Strategic Environmental Assessment for the Felmersham and Radwell Neighbourhood Plan
Environmental Report to accompany the Regulation 14 version of the Neighbourhood Plan
Felmersham and Radwell Neighbourhood Plan Steering Group
May 2020
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
Quality information
Prepared by Checked by Verified by Approved by Ryan Putt Nick Chisholm-Batten Alastair Peattie Alastair Peattie Environmental Associate Director Associate Director Associate Director Consultant
Revision History
Revision Revision date Details Authorized Name Position V2.0 19th May 2020 Updated version. 20th May 2020 Nick Chisholm- Associate Batten Director
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Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
Table of Contents
Non-Technical Summary ......
1. Introduction ...... 1 Background ...... 1 SEA Screening for the Felmersham and Radwell Neighbourhood Plan ...... 1 SEA explained ...... 2 Structure of this SEA Environmental Report ...... 2
2. Local Plan context and vision for the Felmersham and Radwell Neighbourhood Plan ...... 4 Local Plan context for the Neighbourhood Plan ...... 4 Vision, aims and objectives for the Neighbourhood Plan ...... 4
3. What is the scope of the SEA?...... 6 SEA Scoping Report ...... 6 Key Sustainability Issues ...... 6 SEA Framework ...... 10
4. What has plan making / SEA involved up to this point? ...... 14 Introduction...... 14 Overview of plan making / SEA work undertaken since 2015 ...... 14 Housing numbers to deliver through the Neighbourhood Plan ...... 14 Assessment of reasonable alternatives for development strategies...... 15 Current approach in the Neighbourhood Plan and the development of Neighbourhood Plan policies 15
5. What are the appraisal findings at this current stage? ...... 39 Introduction...... 39 Approach to this appraisal...... 39 Air Quality ...... 39 Biodiversity and Geodiversity ...... 39 Climate Change ...... 39 Landscape ...... 40 Historic Environment ...... 42 Land, Soil and Water Resources ...... 42 Population and Community ...... 43 Health and Wellbeing ...... 45 Transportation ...... 45 Conclusions at this current stage ...... 46
6. What are the next steps? ...... 48
Appendix A Context Review and Baseline ...... 49
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
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Non-Technical Summary What is Strategic Environmental Assessment (SEA)? A strategic environmental assessment (SEA) has been undertaken to inform the Felmersham and Radwell Neighbourhood Plan. This process is required by the SEA Regulations.
Neighbourhood Plan groups use SEA to assess Neighbourhood Plans against a set of sustainability objectives developed in consultation with interested parties. The purpose of the assessment is to help avoid adverse environmental and socio-economic effects through the Neighbourhood Plan and identify opportunities to improve the environmental quality of the area covered by the Neighbourhood Plan and the quality of life of residents. What is the Felmersham and Radwell Neighbourhood Plan? The Felmersham and Radwell Neighbourhood Plan is currently being prepared as a Neighbourhood Development Plan under the Localism Act 2011 and the Neighbourhood Planning (General) Regulations 2012. Purpose of this Environmental Report This Environmental Report, which accompanies the Regulation 14 version of the Neighbourhood Plan, is the latest document to be produced as part of the SEA process. The first document was the SEA Scoping Report (February 2020), which includes information about the Neighbourhood Plan area’s environment and community.
The purpose of this Environmental Report is to:
• Identify, describe and evaluate the likely significant effects of the Felmersham and Radwell Neighbourhood Plan and alternatives; and • Provide an opportunity for consultees to offer views on any aspect of the SEA process which has been carried out to date. The Environmental Report contains:
• An outline of the contents and main objectives of the Felmersham and Radwell Neighbourhood Plan and its relationship with other relevant policies, plans and programmes; • Relevant aspects of the current and future state of the environment and key sustainability issues for the area; • The SEA Framework of objectives against which the Felmersham and Radwell Neighbourhood Plan has been assessed; • The appraisal of alternative approaches for the Felmersham and Radwell Neighbourhood Plan; • The likely significant effects of the Felmersham and Radwell Neighbourhood Plan; • The measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects as a result of the Felmersham and Radwell Neighbourhood Plan; and • The next steps for the Felmersham and Radwell Neighbourhood Plan and accompanying SEA process.
