Planning – Application Comments

2025/10/27 Please see Documents tab for additional Parish Council's comments (Felmersham & Radwell Parish Council)

Please see Documents tab for Parish Council's comments

Addition comment please see document tab

I make these comments with regards to the recently submitted Foul Drainage Assessment form and associated paperwork.
- the distance to the public foul sewer is less than the number of residencies on the site multiplied by 30m. On the application these '5' plots comprise of 11 mobile homes and 4 touring caravans therefore 15 residencies if the touring caravans are to be occupied, as they are now. Therefore an environmental permit would be required.
- the form states the site will utilise an existing non-mains foul drainage system. There was no system in place prior to this development. The system being used was constructed on the weekend this site was occupied and days before the retrospective planning application was submitted. There was no building control oversight of the installation.
- the form states that the land does not get waterlogged or flooded. This site is well known to be one of the most waterlogged fields in the area when there is wet weather and this is within a village that experiences extreme flooding. Many residents and presumably previous users of the field could evidence this.
- the provided plan does not make it clear as to whether the foul water treatment system will drain into the surrounding ditches. Do the ditches belong to this site or surrounding landowners.
- appendix A provides very low numbers of occupants on the site. A total of 24 people gives an occupancy of under two persons per residency and on plot number one only one person per residency. Such low figures are not realistic and provide no scope for future growth, especially when considering the size of some of the homes on the site. I obviously do not know the present number on the site but the number of vehicles and children present would indicate a higher number.
- without access to the site I am unable to check the other data provided. I trust the various measurements required and those provided will be verified and checked by the correct authority

I wish to object to this application
This is clearly an intentional unauthorised development which should weigh against approval. The infrastructure and occupation took place over a weekend several months after the applicants purchased the land. This was clearly well organised in order to minimise any response by local planning. I would request that the planning dept liaise with the police officer(s) who attended on Saturday 12th April when the infrastructure was being laid as I have heard that the applicants misled them as to their intention. I also understand that planning regulations were breached at the plots where some of the applicants previously resided at in Central Beds. This is evidence of flagrant disregard for established planning laws and processes.

The applicants state that Human Rights Article 2 applies. There is understandably no detail regarding this other than perhaps a very non specific resume from the police regarding general issues at their previous site and a letter from National Gas Transmission regarding a fire at their previous location. If the fire was set by a third party then this may be relevant with respect to fear. If the fire was set by the applicants, then this should not be evidence to necessitate a move. As occupants they should have been aware that fires were not permitted. It would be right to question how a fire set several months after the land in Felmersham was purchased should give credence to a need to move. I trust that the article 2 issue will be thoroughly investigated by qualified professionals. Is it proportionate and necessary that all occupants of 15 homes need to move? If the threat is so great does a publicly documented move of only 20 miles suffice and does such a move create a risk to the wider local community?

Pavenham Road is a minor road that runs between the villages of Felmersham and Pavenham. It is a narrow road with some very tight bends that are often subject to accidents in bad weather. In each village the road is already subject to traffic calming measures due to traffic concerns. At the Pavenham end there are average speed cameras and in Felmersham speed is restricted to 20mph and double yellow lines have been introduced at the bottom end in effort to reduce congestion
Pavenham Road has no footpath and the entrance to this development is well within the 60mph National speed limit. This added to the unsuitable entrance to the site significantly raises the risk to all Road users. I am personally aware of 8 incidents over the past 2 weeks where dogs from the development have run out into the road in front of cars, motorcycles and cyclists, plus incidents where cars have had to brake to avoid vehicles exiting the site to join Pavenham Rd. Thankfully none of these resulted in a collision although the road users had to take avoiding action. I am sure there will have been many more such incidents.
The road and entrance are clearly not suitable for the vehicles and caravans on the site. To evidence this, on the weekend that the site was occupied the applicants cut back trees to widen the entrance and unlawfully blocked the road to other road users to enable access.
The application states the site is suitable for collection of refuse. This seems at odds with the view of the Highways agency who have raised the issue of manoeuvrability of large vehicles on the site. Collection from the roadside would cause a number of issues. The verges around this site are very uneven and would not be suitable for leaving wheelie bins out for collection. To build a low, level verge would detract from the rural setting. With 15 occupied dwellings on the development one would anticipate 15-30 wheelie bins per week. Not only is there no space to leave these out but due to the number they would also significantly affect road safety.
Para 10.51 of The local plan states that sites must 'ensure access is retained at all times for emergency vehicles and servicing requirements, including refuse collection'.

