutes-drive of a crematorium for the first time leaving only 1,950 of Tandridge residents still within the white land. As figure 10 shows, were the crematorium at Woodhatch Road to proceed, it would be far less beneficial. 41,046 residents would still be in ‘white land’ - further than 30-minutes drive from a crematorium.

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Figure 10 White land in Tandridge assuming new crematorium at Woodhatch Road, Reigate

6.12 From the narrow position of choosing the proposal which will benefit Tandridge residents to the greatest extent, the Oxted application is clearly the winner.

Waiting Times

6.13 A 2017 Report by the Institute of Policy Research, ‘Death, Dying and Devolution’ looked at the question of the length of time families should wait for a funeral service. It said, “There is a growing concern regarding the length of time between death and the funeral, burial or cremation. Bereaved people are telling us that in parts of England and Wales the waiting time can now be three weeks.”

It continued,

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“There are considerable implications for delays between death and disposal, not least the pressure on hospital and local authority mortuaries where bodies are held, the costs to funeral directors when those bodies are moved into their cold storage facilities and the impact on businesses from employees needing additional time off work.” And further states,

“We know that the funeral service and saying goodbye to the person who has died plays a vital role in helping grieving families…. Delays to holding the funeral can exacerbate the feelings of distress and disorientation (the feeling of being in limbo). It can also cause significant practical difficulties such as for families travelling from overseas to attend the funeral… Uncertainty makes an already difficult situation so much worse. Where cultural or religious practices around timescales cannot be fully observed, it can significantly add to the distress.”17

17 Institute for Policy Research, Death, Dying and Devolution” September 2017 pp 60-61

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6.14 Crematorium operator, Westerleigh, commissioned an opinion poll in October 2017 from independent research company, ‘Research Interactive’ of 330 respondents in Leeds in support of a planning application. They asked, “How long would you want the period to be between the death of a family member and their cremation? 41 percent of respondents said, ‘up to a week’ and a further 52.4% responded ‘one to two weeks’”.18

6.15 This need for cremations to be undertaken within this timeframe has been upheld at appeal. In an appeal for a crematorium in Cambourne, the Inspector stated,

Of greater concern is the evidence submitted indicating the delay between death and funeral. It is apparent that over 80% of funerals take place at least seven days after death. These figures support the perceptions encompassed in submissions from funeral directors and clergy which point to significant difficulty in mourners achieving their preferred time and day for funerals and consequential delays and compromise. Such pressures are clearly greater in winter with increased delays during January and February in particular with a significant proportion extending to over two weeks from date of death. While these delays can be partly explained by coroner delays or similar, this presents substantial evidence of pressures on the capacity at Penmount [Crematorium] to meet the qualitative needs of such a large population.”19

6.16 An Inspector in a 2014 appeal heard evidence that during busy periods (defined in this appeal as September through the winter to April) waiting periods extended to two weeks or more, even though during the rest of the year delays were less severe. This, he accepted, as showing need.20

6.17 This was also one of two reasons that the Inspector allowed the appeal by Mercia Developments on the Oak Tree/Bluebell proposal in December 2014. In a paragraph listing what he described as the ‘salient points’, the Inspector stated,

“Support for the proposal from the clergy and funeral directors is also telling. This refers, amongst other things, to an average wait of 19 days in 2013 between death and cremation and to long journeys which add to the stress of the bereaved at a difficult time.”21

6.18 Horizon analysed the death notices printed in the Surrey and Sussex and London newspapers covering cremations held in 2019. We have attempted the same exercise for Beckenham and Croydon crematoria, but unfortunately there are insufficient notices published online to secure a representative sample for these crematoria. We decided not to use the more readily available data for 2020 because of concerns that Covid19 would affect the results.

6.19 Published notices for the Kent and Sussex, Randall’s Park and Surrey and Sussex Crematoria were included in the analysis when they stated the date of death, the date of cremation and the name of the crematorium concerned. We have a data set of 427 cremations, which is six percent of all

18 The Need for a Crematorium to serve East Leeds”, Westerleigh Group, Appendix 9 ‘A survey of the attitudes of the Residents of Leeds City Council to a Proposed Crematorium near Garforth”. 19 Appeal Ref. APP/D0840/A/09/2098108 Land at Race Farm, Puggis Hill, Treswithian, Camboure, Cornwall. 20 Appeal reference APP F2415/A/14/2211858 Harborough Council v Co-operative Group Land at London Road, Great Glen, Leicestershire 21 Appeal Ref: APP/G2245/A/14/2217055

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cremations that took place that year in these three crematoria.22 From these, we have calculated the average amount of time families waited for a funeral in each month of that year. The results are in Table 29:

Crematorium Month (Jan-Dec 2019) Average Wait (days) J F M A M J J A S O N D Kent & Sussex 24 27 26 24 24 27 26 25 25 22 25 25 25 Randalls Park 28 25 28 31 22 19 22 21 21 30 25 31 25 Surrey & Sussex 27 26 25 24 29 22 23 23 22 29 29 23 25 Table 29 Number of days average wait for a service in existing crematoria during 2019

6.20 Table 29 shows that existing crematoria are performing particularly poorly. These waiting times are the longest that Horizon has encountered in all the sites we have considered for planning purposes in the UK. The aim of providing a service within 14 days of a funeral is being missed every single month, even in the summer months when the death rate usually slows. In busy months, all three of these crematoria are making relatives wait on average at least twice the recommended time and there are no months of respite when demand drops sufficiently for the figures to decline.

6.21 This alone is evidence of need and probably explains more than any other factor why there is a perception among Tandridge residents that there is a need for a new crematorium. This perception was illustrated both during the public consultation on the planning application undertaken by Horizon and during the public consultation undertaken by Tandridge District Council. During the Horizon consultation, 90 percent of those who completed a questionnaire answered Yes to the question “Do you believe that a crematorium to serve the Tandridge Council area and surrounding communities is needed?” Many of these had concerns about the application but, nonetheless felt that it is needed.