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Assessment of reasonable alternatives for the Felmersham and Radwell Neighbourhood Plan Housing numbers to deliver through the Neighbourhood Plan
The Felmersham and Radwell Neighbourhood Plan has been prepared in conjunction with the provisions of the Bedford Local Plan 2030 (adopted in January 2020).
The Local Plan does not provide an indicative number of houses for Felmersham and Radwell parish. However, the Neighbourhood Plan sought to consider the potential for delivering small scale development in the parish providing it is supported by adequate and enhanced local facilities and services to ensure a high quality of life for both current and future residents.
In light of the findings of a local Housing Need Survey completed in February 2017, and the outcomes of community consultation which highlighted a clear preference for development to take place on smaller sites with access to local services (rather than on one large site), the Neighbourhood Plan seeks to allocate 13 homes on multiple sites.
Assessment of reasonable alternatives for site allocations
During the earlier stages of the Neighbourhood Plan’s development, there was a recognition that the Neighbourhood Plan would potentially need to allocate sites for new development. In light of this, a site assessment process was completed between March 2017 and July 2018 by an independent planning consultancy on behalf of Felmersham and Radwell Parish Council. This considered sites which were put forward through the most recent Strategic Housing Land Availability Assessment process undertaken by Bedford Borough Council to support the Local Plan 2030, alongside sites which were identified through a local ‘call for sites’ process. These sites were assessed against a range of criteria relating to suitability, availability and achievability.
Subsequent to this process, seven sites were shortlisted as being appropriate for further consideration as potential allocations for the Neighbourhood Plan due to their ‘deliverability’ and ‘achievability’. All seven sites are located on land which is located adjacent to settlement policy area boundary (SPAB) for Felmersham.
To support the consideration of the suitability of these seven sites for potential allocation in the Neighbourhood Plan, the SEA process has undertaken a separate appraisal of the key environmental constraints present at each of the sites and potential effects that may arise as a result of housing development at these locations. In this context, the sites have been considered in relation to the SEA Framework of objectives and decision-making questions developed during SEA scoping and the baseline information.
The locations of the seven sites assessed through the SEA process are presented in Figure 4.1 within the main body of the Environmental Report. The tables which follow present a summary of this appraisal and provide an indication of each site’s sustainability performance in relation to the eight SEA themes.
It should be noted that, for consistency and fairness, the boundaries of the sites assessed through the SEA process mirror the boundaries of the sites appraised during the site assessment undertaken for the Neighbourhood Plan (and which informed the Issues and Options Consultation stage of the Neighbourhood Plan process). The two separate assessments subsequently provided key evidence to support the Regulation 14 version of the Neighbourhood Plan.
Current approach taken forward through the Neighbourhood Plan
The Regulation 14 version of the Neighbourhood Plan allocates two sites for residential development, specifically:
• Site 6: ‘Land at The Old Road, Felmersham’ (up to six dwellings); and • Site 7: ‘Land at Perch Heights, Carlton Road, Felmersham’ (up to seven dwellings).
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This follows the consideration of the findings of the site assessments undertaken for the Neighbourhood Plan, consultation events, an ongoing consideration of viability and achievability, and the SEA findings (further detailed within the main body of the Environmental Report).
These sites have been allocated in the Neighbourhood Plan in conjunction with the following criteria:
• With reference to the proposed site allocation on ‘Land at The Old Road, Felmersham’ (see Policy FR3 in the Neighbourhood Plan) the following community benefits should form part of the development site: a play area or other sports facility; a new car park for use by the Pinchmill Primary School, the church and the village hall; and suitable pedestrian crossing from the car park to the school. • With reference to the proposed site allocation on ‘Land at Perch Heights, Carlton Road, Felmersham’ (see Policy FR4) the development should provide community benefit through the provision of a new access to the nearby woodland; a significant, valued and popular area of green space which would be retained by the Parish Council and made accessible to the local community (developed to incorporate community managed facilities. The woodland would serve as a local community area containing nature trails; garden, picnic and performance area; and conservation efforts area). Assessment of the Regulation 14 version of the Felmersham and Radwell Neighbourhood Plan The Regulation 14 version of the Felmersham and Radwell Neighbourhood Plan puts forward 13 policies to guide new development within the Neighbourhood Plan area, along with along with 17 non- policy actions to help achieve the vision of the Plan.