The bottom end of Pavenham Rd, from Baileys Villas down to Grange Road severely floods regularly. There are numerous documented photos of this and it is not unusual for a number of Baileys villas to flood internally as well as the pub cellar. The application proposes covering a large area of the site with tarmac roads and parking bays plus concrete mobile home bases. These hard surfaces will increase the speed at which surface water flows into the ditches surrounding the site and down to the lower part of Pavenham Rd. If flood risk increases this could affect the residents of the houses that are susceptible to flood of their right to enjoy their property peacefully. The application proposes soakaways but provides no evidence of soil permeability in a field that is well known to get boggy when wet.
The proposed sewage system breaches policy 50s of local plan as the applicants have not demonstrated that it is not feasible to connect to the existing sewer nor that the proposed system would not have a detrimental impact on ground or surface water. Para 10.52 of the local plan states ' where foul drainage to a public sewer is not feasible sites will only be permitted if proposed alternative facilities are considered adequate and would not pose an unacceptable risk to the quality or quantity of ground or surface water, pollution of local ditches' . As the proposed system will drain into ditches that feed to down Pavenham Road to the river the possibility of pollution will increase. The environment agency have objected to the proposed foul water system. . I also note the Urbanwater evacuation route heads towards the area of Pavenham Road that floods!

Although not so prevalent in recent years when we get severe snow and cold weather the road at its highest point does become impassable. This has been known to last several days as the tree canopy shelters the frozen peak of the hill from the sun.

The application states that views of the site are limited! Even at this time of year with plants and trees in bloom the site is clearly visible from Pavenham Rd, The Slip and the High Rd and Felmersham Rd in Radwell. As one walks along the road past the site entrance you actually see 10-12 caravans/mobile homes depending on how they are configured at the time plus associated vehicles. Several caravans and homes, associated vehicles plus a storage container are clearly visible from the much used bridleway that runs from Pavenham Road to Radwell. This bridleway is on the highest part of the village and affords views of the church tower and also the church spire in neighbouring Sharnbrook. To the forefront of this view now is this development. The application states that all hedges would be retained. The applicants have already removed a small amount of the hedgerow to the south of the site that faces this bridleway.

It is well documented that on this site were badger setts, newts, bats and a barn owl. The effects of the increased light and noise pollution will be greatly affecting the wildlife and neighbouring community. Felmersham is a quiet village and in the quiet of the evenings the constant noise of generators can be heard for about 300 metres from the site into the village past the Slip. In the other direction where established houses do not block the noise it can be heard for 550 metres. This site is now the brightest area of Pavenham Rd, if not the whole village. As one passes by during the hours of darkness you are struck by the brightness of numerous lit up caravans. This will be more extreme in winter months.

This application is for what would be considered a large development for such a small village. As such, it will negatively affect the character of the village and significantly add to the population. There is very little infrastructure in the village. The Dr surgery in Sharnbrook is stretched already and the only bus stops in the village are a distance from this site and would necessitate walking along the actual road with a 60mph speed limit.

Planning Application Reference: 25/00790/M73A - Formal Objection Proposal: Change of use of agricultural land to a Gypsy and Traveller site, east side of Pavenham Road, Felmersham

I write in objection of the above application. There are numerous reasons for this objection.

Highway Safety and Accessibility Issues
The proposed access is onto Pavenham Road, a narrow, unlit rural road with a 60mph limit, limited visibility, no pavements, and sparse streetlighting. It poses considerable risk for both larger service vehicles and pedestrians, especially during darker months. This location is unsuitable for frequent traffic and raises serious safety concerns.