Pricing

6.22 In situations where the customers of crematoria suffer from a lack of choice, prices tend to be higher. The Competitions and Markets Authority, (CMA) undertook an investigation into the cremation market in 2019-2020. One of its conclusions was that prices are higher in areas where there is no choice within 30 minutes of a crematorium.

22 Statistically, this is of sufficient scale to constitute a representative sample.

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“On average, fees at crematoria with alternatives within 30 minutes tend to be lower than fees at crematoria without alternatives. For crematoria who have at least one rival within 30 minutes, differences in average fees, depending on whether the closest rival is located relatively close or further away, are often small, as are differences in average fees depending on the number of rivals located within 30 minutes. For example, average local authority fees when the closest rival is located 20-30 minutes away are £712, falling slightly to £691 when the closest rival is closer (10-20 minutes away). Private providers with two rivals within 30 minutes charge, on average £788, and this falls by less than £10 to £784 when there are three or more rivals within 30 minutes.”23

6.23 This is the situation for the residents of Tandridge. Prices are high in three of the local crematoria. It seems fair to deduce that one of the reasons for this is because there are insufficient crematoria within a 30-minute drive time to provide competition.

6.24 In fact, the situation for Tandridge residents is worse than this because three of the available crematoria (Beckenham, Randall’s Park and Surrey and Sussex) are operated by the same company, Dignity plc.

6.25 Dignity is a professionally run and efficient business offering great quality of care at its facilities. However, its crematoria are the most expensive in the country. The price for a standard service in 2020 at all three of these facilities is £1,070. These are the most expensive crematoria in the UK. Oak Tree/Bluebell (and, incidentally, Darenth) are also being developed by Dignity. When they open, they are likely to further exacerbate the lack of price competition in the region.

6.26 Prices are lower at the Kent and Sussex which is operated by Tunbridge Wells Borough Council and at Croydon Crematorium operated by the London Borough of Croydon. The headline cost of a funeral here at Tunbridge Wells is £690, but this omits essential ‘extras’ such as the medical referral fee and an environmental surcharge bringing a comparative cost to £768.

6.27 Croydon Crematorium charged £889 for a standard cremation in 2020.

6.28 Prices at the two local authority operated facilities are lower than the prices charged by Dignity. However, both are still significantly above the £712 that the CMA found was the average for a local authority in areas where crematoria faced competition within a 30-minute drive time.

6.29 Pricing is, perhaps a crude tool to measure need, but it is nonetheless interesting that all five of these crematoria charge relatively high prices. Those reading the CMA report might contend that these prices would fall were there more crematoria in the area.

23 Competition and Markets Authority. Funerals Market Investigation. Updated Review of Key Research and Analysis. February 2020 Para 81 (b)

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A Qualitative Assessment of Beckenham Crematorium

6.30 Beckenham Crematorium is situated in the grounds of Beckenham Cemetery which sits on a large 32-acre plot covered with mature trees and shrubs and first opened in 1876. Originally there were two gothic chapels at the centre of the cemetery, but they were badly bombed in WW2 and the second was demolished. The first is used as the chapel for the crematorium and has an extension on the side dating from the 1950. The crematorium opened in 1956.

6.31 The crematorium is approached up an attractive drive from the magnificent main entrance with its stone piers and wrought iron gates which go back to the opening of the cemetery. There is though only one car park that can, at best, accommodate 30 cars. This is woefully short of the standards suggested by the Federation of Cremation and Burial Authorities (FBCA) which, in its 2016 “Guide to Cremation Figure 10 The approach to Beckenham Crematorium showing the gothic chapel, and Crematoria”, porte-cochere and prominent brick cross. recommends that parking provision for crematoria should be “approximately two thirds of the total seating capacity of the chapel”. During busy services at Beckenham, cars park on the access roads.

6.32 The Crematorium is, however, well served by public transport, with Birkbeck Station situated by the entrance, Elmers End Station and the Harrington Road Tram Stop for Tramlink.

6.33 The Chapel has a very traditional feel. Mourners face stained glass windows in front of which is a catafalque which can be lowered at the end of the service to represent a burial. Christian religious iconography within the chapel can be moved for other religions or non-religious services. However, it is harder to hide the enormous cross built in brick on the main wall as funeral corteges approach the chapel.

6.34 Inside, the chapel can seat 90 people and accommodate others standing. Seats are used rather than pews and the layout with a large and Figure 11 View of the Chapel wide area to the rear of the chapel means that it is

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a design that will work effectively with both large and small funerals. The use of seats also makes disabled access easier and are more flexible when dealing with smaller funerals. The chapel is very light with seven tall windows flanking the rear of the large room and allowing light to flood in.

6.35 The Chapel uses the Obitus music system. The coffin is place on a central catafalque and for cremations can be lowered at the end of a service to simulate a burial. For a burial it remains raised and the coffin is then taken to the graveside after the service.

6.36 Beckenham is the only crematorium of those we have assessed that is not fully abated for mercury. In an unabated system, when dental amalgam is incinerated, mercury is emitted into the air from the cremator stack. Mercury is a highly toxic heavy metal. It can be inhaled or be ingested by falling onto cultivated land or being washed by rain into rivers and the sea and, thereby, entering Figure 12 View to the rear of the Chapel the food chain.

6.37 The UK is a signatory to the 2003 Oslo-Paris Commission agreement on eliminating mercury emissions from crematoria. In 2005, the Department of the Environment Fisheries and Foods (DEFRA) required that, by 2012, half of mercury emissions would be eliminated and, by 2020, all facilities would need to have zero emissions.

6.38 Complying with the Oslo-Paris Commission Agreement has proved difficult for some facilities. Abatement equipment is both costly and very bulky. Some old crematoria have proved impossible to convert, sometimes because buildings are listed and it is impossible to secure planning permission for the alterations so the facilities can comply with the new standards. We suspect that Beckenham is one of these.