Utilising the SEA Framework of objectives and assessment questions developed during the earlier scoping stage of the SEA, the SEA process assessed the policies put forward through the current version of the Felmersham and Radwell Neighbourhood Plan. The Environmental Report has presented the findings of the assessment under the following SEA Themes:
• Biodiversity and Geodiversity; • Climate Change; • Landscape • Historic Environment; • Land, Soil and Water Resources; • Population and Community; • Health and Wellbeing; and • Transportation. The assessment has concluded that the Regulation 14 version of the Neighbourhood Plan is likely to lead to significant positive effects in relation to the ‘Population and Community’ SEA theme. This relates to the focus of the Neighbourhood Plan on safeguarding and enhancing community infrastructure, facilitating the delivery of housing which meets local needs and through encouraging proposals which would seek to enhance the economic and community vitality of the parish. The Neighbourhood Plan will also bring significant positive effects in relation to the ‘Health and Wellbeing’ SEA theme, linked to its promotion of improved and accessible network of footpaths, enhancements to green infrastructure and open space provision to encourage active lifestyles, and the facilitation of public realm improvements.
The Neighbourhood Plan is also likely to lead to positive effects in relation to the ‘Landscape’ and ‘Historic Environment’ SEA themes. These benefits largely relate to the Neighbourhood Plan’s emphasis on protecting and enhancing the special qualities of the parish, supporting the quality of the public realm, and through incorporating high-quality and sensitive design through new development proposals. However, it is important to acknowledge that the proposed site allocations do have the potential to negatively impact on the setting of the Felmersham Conservation Area and nearby
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Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
heritage assets in the absence of sensitive design. In this respect, the Neighbourhood Plan policies provide an appropriate level of protection for the special interest and character of these key assets of historic environment value.
Additionally, the Neighbourhood Plan will bring positive effects in relation to the ‘Biodiversity and Geodiversity’ SEA theme through retaining habitats, enhancing ecological networks and delivering net gains. However, given the approaches taken forward through the Neighbourhood Plan will help limit potential effects from new development areas rather than secure significant enhancements, these impacts are less likely to comprise significant positive effects overall.
Regarding the ‘Climate Change’ SEA theme, the Neighbourhood Plan will potentially lead to positive effects through supporting development proposals in accessible locations within proximity to services and facilities and locating development in areas which have a low flood risk potential. However, this is dependent on the extent to which development proposals incorporate these mitigation and adaptation measures through design. In this respect, it is recommended that the Neighbourhood Plan consider enhancing the wording of Policy FR3 ‘Land at The Old Road, Felmersham’ to include: “proposals should clearly demonstrate how any potential flood risk issues will be appropriately mitigated, including through incorporating sustainable urban drainage systems (SuDS) through design”. This is given the fluvial flood risk concerns in the northern section of the site, along with the proximity to the River Great Ouse.
The Neighbourhood Plan will also initiate several beneficial approaches regarding the ‘Transportation’ SEA theme, given its focus on reducing traffic congestion, providing additional parking through new development, supporting a modal shift towards sustainable transport and by ensuring that new developments provide appropriate access to local services and facilities. However, the scale of development through the proposed site allocations is unlikely to lead to significant increases to the levels of traffic along the key routes passing through the parish.
The Neighbourhood Plan will also initiate several beneficial approaches for the ‘Land, Soil and Water Resources’ SEA themes through the implementation of objectives which seek to limit pollution and improve the environmental quality of the parish. However, the Neighbourhood Plan will facilitate a proportion of new dwellings on greenfield sites which have a greater than 60% likelihood containing ‘best and most versatile’ agricultural land. This has the potential to lead to the permanent loss of productive agricultural land in the Neighbourhood Plan area, which cannot be mitigated. Next steps This Environmental Report accompanies the Felmersham and Radwell Neighbourhood Plan for Regulation 14 consultation.
Following consultation, any representations made will be considered by the Neighbourhood Plan Steering Group, and the Neighbourhood Plan and Environmental Report will be updated as necessary. The updated Environmental Report will then accompany the Neighbourhood Plan for submission to the Local Planning Authority, Bedford Borough Council, for subsequent Independent Examination.
At Independent Examination, the Neighbourhood Plan will be considered in terms of whether it meets the Basic Conditions for Neighbourhood Plans and is in general conformity with local planning policy.