Flooding and Drainage Concerns
The elevated site naturally drains downhill into the village. During heavy rainfall, Pavenham Road regularly experiences flooding due to poor drainage and some properties even have flood prevention gates/walls installed.

With 3,900m² (27%) of the site proposed for hard surfacing, surface water runoff will increase significantly. No adequate or accurate flood risk assessment or drainage strategy has been submitted, and the Environment Agency has previously objected to the proposed on-site sewage treatment, highlighting the lack of foul drainage provision. The updated foul drainage statement still fails to demonstrate how they could connect to mains sewage and the proposals will see them discharge illegally into ditches they do not own.

Environmental Impact and Damage to Countryside Character
The site lies within open countryside and a designated wildlife corridor supporting badgers, deer, birds, and newts. Its proximity to a nature reserve raises ecological concerns. Preliminary unauthorised work, including land clearance and septic tank installation, has already degraded the landscape and wildlife habitat.
Great Crested Newts have been identified by the parish council's ecologist as living in the nearby nature reserve.

Pollution and Amenity Impact
The introduction of up to 11 mobile homes and 4 touring caravans would increase levels of noise, light, and air pollution in a peaceful rural location. With no buffer or existing development surrounding the site, the change would significantly alter the area's character and affect community wellbeing. There is a significant noise disturbance from the generators working on site that can be heard a large distance from the site. In particular, the site is very visible from the well-used village circular walk along the bridlepath which enjoys views of the church. This appears not to have been considered by the councils heritage officer.

Lack of Sustainable Transport Links
The site is disconnected from essential services and amenities. The lack of safe pedestrian and cycle routes, combined with limited public transport, means all activity would rely on private vehicle use and residents walking along a 60mph road, further increasing local traffic and undermining sustainability principles.

Conflict with the Felmersham and Radwell Neighbourhood Plan (FRNP)
This proposal disregards the 2022 FRNP, which was built on detailed site assessments and inclusive community consultation. The site was not identified for development, is outside the village envelope and does not meet core objectives on infrastructure, housing needs, or design standards.

Inconsistency with the Bedford Borough Local Plan 2030
Although there is under provision for Gypsy and Traveller sites in the Borough, this application fails key location and sustainability tests. The site is not allocated in the Plan, lacks access to services, and does not support inclusive or sustainable development aims. The policy officers response is clear on the contraventions.

Intentional Unauthorised Development
The application follows significant unauthorised activity, including land clearance and construction, which began well in advance of submission. The applicants had ample time to follow due process and chose not to. This disregard for planning protocols should be taken into account during assessment. There are also continued questions as to how safe the septic tanks are that were installed and what impact any discharge has on the water course.

I know that the time window for objections has passed but I noticed recently that this site is floodlit during the night. This use of artificial lighting during the night will affect the bats and their ability to hunt prey. I am sure that had the applicant told their ecological surveyor that the site was to be lit during the hours of darkness then the appropriate advice would have been forthcoming.

There is information on the Bat Conservation Trust and other sites re the problems of artificial lighting and its effects.

Could this be included in the reasons not to allow development.

I wish to object to the building of a caravan site on land to the East of the Pavenham Road for the following reasons
The planning application was well advanced prior to the illegal occupation of the site. Evidenced by the dates on the documents.
There is no ecological survey despite a reference to one undertaken by Arbtec
There is no traffic survey
The application claims there is a high pressure Gas main running across the site. There is no gas in the village. 25+00790+M73A+V10.
There is no mention of electricity supply to the site. A diesel generator has been installed, I am sure the neighbours will find the noise intrusive.
The application specifies the installation of Sewage Treatment Plants however sepic tanks have been installed instead
25+00790+M73A+V08..pdf has been heavily redacted and for that reason I find it difficult to comment on it.
The flood report has ignored the flooding at the lower end of Pavenham Road due to the Ditch overflowing as it passes down the hill through the center of the village to the river.
Will Bedford Borough Council ensure that any sewage entering that Ditch and Brook does not pass through the village. There are many properties which use the brook as a boundary. The Brook is an important habitat rich in invertebrates and deserves preservation.
The copse beside the Pavenham road on the site has an extensive and historic Badger set which is being disturbed.
Flooding at Radwell and Felmersham bridges is not mentioned, these roads are closed regularily due to the River flooding. Pavenham Road then becomes the main route in and out of the Village. An accident or blockage on this route could have serious implication for the emergency services attending the Village.
This site is simply unsuitable for development.
Permission should be refused.