6.39 However, it cannot be sensible to refuse planning permission for a new facility that will have mercury abatement equipment fitted when one of the facilities that is perhaps suggested as meeting need in an area remains unabated. This is especially the case given that Beckenham Crematorium is in London and surrounded by a large residential population. Worse still the cremator room is situated to the north east of Beckenham Cemetery and so emissions will be pushed towards the nearest houses by the prevailing south westerly winds.

6.40 To the west of the Chapel is an area of rockwork with cascades and pools and there is a garden of remembrance with brick-piered pergolas and rosebeds. The setting of the crematorium within the large graveyard and adjacent to South Norwood Country Park means that the facility feels properly funereal. Some of the older stones in the graveyard are in poor repair but this all adds to the quiet and tranquil feel to the grounds.

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6.41 Considering it is the result of several periods of building, Beckenham Crematorium is attractive. There are significant issues however, not least of which is the lack of an abatement plant to cleanse emissions of mercury and the wholly inadequate car parking facilities. The building is also showing its age particularly with the preponderance of Christian religious symbols which are fast becoming out of keeping with many modern services.

A Qualitative Assessment of Croydon Crematorium

6.42 Croydon Crematorium is situated within the large Mitcham Road Cemetery which first opened in 1897. The crematorium was originally built in 1937 (the West Chapel goes back to that time) in brick to a traditional and gothic design. It was then extended in 1962 with the addition of the East Chapel with architecture in keeping with its 1960s municipal roots.

6.43 There are two entrances, one on Mitcham Road and another on Thornton Road. Visitors by car can park in a car park with 80 spaces adjacent to the chapel. Given the capacity of the two chapels, this would appear to be a significant under-provision of parking spaces and is far short of the 138 that would be provided were the FBCA guidelines being adhered to. Access roads within the Figure 13 Croydon Crematorium cemetery are used for overflow parking during busy services.

6.44 There are reasonable public transport links to the cemetery. There are bus stops outside each of the two entrances and Therapia Lane tram stop is a 500m walk from an entrance. However, visitors who decide to leave the car at home still have something of a trek when they enter the cemetery as once in, even by the shortest route, it is still half a kilometre to get to the crematorium building.

6.45 Entrance to the crematorium is from under a large timber-clad porte-cochere, which is a relic of the 1962 additions to the building. It is large enough for a hearse but not a limousine as well.

Figure 14 East Chapel, Croydon

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6.46 Croydon has two crematorium chapels and a separate chapel which is used for burial services. East Chapel, which seats 130 people, is an attractive if somewhat municipal, long and narrow room which resembles a 1960’s school assembly hall. It is light and airy. The catafalque is situated to the right- hand side of the room and a lectern for speakers is to the left. There is no obvious religious iconography in this room. The Chapel has both an organ and uses the Wesley music system.

6.47 West Chapel is a much more traditional space finished in brick with a vaulted ceiling. It seats 80 people in traditional wooden pews which are attractive to those of us with a church upbringing but not at all flexible and out of step with modern demands for non-religious and humanist services. A large cross is suspended on the wall above the catafalque. The coffin is placed on a traditional central catafalque system with the coffin descending at the end of the service to replicate a burial. The Chapel has both an organ and uses the Wesley music system.

6.48 Unusually Croydon does not have the ability to stream services remotely.

6.49 Surrounding the crematorium are formal gardens with a pond, winding paths and drives. Because of its age, there are fine mature trees in which are set traditional rose gardens and pathways with seating. As you get away from the Figure 15 West Chapel, Croydon crematorium and enter the cemetery, the gardens are less formal with a grid of paths, an avenue of Limes and some fine specimen trees.

6.50 In many ways Croydon seems quite comparable to Beckenham. It offers an attractive setting for a traditional funeral. However, the experience of later extensions to a gothic designed building has, perhaps been less successful at Croydon. It also suffers many of the same problems – prominent Christian iconography and wholly inadequate car parking facilities. One gets the impression that Croydon has had less investment than Beckenham in recent years – it is less well maintained, and the lack of a functioning video streaming service must have been particularly problematic during the pandemic when so few relatives were able to attend funerals first hand.

A Qualitative Assessment of Kent and Sussex Crematorium, Royal Tunbridge Wells

6.51 The Kent and Sussex Crematorium opened in 1958 and is located on the south east outskirts of Tunbridge Wells in a semi-urban area.

6.52 It is entered through a pair of brick pillars with wrought iron gates. The crematorium is next door to a cemetery, but has its own entrance and separate exit, thus avoiding conflict between traffic to either the cemetery or between funerals arriving and leaving the crematorium.

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6.53 The crematorium is set in extensive and well-kept grounds with one reviewer commenting that it was a “beautiful place”. The driveway is through open lawns dotted with trees. A line of trees draws a boundary between the crematorium grounds and the cemetery. More trees screen the chapel from houses to the rear. The chapel is at the end of a 250m long drive with a car park beyond.

6.54 A main car park of 40 spaces including two for disabled is supplemented by an overflow with an additional 17 bringing numbers close to the 60 parking spaces required to service a chapel with a capacity of 90. The layout of all the car parks is practical and at the time we visited there was no congestion and this was at a time when one service followed another. The nearest point of the car park is 50m from the chapel entrance, the distance from the disabled spaces is just a few yards further. The nearest point in the overflow car park is 70m away from the chapel.

6.55 The Kent and Sussex is fairly well served by public transport. A bus service which runs past the crematorium entrance to Tunbridge Wells railway station and town centre.

6.56 The external access to the chapel is not level, and there is a ramp with a moderate slope leading from the car park to the entrance. However, a wheelchair is available in entrance hall and the entrance doors are double width. These arrangements are not ideal. Once inside, there is level access into the chapel and motorised scooters are allowed in public parts of Figure 16 Kent and Sussex Crematorium the building.

6.57 The chapel, which dates from 1958, reflects the architecture of the era and is neutral and functional in appearance, albeit rather uninspiring – it is a bland ‘school hall’ of a building. It has a large cross mounted above the entrance – an unremarkable feature in 1958, but now out of keeping with the many non-religious and non-Christian services that will take place.