If the Independent Examination is favourable, Felmersham and Radwell Neighbourhood Plan will be subject to a referendum, organised by Bedford Borough Council. If more than 50% of those who vote agree with the Neighbourhood Plan, then it will be ‘made’. Once made, Felmersham and Radwell Neighbourhood Plan will become part of the Development Plan for the parish.
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Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
1. Introduction Background 1.1 AECOM has been commissioned to undertake an independent Strategic Environmental Assessment in support of Felmersham and Radwell’s emerging Neighbourhood Plan.
1.2 The Felmersham and Radwell Neighbourhood Plan is currently being prepared as a Neighbourhood Development Plan under the Localism Act 2011 and the Neighbourhood Planning (General) Regulations 2012. The Neighbourhood Plan is being prepared in the context of the adopted Bedford Borough Local Plan 2030.
1.3 It is anticipated that the Neighbourhood Plan will be submitted to Bedford Borough Council later in 2020.
1.4 Key information relating to the Felmersham and Radwell Neighbourhood Plan is presented in Table 1.1.
Table 1.1: Key facts relating to the Felmersham and Radwell Neighbourhood Plan
Name of Responsible Authority Felmersham and Radwell Parish Council
Title of Plan Felmersham and Radwell Neighbourhood Plan
Subject Neighbourhood planning
Purpose The Felmersham and Radwell Neighbourhood Plan is being prepared as a Neighbourhood Development Plan under the Localism Act 2011 and Neighbourhood Planning (General) Regulations 2012. The plan will be in general conformity with the adopted Bedford Borough Local Plan 2030.
The Felmersham and Radwell Neighbourhood Plan will be used to guide and shape development within the Neighbourhood Plan area.
Timescale To 2030
Area covered by the plan The Felmersham and Radwell Neighbourhood Plan area covers the parish of Felmersham and Radwell in Bedford Borough (Figure 1.1).
Summary of content The Felmersham and Radwell Neighbourhood Plan will set out a vision, strategy and range of policies for the Neighbourhood Plan area.
Plan contact point Trever Roff, Parish Clerk, Felmersham and Radwell Neighbourhood Plan [email protected]
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SEA Screening for the Felmersham and Radwell Neighbourhood Plan
1.5 The Felmersham and Radwell Neighbourhood Plan has been screened in by Bedford Borough Council as requiring a Strategic Environmental Assessment (SEA).
1.6 A Neighbourhood Plan requires SEA where it is likely to have significant environmental effects. In this respect, the Felmersham and Radwell Neighbourhood Plan has been screened in as requiring an SEA. The Neighbourhood Plan will allocate new development in the parish. This includes potentially in environmentally sensitive locations, such as:
• Locations within SSSI impact risk zones for the Felmersham Gravel Pits SSSI; • Locations with sensitivity for the historic environment; and • Locations within sensitivity for landscape character.
1.7 In light of this screening outcome, an SEA process is being undertaken to meet the specific requirements prescribed by the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations). SEA explained 1.8 Strategic Environmental Assessment (SEA) is a mechanism for considering and communicating the impacts of an emerging plan, and potential alternatives in terms of key sustainability issues. The aim of SEA is to inform and influence the plan-making process with a view to avoiding and mitigating negative impacts. Through this approach, the SEA for the Felmersham and Radwell Neighbourhood Plan seeks to maximise the developing plan’s contribution to sustainable development.
1.9 SEA is undertaken to address the procedures prescribed by the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations) which transpose into national law the EU Strategic Environmental Assessment (SEA) Directive1. It also widens the scope of the assessment from focusing on environmental issues to further consider community issues.
1.10 The Felmersham and Radwell Neighbourhood Plan has been screened in by Bedford Borough Council as requiring an SEA. To meet this requirement, the Neighbourhood Plan is undergoing an SEA process which incorporates the requirements of the SEA Directive.
1.11 The SEA will be undertaken to meet specific requirements prescribed by the Environmental Assessment of Plans and Programmes Regulations 2004 (the SEA Regulations).
1.12 Two key procedural requirements of the SEA Regulations are that:
1. When deciding on ‘the scope and level of detail of the information’ which must be included in the Environmental Report there is a consultation with nationally designated authorities concerned with environmental issues; and 2. A report (the ‘Environmental Report’) is published for consultation alongside the Draft Plan (i.e. the Regulation 14 version of the Felmersham and Radwell Neighbourhood Plan) that presents outcomes from the environmental assessment (i.e. discusses ‘likely significant effects’ that would result from plan implementation) and reasonable alternatives.