Please find comments under documents tab

As Ward Councillor, I make the following observations, and object the application for the following reasons (but not exhaustive) -
Highway -
the proposed site is on a connecting road between communities, used regularly by various vehicles, at speeds up to the national speed limit; 60mph. The entrance is a typical access to a field, not in regular use, with poor visibility in at least one direction.
Surface water mitigation, and associated flooding -
I do not see sufficient proposals to mitigate surface water issues arising from the proposed development. Furthermore, I consider the density of the proposal to significantly reduce any reasonable opportunity to incorporate appropriate SUD's within the red line boundary. Whilst the "field drain/watercourse" to the rear of the site is empty through dry periods, the contrary is the case in wet weather. This field drain runs to The Slipe, then traverses to the other side of Pavenham Road which is then culverted running down towards the main river in what becomes an open ditch/watercourse at or near to Grange Road. There are already recorded flood issues, occurring in the December 2020 and September 2024 events, arising from surface water issues both on Pavenham Road and Grange Road - high risk to property flooding on Grange Road.
Treatment of sewage -
the applicant made an assumption that cesspits and or "Klargester" equivalent would be used, in the first submission. This option should not be considered, and not employed in any event given the field drain (referred to above) is often dry. I note the Environment Agency object strongly, clearly stating this should not be an option. I note the applicant may be seeking to connect to main sewer - I observe three issues to consider;
1. Capacity in system
2. Topography in relation to gravity flow, and
3. Length of connection - I concede this would be a civil matter.
Site allocation and relevant policies -
The site is outside the settlement policy area. There is no designation in the LP2030, nor the emerging LP2040 and the Neighbourhood Plan makes no provision nor consideration for such.
Ecology and biodiversity -
I rely on others to be specific in details of the impact the proposed development would have on the locality, but I note already several trees and or hedges have been significantly reduced, if only to allow wider and higher clearance/access to the site. With regards to habitat, I note there are records of several habitats on the application site, where there appears to be little or no regard to the indigenous species known to exist.
I endorse the submission made by Felmersham and Radwell Parish Council, which sets out more fully the reasons the Local Planning Authority should refuse the application

I CONURE WITH THE FELMERSHAM PC APPLICATION

I am writing to formally object to the unlawful development and retrospective planning application concerning the change of use of agricultural land to the east side of Felmersham to a Gypsy and Traveller site for the following reasons:

Planning Law and Retrospective Applications
While retrospective applications are legally permissible under the Town and Country Planning Act 1990, paragraph 59 of the National Planning Policy Framework (NPPF) makes clear that planning decisions should promote sustainable development and avoid causing irreversible harm. A change of use of this scale on agricultural land is contrary to policies designed to protect the countryside and manage development appropriately. Notably:
- Policy 7S of the Bedford Borough Local Plan 2030 focuses on sustainable development and restricts inappropriate development in rural areas unless justified by local needs.
- Retrospective nature implies unauthorized development has already occurred, which contravenes principles of orderly planning and public accountability.