6.58 There is a large porte-cochere, which has plenty of room for a hearse and a limousine. Underneath this, there are loudspeakers which would allow the service to be broadcast outside.

6.59 There is a spacious entrance hallway which is unlikely to suffer congestion, and a straight run from a hearse to the catafalque, which is set a little to the left of the centre of the far end of the chapel. This is open but has curtains to one side.

6.60 A waiting room is set to the left-hand side of the hall as one enters and has doors both to the hallway and to the front of the building. It has 17 seats. Toilets are situated at one end of the waiting room, which is equipped with a drinks machine and books of remembrance.

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6.61 The chapel has 90 seats, which are removable to create space for more people to stand. Overall, the chapel is light and airy with exposed brickwork and light-coloured woodwork. Two large screens are available for displaying photographs or Figure 17 The Chapel at the Kent and Sussex video footage.

6.62 Service lengths for the chapel are 30 minutes for the first and last service of the day, with all other services being 45 minutes. Additional consecutive service times are available. The chapel has an induction loop hearing assistance.

6.63 The Chapel is fitted with an organ and is also equipped to play digital music, drawing pieces from an online library. Audio and video recording of funerals can be arranged as well as webcasts, both live on the day and on demand for 28 days afterwards.

6.64 The exit to the chapel is at the far right and leads to two rectangular courtyards, one with a covered walkway on all four sides. This has a garden, a pool and a gentle fountain. However, in poor weather or in winter months this can appear rather gloomy, and certainly would not inspire mourners to stop and reflect.

6.65 The other courtyard, the flower cloister, which has no overhead cover, has a circular structure in its centre for memorial plaques. Both courtyards have plenty of space for mourners to congregate and for flowers to be displayed. Both open out onto the car park, the first having a small porte- cochere, big enough for one vehicle.

Figure 18 The Flower Courtyard 6.66 Over the years the crematorium has undergone several upgrades and refurbishments, the latest in 2014 included a £1.1m replacement of the two cremators with state of art emissions monitoring and filtration equipment plus a new catafalque and curtains.

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6.67 While the building itself is bland and uninspiring externally, the chapel is pleasant, though could seem a bit intimidating for a smaller funeral. Access is not ideal for disabled mourners and some may require the use of a portable ramp. Neither of the flower courtyards present ideal surroundings all the year round for mourners to congregate, reflect and chat. One is completely uncovered, and the other is only partly covered.

A Qualitative Assessment of Randalls Park Crematorium, Leatherhead

6.68 Randalls Park Crematorium opened nearly 60 years ago in 1961. It is located a little more than a mile to the west of the centre of Leatherhead and set in fairly open countryside. The site and adjoining cemetery are lined by a belt of trees, which thicken into a wood to the south and east of the crematorium. Significantly, the River Mole forms part of the southern boundary to the site.

6.69 This is significant because Randalls Park floods. Several of the incidents have been serious. In both 2013 and 2014, the facility and had to close each time for three months. It flooded again over Christmas 2019. In March 2020, it re-opened, but held services in a temporary marquee while building work began. It was not until later in 2020 that the situation was resolved.

6.70 The entrance to the crematorium is off the A245 Randalls Road and is shared with the cemetery. It leads to a small roundabout with a left turning to the cemetery, a right turn for the crematorium car park, but corteges would continue straight ahead to the chapel. That road forms a loop around the crematorium building for the return journey.

6.71 Both the road to the crematorium and the car park run through open grassland with a few trees dotted along their lengths. The distance between the entrance and the chapel is about 160 yards.

6.72 A single car park has a practical layout with an easy walk to the chapel entrance, which is 60 yards from the nearest point to the Figure 19 Randalls Park flooded in 2013,2014 and 2019-20 entrance. There are 93 car parking spaces, with a further three for disabled parking, significantly more parking than the capacity of the chapel would seem to require.

6.73 There is an extensive remembrance gardens located adjacent to the car park.

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6.74 The crematorium is poorly served for public transport. Leatherhead Station is only three quarters of a mile from the entrance but unfortunately no bus services go up Randalls Road and there are no stops near the crematorium.

6.75 The crematorium has easy disabled access and there are no steps into the building. Being all on one level, this facilitates the use of wheelchairs. There are disabled toilets in the building.

6.76 The Crematorium itself is an untidy jumble of buildings that seems to have suffered over time from additional facilities having been added to a central core. It is now a bit of an architectural mish mash. The chapel building proper is of red brick with three round arched windows to its front, and three tall windows on either side. Otherwise, it is featureless. It looks bleak. The building appears to be in good order, although the brick signage marking the entrance is weathered and a little dreary.

6.77 Internally, the chapel appears light and airy but seats only 72 mourners. The catafalque is set to the right, with an exit is to the left. At the far end of the chapel there is a curtain wall with three arches, beyond which is a table and candles. There is no religious iconography on the outside of the chapel, and apparently none on the inside.

6.78 The chapel has an induction loop for the hard of hearing. There are facilities for photographic tributes and the Wesley media system for recorded music. Webcasting is also available as well as facilities for video and audio recording of services.

6.79 Having exited the Chapel mourner enter a small memorial garden set around an open area with a small square to its left with a flowering tree at its centre. The area also includes a brick pergola with memorial plaques on its walls and there is space for mourners to congregate. This leads to the road at the rear of the building where cars can collect mourners waiting under a canopy. Figure 20 Randalls Park - A Mishmash of Styles and Materials

6.80 Online reviews of the building are mixed. One commented: “It was warm and welcoming”. Conversely a number of other reviewers said the chapel and waiting room were “freezing cold”.

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6.81 Randalls Park is showing its age. It is set within attractive grounds and the buildings are a hotchpotch of different styles. The chapel is small and must struggle to accommodate large funerals. Given that this is the highest price point in the country, customers may well feel they are being taken advantage of. However, the biggest problem is that the site floods, and if the last five years are anything to go by, will continue to do so.