1 Directive 2001/42/EC
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Structure of this SEA Environmental Report 1.13 This document is the SEA Environmental Report for the Felmersham and Radwell Neighbourhood Plan and hence needs to answer all four of the questions listed below with a view to providing the information required by the SEA Regulations. Each of the four questions is answered in turn within this report, as follows:
Table 1.2: Questions that must be answered by the SEA Environmental Report in order to meet the regulatory2 requirements
In line with the SEA Regulations, the report must Environmental Report question include…3
What is the plan • An outline of the contents and main objectives of the seeking to plan. achieve?
• Relationship with other relevant plans and programmes. What is the • The relevant environmental protection objectives, sustainability established at international or national level. ‘context’? • Any existing environmental problems which are relevant to the plan including those relating to any What’s the areas of a particular environmental importance. scope of the • The relevant aspects of the current state of the SEA? environment and the likely evolution thereof without implementation of the plan. What is the • The environmental characteristics of areas likely to be sustainability significantly affected. ‘baseline’? • Any existing environmental problems which are relevant to the plan including those relating to any areas of a particular environmental importance.
What are the key • Key problems/issues and objectives that should be issues and a focus of (i.e. provide a ‘framework’ for) assessment. objectives?
• Outline reasons for selecting the alternatives dealt with. • The likely significant effects associated with What has plan-making/SEA alternatives. involved up to this point? • Outline reasons for selecting the preferred approach in-light of alternatives appraisal/a description of how environmental objectives and considerations are reflected in the current version of the plan.
• The likely significant effects associated with the Regulation 14 version of the plan. What are the assessment findings • The measures envisaged to prevent, reduce and as at this stage? fully as possible offset any significant adverse effects of implementing the Regulation 14 version of the plan.
What happens next? • The next steps for the plan making / SEA process.
2 Environmental Assessment of Plans and Programmes Regulations 2004 3 NB this column does not quote directly from Schedule II of the Regulations. Rather, it reflects a degree of interpretation.
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2. Local Plan context and vision for the Felmersham and Radwell Neighbourhood Plan Local Plan context for the Neighbourhood Plan 2.1 The Felmersham and Radwell Neighbourhood Plan is being prepared in the context of Bedford Borough Local Plan 20304. The Local Plan 2030 has recently undergone examination and main modifications have been made. The plan was adopted on 15 January 2020. Neighbourhood plans will form part of the development plan for the borough, alongside, but not as a replacement for the Local Plan. The Local Plan seeks to give communities a solid framework within which appropriate community-led planning policy documents, including neighbourhood plans, can be brought forward. Neighbourhood plans are required to be in general conformity with the strategic policies of the Local Plan and can develop policies and proposals to address local place-based issues. In this way it is intended for the Local Plan to provide a clear overall strategic direction for development in Bedford, whilst enabling finer detail to be determined through the neighbourhood planning process where appropriate.
2.2 Within the Local Plan, Felmersham is identified as a settlement which has a Settlement Policy Area. Settlement Policy Areas are defined for villages with a built up-character. The Settlement Policy Area boundary encloses the main built-up part of the village but excludes subordinate built-up areas that are detached from the main built-up area, more loosely knit development associated with the village or undeveloped areas surrounding the village. Policy 5S ‘Development in villages with a Settlement Policy Area’ states that within Settlement Policy Area boundaries, development or redevelopment will be acceptable in principle provided that it is consistent with the other policies of the development plan.
2.3 Radwell is identified as a Small Settlement within the Local Plan. Small Settlements are settlements that do not have a defined Settlement Policy Area but nevertheless do have a definite built form. Small Settlements comprise a distinct group of buildings and their immediate surroundings that include 30 or more dwellings. Policy 6 ‘Development in Small Settlements’ states that within the built form of Small Settlements development will be supported where the proposal contributes positively to the character of the settlement and is appropriate to the structure, form, character and size of the settlement as a whole.
2.4 The Local Plan does not provide an indicative number of houses for Felmersham and Radwell parish. Vision, aims and objectives for the Neighbourhood Plan 2.5 The vision for the Neighbourhood Plan captures the community’s views and aspirations for the parish over the next 10 years as expressed through the consultation process. It therefore forms the basis on which the neighbourhood objectives and proposed policies have been formulated.