Environmental and Ecological Impact
The site is located close to the River Great Ouse, a designated Site of Special Scientific Interest (SSSI) in parts, and is part of the Nene Valley Nature Improvement Area. Any increase in hardstanding and human activity risks:
- Runoff pollution into the river system, especially if foul water infrastructure is inadequate.
- Loss of biodiversity: The site supports local species, such as the great crested newt, that are protected under the Wildlife and Countryside Act 1981.
- The increase in impermeable surfaces can lead to surface water flooding and harm to natural drainage patterns.
The Environment Agency has previously raised objections to developments near watercourses that lack a full and satisfactory Foul Drainage Assessment and Surface Water Management Plan. It is unclear whether these objections have been addressed in full by the applicant.

Impact on Roads and Infrastructure
Felmersham is served by a network of minor rural roads, including narrow lanes unsuitable for high-frequency traffic or larger vehicles. Concerns include:
- Increased traffic volume from 11 mobile homes and 4 touring caravans could place stress on single-track lanes and junctions.
- Risk to road safety for pedestrians, cyclists, and equestrians.
- No clear transport plan has been submitted to demonstrate sustainable connectivity (e.g., walking, cycling, or public transport options), contrary to NPPF para 110-112.

Impact on Character and Appearance of the Area
The proposed site lies in a rural and agricultural setting. The addition of 15 mobile/touring units, parking areas, and hard landscaping is inconsistent with the:
- Open countryside character as identified in the Felmersham and Radwell Neighbourhood Plan (FRNP).
- Policy FR2 of the Neighbourhood Plan, which protects local landscape character and visual amenity, particularly views to and from the Ouse Valley.
The cumulative impact of the development introduces a scale and density of habitation alien to this rural edge.

Strain on Local Amenities and Services
Felmersham and surrounding villages have limited amenities:
- No local GP surgery, limited public transport, and restricted school capacity.
- The nearest secondary services are in Bedford, approximately 7-8 miles away.
- Increased population could exacerbate pressure on schools, healthcare, and waste services, without commensurate investment.
I am naware of supporting evidence from the applicant demonstrating that the local infrastructure can absorb this population increase.
6. Foul Water and Pollution Risk

The development's scale raises serious concerns about foul water management:
- If foul sewage is to be managed via cesspits or septic tanks, proximity to the river means high risk of groundwater and river contamination-especially during heavy rainfall events.
- I am unaware that any clear evidence has been presented that Environment Agency requirements on foul water handling, soakaway performance, and long-term management have been satisfied.

Compliance with Local and Neighbourhood Plans
The Felmersham and Radwell Neighbourhood Plan (2021) includes several relevant policies:
- FR1 - Settlement Boundaries: The proposal lies outside designated boundaries and is not identified for development.
- FR2 - Landscape Character: Emphasises preservation of open countryside; this development undermines this goal.
- FR3 - Design of Development: The proposal conflicts with the traditional scale and rural setting described in the plan.
- FR5 - Infrastructure: Developments should demonstrate that existing infrastructure can support them. No such assurance is given here.
Moreover, Policy 3S of the Bedford Borough Local Plan 2030 requires developments in rural areas to demonstrate both need and sustainability-both seem to be unproven in this case.

Sustainability Concerns
This site is not considered sustainable development under the three pillars of the NPPF:
- Economic: No employment or economic benefit is demonstrated.
- Social: It risks overburdening limited rural amenities.
- Environmental: It threatens biodiversity, river health, and landscape integrity.
A development of this size should have undergone a Sustainability Appraisal, which appears to be missing.

Precedent and Cumulative Impact
Approving this application may set a precedent for similar retrospective applications on greenfield sites across Bedford Borough. It risks undermining:
- Local plans and policy authority.
- Public confidence in planning controls.
- Agricultural land protection, especially in a region where greenfield land is a finite resource.

I am objecting to the above planning application for the following reasons.

Location - situated in open countryside ,the land unsuitable for a change of use for large residential occupation. The look & scale of the site is in grave contrast to what was a peaceful and beautiful rural setting teeming with a variety of wildlife. The site is surrounded by a tall hedge line in places, with mature trees dotted about which does give a level of screening during summer months, but it is still clearly visable and heard from a local bridleway, footpath and road. Once the hedges and trees shed their leaves in autumn there will be barely any screening of this site, it will be a massive eyesore , made even worse by the light pollution once dark.