A Qualitative Assessment of Surrey and Sussex Crematorium, Reigate

6.82 Surrey and Sussex Crematorium opened in 1956 and is set in 13 acres of dense woodland in a semi- urban area a little more than a mile south east of Gatwick Airport. Less than half a mile to the east is the M25, but road and to some extent aircraft noise is deadened by the significant woodland planting.

6.83 The entrance opens onto a driveway from which it is only 200m drive through trees and attractive gardens to the chapels. It feels as though the crematorium is set in a woodland grove and indeed there are several favourable reviews online about the beauty of the gardens: “what beautiful grounds….the whole place was pristine” and “beautiful place, the gardens are always immaculate”.

6.84 The crematorium has 124 parking spaces in total. The Federation of Burial and Cremation Authorities (FBCA) in its 2016 “Guide to Cremation and Crematoria” recommends that parking provision for crematoria should be “approximately two thirds of the total seating capacity of the chapel”. With two chapels seating 188 people in total, Surrey and Sussex Crematorium meets this requirement exactly.

6.85 Parking is split between two areas, one of 91 spaces and the other of 33 including two disabled spaces. Both are within easy Figure 21 The Gardens at Surrey and Sussex Crematorium walk of the crematorium entrance.

6.86 However, the crematorium is poorly served by public transport. It is over two miles from the Three Bridges railway station and there are no bus stops nearby.

6.87 The crematorium is largely accessible to a wheelchair user. St Richard’s Chapel does not have level access, but there are ramps for wheelchair mourners. St Michael’s Chapel has level access and a wide doorway.

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6.88 The crematorium itself is a cluster of brick buildings well over 60 years old. They are in good order. The facility has two separate chapels: St Richard’s, which is the larger and St Michael’s, more usually known as the Memorial Chapel. There does not appear to be any external religious iconography.

6.89 Slots for services are limited to 45 minutes, within the standard of 45 minutes suggested by the Trajectory Report and the 40-45 minutes recommended by the ICCM.

6.90 Both chapels are equipped with induction loops for the hard of hearing. There are CCTV cameras mounted on walls outside the crematorium buildings.

6.91 St Richard’s Chapel, the larger chapel, has a porte-cochere which can accommodate a hearse, but not a limousine. There is plenty of room at the entrance to avoid a bottleneck, except perhaps for the largest funerals. Figure 22 St Richard's Chapel

6.92 There is a straight run from the entrance to the catafalque, which is set to the left at the front of the chapel. It can be hidden behind curtains. There is also a table in a recess at the front with candles and a free-standing cross.

6.93 The chapel feels very traditional and ‘Church-like’ in keeping with the time in which it was built, even though there is no fixed religious iconography in the chapel. A lectern is placed alongside the catafalque.

6.94 The chapel is light and airy and has tall, attractive stained-glass windows. It has 134 removable seats plus enough standing room to take its maximum capacity to 200. It is equipped with two large screens allowing photographic tributes to be displayed, and an organ and facilities for recorded music. It has facilities to broadcast a service to mourners outside the chapel, and a member of staff said they once coped with a funeral attended by 300 people. Figure 23 The Memorial Chapel

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6.95 The exit is to the left of the entrance, which opens out onto a courtyard, allowing mourners to congregate and inspect floral tributes. This contains memorial wall plaques. At one end of the courtyard is a small building containing male, female and disabled toilets, shared between the two chapels, and a waiting room for bereaved families with 10 seats.

6.96 St Michael’s Chapel does not have a porte-cochere, and its hallway is sufficiently large to avoid congestion. There is a straight run into the catafalque at the far end of the chapel in the centre. This is surrounded by curtains and has a table the left front of the chapel, with candles and a free-standing cross. There are lecterns to the left and right of the catafalque.

6.97 The chapel is light and airy and, like St Richard’s Chapel, has attractive modern stained-glass windows. It has 54 removable seats, but when they are all in place there is little standing room. Like the larger chapel it is equipped with two screens, an organ and facilities for recorded music.

6.98 It too has a dedicated waiting room, this time with 11 seats.

6.99 The exit is to the left of the entrance, and it leads to an open courtyard allowing mourners to congregate and for flowers and wreaths to be displayed.

6.100 No services were being conducted during the visit, but there is plenty of space to allow arriving and outgoing funerals to pass each other without too much difficulty.

6.101 The cremators in the Surrey and Sussex are all fully abated meaning that the facility complies with the most recent emissions regulations.

6.102 Surrey and Sussex has a most attractive setting of woodland and gardens which provides a natural screening and sound deadening for Gatwick Airport in close proximity. The grounds are highly regarded by mourners and have received many favourable comments, as have the services provided.

6.103 However, there are several issues, which although minor in themselves, might cumulatively detract from the attractive grounds. These include the Christian feel to the chapels, the lack of a bus services to the crematorium (and the railway station is two miles away); rather small waiting rooms; toilet facilities shared between the two chapels; the lack of a porte-cochere for the smaller chapel and open courtyards for the flowers and congregating after the funeral, which are not ideal in the winter months and when the weather is poor.

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7 Conclusions

7.1 There is both a quantitative and a qualitative need for a new crematorium in and around Tandridge. The qualitative need is set out in Table 30. Averages 2015-2019 Summary Beckenham Croydon Kent & Randalls Surrey & Sussex Park Sussex Annual cremations 1592 1772 1553 2186 1636 Annual cremation minus directs 1559 1737 1477 2164 1626 Annual burial services 168 0 0 0 0 Total services 1759 1737 1477 2164 1626 Total Slots Available 2520 5040 3024 2520 2520 Technical Capacity 70% 34% 49% 86% 65% Total Core Slots Available 2016 3780 1764 2016 1764 Practical Capacity 87% 46% 84% 107% 92% Average Monthly core slots available 168 315 147 168 147 Average monthly services 147 145 123 180 136 Difference between peak and average 27% 28% 28% 28% 28% month (See appendix one) Calculated peak month services 187 192 157 230 174 Practical Capacity in peak month 111% 61% 107% 137% 118% Table 30 Summary of Cremation Capacity 2015-2019 assuming Wealden and Oak Tree/Bluebell

7.2 Table 30 demonstrates that four of the five crematoria open to Tandridge residents are failing tests of quantitative capacity. The worst performer is Randall’s Park at Leatherhead, which cannot meet practical capacity tests even on an average month, let alone during the busy times of the year. Beckenham, the Kent and Sussex and Surrey and Sussex Crematorium all fail tests of practical capacity in the peak month and do so by some margin. Only Croydon Crematorium has capacity.