4 Bedford Borough Council (2020): ‘Bedford Borough Local Plan 2030’ [online] available at: < https://bbcdevwebfiles.blob.core.windows.net/webfiles/Planning%20and%20Building/local-plan- 2030/APPENDIX%20D%20Local%20Plan%202030%20showing%20main%20and%20additional%20modifications.pdf> [accessed 06/01/2020]
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To value, protect and promote the unique parish of Felmersham and Radwell, by respecting its heritage, appreciating its current community and being aspirational when planning its future.
Vision Statement for the Felmersham and Radwell Neighbourhood Plan
2.6 The vision is underpinned by the following five core objectives that seek to make a positive contribution to sustainable growth within the parish:
• Housing: plan the development of a range of good quality housing which meets the current and identified future needs of our community;
• Our Infrastructure: encouraging safe and sustainable movement for pedestrians, cyclists, motorists and public transport, and to plan infrastructure provision (including communications infrastructure) to meet current and future needs;
• Environment and Heritage: protecting and enhancing our existing and future open spaces and supporting our distinctive landscape which contributes to a sense of place and community, including natural features such as small woodlands, in-field trees, hedgerows, ponds and streams which distinguish the parish, preserving the significance of listed buildings and non-designated heritage assets as well as the special interest of the conservation area;
• Our community: ensuring that the village benefits from sufficient facilities, amenities and services for all members of the community; and
• Business and Employment: identifying development opportunities to provide further employment growth within the village whilst safeguarding existing businesses for the benefit of the community.
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3. What is the scope of the SEA? SEA Scoping Report 3.1 The SEA Regulations require that: “When deciding on the scope and level of detail of the information that must be included in the report, the responsible authority shall consult the consultation bodies”. In England, the consultation bodies are Natural England, the Environment Agency and Historic England.5 These authorities were consulted on the scope of the Felmersham and Radwell Neighbourhood Plan SEA for a period of five weeks, between February 2020 and March 2020.
3.2 The purpose of scoping was to outline the ‘scope’ of the SEA through setting out:
• A context review of the key environmental and sustainability objectives of national, regional and local plans and strategies relevant to the Neighbourhood Plan;
• Baseline data against which the Neighbourhood Plan can be assessed;
• The key sustainability issues for the Neighbourhood Plan; and
• An ‘SEA Framework’ of objectives against which the Neighbourhood Plan can be assessed.
3.3 Responses received on the Scoping Report, and how they were addressed, have been summarised below.
Table 3.1: Consultation responses received on the SEA Scoping Report
Consultation response How the response was considered and addressed Natural England Jacqui Salt, Consultation Service Team (email response received on 10th March 2020) Odell Great Wood SSSI and Stevington Marsh Comment noted. Potential impacts to SSSI should be scoped into the assessments nationally designated sites are further within the biodiversity and geodiversity section: explored through the consideration of please refer to Natural England’s Impact Risk reasonable alternatives (Chapter 4) and the Zones on MAGIC. plan appraisal (Chapter 5 of this Report).
We refer you to the advice in the attached annex Comment noted. The recommended which covers the issues and opportunities that guidance and advice have provided an should be considered when preparing a essential reference point during the SEA Neighbourhood Plan. process.
Environment Agency Neville Benn, Senior Planning Advisor (email response received on 11th February 2020) We have no comment to make on this SEA. Comment noted. I do not recollect being consulted on the SEA Screening Opinion for this Neighbourhood Plan and have not come across many that have concluded an SEA is required.
5 In-line with Article 6(3).of the SEA Directive, these consultation bodies were selected because ‘by reason of their specific environmental responsibilities,[they] are likely to be concerned by the environmental effects of implementing plans and programme’.’
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Consultation response How the response was considered and addressed
Looking over the Issues and Options Comment noted. consultation Oct 2018 I can see all proposed sites are within Flood Zone 1 (lowest probability of flooding) on our Flood Map. Therefore, we consider that any matters within our remit can be left to the planning application stage.
The Parish and potential developers may be Comment noted. The planning guidance interested in the attached planning guidance. has provided a useful source of reference during the SEA process.
Historic England Edward James, Historic Places Adviser (email response received on 5th March 2020) We would refer you to the guidance in Historic Comment noted. The recommended England Advice Note 8: Sustainability Appraisal guidance and advice have provided an and Strategic Environmental Assessment, which essential reference point during the SEA can be found here: process.