From first hand knowledge of the field-
- After periods of heavy rain, the field floods at the top end , ankle deep or more in the areas as identified on the flood map - shown in paragraph 8.07 of the flood risk assessment report. In autumn, winter , spring this would happen frequently These same areas were either spongy/boggy/very wet all year round & grew different marshy type grass.
- There were huge ant hills everywhere. In the summer months it was alive and buzzing with crickets and other insects, providing food for the mice, shrews, voles, newts in turn snakes, owls, other birds of prey which I regularly saw hunting here. There were several Badger sets on / adjacent to the land , foxes and deer were often seen. Swallows and bats were also seen feeding on insect life there. With the small spinney and the all year round wet marshy ground at the top end of the field , the environment was varied , unspoilt and would have supported a multitude of flora & fauna. I imagine the damage caused to the flora and fauna already by this development will be immense, and should planning be granted it will become even worse.
- Immediately prior to the development of the site I know there to have been barn owl (s) roosting / potentially nesting in the old shed. If it was a nest I expect it has been abandoned. The huge badger set in the spinney appears to have been recently abandoned as will have other sets in the vicinity given the sudden dramatic increase in noise , light pollution and comings and goings of so many vehicles.



The land is adjacent to a rural de-restricted public highway, outside the village boundary with undulations and bends that can restrict visibility in places.
Dogs have frequently been seen running around uncontrolled close to the site. This is a RTA waiting to happen.
The site has unsuitable access to and from an unlit road , with no footpath raising significant safety issues for road users and residents of alike.


The application states that the development is not within 20 metres of a watercourse, this is incorrect. Water run off and sewage management is a huge concern. There are ditches on 2/4 sides of the land that runs towards the village.
Contrary to the planning application there is a flood risk elsewhere. The ditches overflow and flood onto Pavenham road during and after periods of heavy rain, the frequency of which is increasing. Flooding threatens houses on Pavenham Road /Grange road and The Sun Pub.
The location has no connected services and amenities - Increasing the risk of pollution from sewage , washing machines etc into the ditches
Constant noise from generators is affecting wildlife and is noise pollutant for residents on Pavenham road.
The application states development cannot be seen from public footpaths which is not true. It's clearly visible from the public bridleway running between Pavenham road and Radwell road and from the old cricket pitch in Felmersham.
Any development on this land is harmful to the rural character and appearance of the area. It does not reflect the natural beauty and character of the countryside strategy referenced in the Bedford Local Plan 2030, policies 28S, 29, 37 and 64 together with the Felmersham and Radwell Neighbourhood Plan 2030.

I object to un-authorised groundworks and construction commencing in a military type planned operation, intentionally starting at 7am on Saturday morning so they could not be stopped by Council planning officers and deliberately followed up with retrospective planning application the following Monday. Thus riding roughshod over planning process and consequently destroying the beautiful environment and wildlife in and surrounding it .

This and any other planning application for this land should be absolutely refused.

This is a formal objection to the proposed change of use of the land on the east side of Pavenham Road, Felmersham.
Firstly, this is unlawful and unauthorised development that the landowners have knowingly progressed.
The proposed changes are in contradiction with the Felmersham and Radwell Neighbourhood Plan.
There is an illegal water supply into the site, which will increase pollution and likely negatively impact health through risk of disease.
There is negative impact for wildlife, including deer, bats and especially greater crested newts which have been located in a nature reserve and immediate area surrounding the proposed site.
There is constant light and noise pollution, including from the generators, which are running 24/7.
I have concerns about sewerage waste and rubbish disposal, which will likely impact public health.
Felmersham/ Radwell does not have sufficient local amenities, schools, shops and public services, to support the increase in residents in the village.
There is increased risk of severe flooding to property, particularly on Pavenham Road, due to drainage issues, as well as increased surface area flooding, which will present health and safety issues for existing residents.