7.3 Evidence suggests (paras 5.60-5.65) that Tandridge residents overwhelmingly use Surrey and Sussex Crematorium. Very few of the district’s residents choose to go to Croydon Crematorium even though it has capacity. We believe this is because of the difficulty of the journey through congested roads and a complicated network and because there are cultural preferences for a crematorium that is outside London.

7.4 The capacity at the Croydon Crematorium is having little or no impact on the overtrading of the crematoria to the south, as the difficulties in these facilities have persisted for each of the five years tested with no indication of a migration of funerals from the overtrading facilities in the south to Croydon.

7.5 Alongside these quantitative failings are several qualitative problems.

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7.6 A substantial population (125,900 people from a total population of 358,000 in the districts of just Reigate and Banstead, Sevenoaks and Tandridge) live more than a 30-minute drive24 from an existing or permitted crematorium. Within Tandridge Council alone, 64,500 people out of a total population of 87,500 live in an area that is more than a 30-minute drive of a an existing or permitted crematorium. This means that nearly three quarters of Tandridge residents must spend more (and often substantially more) than 30 minutes driving to a crematorium when in a funeral cortege.

7.7 Were the proposed facility at Oxted to proceed, it would bring all but 1,950 Tandridge residents within thirty minutes of a crematorium. In these circumstances, 88% of the population of Tandridge District, 77,379 people - would be within a thirty-minute drive of the Oxted site.

7.8 The proposed crematorium at Woodhatch Road, Reigate would be far less beneficial for Tandridge residents. Were it to proceed, 41,000 Tandridge residents, nearly half the population would remain in ‘white land‘; that is more than a 30 minute drive from a crematorium.

7.9 Research on the length of time people wait for a funeral, shows that three of the facilities tested, (Kent and Sussex, Randalls Park and Surrey and Sussex Crematorium) are so overcrowded that people are having to wait unacceptable periods to secure a funeral. The average across the year for all three facilities is 25 days, significantly more than the 14 days recommended.

7.10 People are paying more than might be expected in all five of the facilities tested. Three of them, Beckenham, Randalls park and the Surrey and Sussex are operated by one company. They all charge the same price (£1,078) which is the highest price for a cremation registered in the country. Both Beckenham and Kent and Sussex Crematoria charge more than the CMA found was average in areas where populations did not have to travel more than 30-minutes to reach a crematorium.

7.11 All five of the facilities are aging, (the most recent is 60 years old) and each one has design features that would not be acceptable now – be it inadequate car parking, poor public transport, or prominent religious iconography.

7.12 Two of these crematoria have deep rooted and very significant issues that seem impossible to rectify – Beckenham is not fitted with equipment to abate mercury emissions and Randalls Park has a problem with flooding that has caused it to shut down for extended periods three times in the last eight years.

7.13 The need for a new crematorium in this area is compelling and urgent.

24 30 minutes assuming the journey of a funeral cortege, at cortege speed avoiding motorways.

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Appendix One Deaths per Month in Local Authorities within the Catchments of Each Existing Crematoria As identified earlier in this report for the purposes of analysis it is important to understand not only the number of deaths in each local authority area, but also their monthly distribution and the extent to which this diverges between average and peak months. This may be ascertained from the datasets set out below. Beckenham

2019 Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Bromley 262 211 213 210 229 208 195 208 193 216 244 194 Croydon 250 201 181 240 196 190 198 178 209 235 236 212 Lambeth 145 110 124 125 140 102 118 119 100 122 108 94 Lewisham 160 152 146 104 139 112 126 99 130 117 128 147 Tandridge 92 74 78 80 51 52 55 67 66 80 78 78 Average 182 150 148 152 151 133 138 134 140 154 159 145 149

2018 Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Bromley 327 275 265 240 221 180 220 215 192 212 208 193 Croydon 281 247 246 211 191 188 216 217 175 237 191 206 Lambeth 178 125 145 129 99 93 117 113 111 112 121 118 Lewisham 165 158 154 153 142 121 96 108 99 139 132 132 Tandridge 87 77 80 65 59 39 59 71 50 72 78 69 Average 142 121 125 112 98 88 98 102 87 112 104 105 108

2017 Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Bromley 319 262 211 211 192 165 183 199 207 204 214 221 Croydon 281 219 197 189 222 189 186 204 173 203 248 207 Lambeth 129 142 118 95 133 127 110 113 105 116 131 103 Lewisham 156 125 122 115 145 138 105 129 109 124 129 137 Tandridge 103 68 81 57 74 69 42 53 62 66 95 79 Average 134 111 104 91 115 105 89 100 90 102 121 105 105

2016 Jan Feb Mar Apr May Jun July Aug Sept Oct Nov Dec Bromley 231 227 241 254 206 209 194 215 226 195 243 214 Croydon 219 236 222 230 169 189 183 187 192 178 214 205 Lambeth 129 114 147 132 113 141 99 95 123 110 117 120 Lewisham 131 123 141 151 114 92 106 138 120 113 132 106

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Tandridge 78 62 71 89 66 65 56 63 60 77 60 72 Average 111 107 116 120 92 97 89 97 99 96 105 101 103

2015 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Bromley 283 217 266 229 195 196 198 186 179 192 211 224 Croydon 306 218 219 225 188 197 175 171 253 199 199 228 Lambeth 162 123 138 130 103 123 157 106 101 154 97 114 Lewisham 178 137 176 122 97 128 149 102 133 120 115 142 Tandridge 94 62 64 71 62 68 42 59 69 72 59 68 Average 148 108 119 110 90 103 105 88 111 109 94 110 108

2015 2016 2017 2018 2019 Average month 108 103 105 108 149 Peak Month 148 120 134 142 182 Difference 37 17 27 32 22

Croydon

2019 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Tandridge 92 74 78 80 51 52 55 67 66 80 78 78 Reigate & Banstead 166 115 114 94 112 101 94 93 88 99 108 96 Croydon 250 201 181 240 196 190 198 178 209 235 236 212 Sutton 153 124 137 125 130 108 107 112 113 103 117 130 Merton 131 92 117 109 92 79 102 88 89 124 87 112 Average 158 121 125 130 116 106 111 108 113 128 125 126 122

2018 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Tandridge 87 77 80 65 59 39 59 71 50 72 78 69 Reigate & Banstead 149 133 139 120 93 88 95 102 86 98 88 95 Croydon 281 247 246 211 191 188 216 217 175 237 191 206 Sutton 171 154 166 144 136 105 126 120 97 124 124 119 Merton 162 126 121 108 95 93 106 95 79 92 92 95 Average 170 147 150 130 115 103 120 121 97 125 115 117 126

2017 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Tandridge 103 68 81 57 74 69 42 53 62 66 95 79 Reigate & Banstead 147 133 122 99 114 115 86 116 105 108 118 130

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Croydon 281 219 197 189 222 189 186 204 173 203 248 207 Sutton 163 129 127 95 132 105 96 97 109 113 128 128 Merton 156 92 109 86 104 87 79 101 96 108 88 111 Average 170 128 127 105 129 113 98 114 109 120 135 131 123

2016 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Tandridge 78 62 71 89 66 65 56 63 60 77 60 72 Reigate & Banstead 120 128 136 110 110 105 92 95 110 107 120 90 Croydon 219 236 222 230 169 189 183 187 192 178 214 205 Sutton 151 133 160 131 116 115 103 121 128 121 117 131 Merton 108 102 122 108 109 81 82 106 82 85 107 114 Average 135 132 142 134 114 111 103 114 114 114 124 122 122

2015 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Tandridge 94 62 64 71 62 68 42 59 69 72 59 68 Reigate & Banstead 175 138 128 137 98 127 87 83 118 117 120 127 Croydon 306 218 219 225 188 197 175 171 253 199 199 228 Sutton 162 145 147 110 109 112 104 86 105 99 109 132 Merton 153 111 107 107 94 88 94 84 111 115 83 104 Average 178 135 133 130 110 118 100 97 131 120 114 132 125

2015 2016 2017 2018 2019 Average month 125 122 123 126 122 Peak Month 178 142 170 170 158 Difference 43 17 38 35 30

Kent and Sussex, Tunbridge Wells

2019 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 107 109 98 95 90 89 87 72 95 89 106 93 Tunbridge Wells 92 74 78 80 51 52 55 67 66 80 78 78 Wealden 168 157 146 151 149 129 134 135 151 183 158 150 Tonbridge and Malling 119 99 96 90 76 69 82 85 78 95 78 95 Rother 146 101 133 106 134 103 98 95 82 130 125 118 Average 126 108 110 104 100 88 91 91 94 115 109 107 104

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2018 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 130 101 108 102 82 86 89 90 85 100 98 73 Tunbridge Wells 126 106 107 86 90 87 81 75 84 106 82 74 Wealden 201 167 191 165 164 124 140 119 130 140 137 138 Tonbridge and Malling 139 101 101 94 86 98 82 95 89 101 79 97 Rother 151 125 128 117 108 72 101 97 102 118 114 92 Average 149 120 127 113 106 93 99 95 98 113 102 95 109

2017 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 131 81 94 85 116 80 88 80 76 86 88 80 Tunbridge Wells 97 86 85 87 105 78 82 73 82 79 80 96 Wealden 190 175 142 145 122 143 139 143 151 155 132 159 Tonbridge and Malling 116 85 94 77 87 82 69 80 58 100 95 93 Rother 176 125 130 98 106 118 95 92 101 121 118 112 Average 142 110 109 98 107 100 95 94 94 108 103 108 106

2016 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 89 85 83 88 90 74 83 89 64 84 89 84 Tunbridge Wells 92 74 99 97 106 100 78 73 75 91 96 85 Wealden 138 139 157 161 132 141 125 126 144 150 171 145 Tonbridge and Malling 96 78 99 107 70 88 70 76 81 83 82 95 Rother 113 116 140 115 101 95 97 86 81 101 119 107 Average 106 98 116 114 100 100 91 90 89 102 111 103 102

2015 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 139 86 115 96 84 80 64 72 80 84 99 103 Tunbridge Wells 131 96 71 104 79 81 85 84 86 85 59 82 Wealden 204 147 142 141 115 140 136 132 156 141 155 152 Tonbridge and Malling 123 73 77 99 76 83 77 61 96 88 79 88 Rother 176 130 121 123 127 111 117 92 121 106 112 115 Average 155 106 105 113 96 99 96 88 108 101 101 108 106

2015 2016 2017 2018 2019 Average month 106 102 106 109 104 Peak Month 155 116 142 149 126

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Difference 45 14 34 37 22 Randalls Park, Leatherhead

2019 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Kingston 111 95 80 87 96 89 85 93 78 77 90 83 Mole Valley 77 69 72 63 71 70 63 59 65 70 63 65 Tandridge 92 74 78 80 51 52 55 67 66 80 78 78 Reigate & Banstead 166 115 114 94 112 101 94 93 88 99 108 96 Elmbridge 121 107 77 93 88 74 73 72 85 100 89 98 Guildford 97 92 93 89 103 85 70 78 82 83 83 75 Epsom & Ewell 66 42 53 47 43 37 44 29 41 46 52 50 Average 104 85 81 79 81 73 69 70 72 79 80 78 79

2018 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Kingston 125 104 104 107 88 93 79 86 77 93 85 77 Elmbridge 135 94 109 100 85 92 76 89 87 94 105 76 Epsom & Ewell 53 43 64 55 40 46 41 48 38 54 56 41 Guildford 120 103 88 83 94 92 83 73 90 65 66 86 Mole Valley 87 77 80 71 61 56 46 49 49 95 63 71 Reigate and Banstead 149 133 139 120 93 88 95 102 86 98 88 95 Tandridge 87 77 80 65 59 39 59 71 50 72 78 69 Average 108 90 95 86 74 72 68 74 68 82 77 74 81

2017 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Kingston 122 110 79 92 77 100 77 89 74 82 101 99 Elmbridge 116 86 92 80 96 83 79 72 102 96 100 101 Epsom & Ewell 62 57 53 41 56 35 43 39 52 39 44 50 Guildford 118 106 90 72 87 85 76 88 101 76 89 102 Mole Valley 96 81 61 73 61 84 50 71 50 77 57 80 Reigate and Banstead 147 133 122 99 114 115 86 116 105 108 118 130 Tandridge 103 68 81 57 74 69 42 53 62 66 95 79 Average 109 92 83 73 81 82 65 75 78 78 86 92 83

2016 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Kingston 107 99 111 103 72 88 81 72 75 72 82 105 Elmbridge 104 79 96 92 83 82 77 87 94 97 86 101 Epsom & Ewell 52 61 58 62 43 47 51 46 59 45 38 57

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Guildford 97 98 91 88 106 95 88 76 79 81 96 106 Mole Valley 82 65 74 98 58 86 66 68 56 70 81 77 Reigate and Banstead 120 128 136 110 110 105 92 95 110 107 120 90 Tandridge 78 62 71 89 66 65 56 63 60 77 60 72 Average 91 85 91 92 77 81 73 72 76 78 80 87 82

2015 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Kingston 118 101 101 85 87 99 87 76 65 111 97 92 Elmbridge 140 96 101 95 67 100 80 75 76 85 72 110 Epsom & Ewell 83 56 56 36 32 57 57 43 45 45 49 58 Guildford 139 103 93 88 68 97 91 65 81 81 83 100 Mole Valley 95 77 95 77 69 82 62 64 68 54 68 72 Reigate and Banstead 175 138 128 137 98 127 87 83 118 117 120 127 Tandridge 94 62 64 71 62 68 42 59 69 72 59 68 Average 121 90 91 84 69 90 72 66 75 81 78 90 84

2015 2016 2017 2018 2019 Average month 84 82 83 81 79 Peak Month 121 92 109 108 104 Difference 44 12 32 34 32

Surrey and Sussex, Redhill

2019 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Tandridge 92 74 78 80 51 52 55 67 66 80 78 78 Reigate & Banstead 166 115 114 94 112 101 94 93 88 99 108 96 Sevenoaks 107 109 98 95 90 89 87 72 95 89 106 93 Mid Sussex 148 112 120 117 115 93 108 93 99 116 125 113 Wealden 168 157 146 151 149 129 134 135 151 183 158 150 Crawley 65 76 70 68 74 53 48 46 59 66 63 70 Horsham 136 123 111 97 116 99 113 88 102 127 95 104 Average 126 109 105 100 101 88 91 85 94 109 105 101 101

2018 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 130 101 108 102 82 86 89 90 85 100 98 73 Mid Sussex 176 113 146 131 95 93 107 96 99 103 109 114

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Wealden 201 167 191 165 164 124 140 119 130 140 137 138 Crawley 97 63 80 68 65 56 50 56 64 57 58 50 Horsham 141 100 130 126 97 111 100 88 101 104 107 100 Reigate and Banstead 149 133 139 120 93 88 95 102 86 98 88 95 Tandridge 87 77 80 65 59 39 59 71 50 72 78 69 Average 140 108 125 111 94 85 91 89 88 96 96 91 101

2017 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 131 81 94 85 116 80 88 80 76 86 88 80 Mid Sussex 174 149 132 102 110 106 104 98 104 104 104 111 Wealden 190 175 142 145 122 143 139 143 151 155 132 159 Crawley 88 67 78 51 54 69 51 61 64 57 61 52 Horsham 168 101 132 101 109 101 89 99 119 98 122 103 Reigate and Banstead 147 133 122 99 114 115 86 116 105 108 118 130 Tandridge 103 68 81 57 74 69 42 53 62 66 95 79 Average 143 111 112 91 100 98 86 93 97 96 103 102 103

2016 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 89 85 83 88 90 74 83 89 64 84 89 84 Mid Sussex 133 135 111 126 77 95 89 97 106 115 132 127 Wealden 138 139 157 161 132 141 125 126 144 150 171 145 Crawley 55 65 63 61 65 65 62 66 57 62 78 60 Horsham 100 119 122 112 93 117 98 101 97 88 113 102 Reigate and Banstead 120 128 136 110 110 105 92 95 110 107 120 90 Tandridge 78 62 71 89 66 65 56 63 60 77 60 72 Average 102 105 106 107 90 95 86 91 91 98 109 97 98

2015 Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec Sevenoaks 139 86 115 96 84 80 64 72 80 84 99 103 Mid Sussex 148 118 135 125 105 94 106 87 110 113 112 112 Wealden 204 147 142 141 115 140 136 132 156 141 155 152 Crawley 88 61 58 63 43 68 43 53 81 64 63 52 Horsham 171 126 125 112 93 106 85 95 92 106 103 124 Reigate and Banstead 175 138 128 137 98 127 87 83 118 117 120 127 Tandridge 94 62 64 71 62 68 42 59 69 72 59 68 Average 146 105 110 106 86 98 80 83 101 100 102 105 102

69

2015 2016 2017 2018 2019 Average month 102 98 103 101 101 Peak Month 146 107 143 140 140 Difference 43 9 39 38 25

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