In addition, we note that the information from the Comment noted. The Norfolk Historic Bedford HER has been obtained via the Heritage Environment Record has provided an Gateway. Heritage Gateway is not regularly essential reference point during the SEA updated, unlike the local Historic Environment process. Record, and is therefore an inappropriate source of information for the purposes of an SEA exercise. The final SEA Report should obtain data directly from the HER. As this is to support the production of a neighbourhood plan, it may be free of charge.
We also note the lack of conservation area Potential impacts to nationally and locally appraisal. We therefore recommend that the designated and non-designated heritage assessment is supported by a proportionate HIA assets (and their settings) has been further that incorporates a character assessment of the explored through the consideration of area in question, in order to define and clarify the reasonable alternatives and site allocations special architectural and historic interest of the (Chapter 4 of the Environmental Report). conservation area. This then provides an appropriate baseline against which to assess the Potential impacts resulting from the site impact of any changes. allocations have been further discussed during the plan appraisal (Chapter 5 of the Environmental Report), alongside policy commitments aiming to protect and enhance the heritage assets and features within the parish.
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Consultation response How the response was considered and addressed
Historic England strongly advises that the Comment noted. Consultees are invited to conservation and archaeological staff of the comment on the Neighbourhood Plan and relevant local planning authorities are closely the supporting evidence base (including the involved throughout the preparation of the plan SEA) during Regulation 14 consultation. and its assessment. They are best placed to advise on; local historic environment issues and priorities, including access to data held in the Historic Environment Record (HER), which should be consulted as part of the SEA process. In addition, they will be able to advise how any site allocation, policy or proposal can be tailored to minimise potential adverse impacts on the historic environment; the nature and design of any required mitigation measures; and opportunities for securing wider benefits for the future conservation and management of heritage assets.
To avoid any doubt, this does not reflect our Comment noted. Further advice and obligation to provide further advice on later guidance is welcomed. stages of the SEA process and, potentially, object to specific proposals which may subsequently arise (either as a result of this consultation or in later versions of the plan/guidance) where we consider that, despite the SEA, these would have an adverse effect upon the environment.
Key Sustainability Issues Air Quality • No air quality issues have been identified in the Neighbourhood Plan area, and future issues are not anticipated. • Due to the absence of any significant air quality issues within the Neighbourhood Plan area, the air quality theme has been scoped out for the purposes of the SEA process. Biodiversity and Geodiversity • The nearest European designated sites are the Upper Nene Valley Gravel Pits Ramsar and SPA which are approximately 11km north west of the Neighbourhood Plan area. • Felmersham Gravel Pits SSSI lies just outside of the Neighbourhood Plan area. • There are numerous Biodiversity Action Plan priority habitats present in the Neighbourhood Plan area. Climate Change • Any increases in the built footprint of the Neighbourhood Plan area (associated with the delivery of new housing and employment land) has the potential to increase overall greenhouse gas emissions in the parish. • Bedford has had lower per capita emissions in comparison to the East of England and England as a whole since 2005. • Bedford has seen a 33.3% reduction in the percentage of total emissions per capita between 2005 and 2016, the same as the reductions for the East of England (33.3%) but lower than the reductions for England (37.6%).
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• The effects of climate change, based on medium emission scenarios, will see an estimated increase in annual mean temperatures of between 2ºC and 3ºC during the period 2040-2059 compared to the period 1981-2000 in East England. • The estimated change in annual mean precipitation is +20 to +30% in winter and -10% to - 20% in summer, during the period 2040-2059 compared to the period 1981-2000 in East England. • There are significant areas which are at high risk of fluvial flooding (Flood Zone 3) in the Neighbourhood Plan area from the River Great Ouse. • Within the 2010 SFRA, Felmersham and Radwell are identified as built up areas which have some risk of flooding. • There are areas within the Neighbourhood Plan area (predominantly located around River Great Ouse and its tributaries) which are at medium-high risk of surface water flooding. • The Felmersham and Radwell Neighbourhood Plan should seek to increase the resilience of the Neighbourhood Plan area to the effects of climate change by supporting and encouraging adaptation strategies. Landscape • The Neighbourhood Plan area lies within Bedfordshire and Cambridgeshire Claylands NCA. • The Neighbourhood Plan area lies within two landscape character areas which are identified in the Bedford Borough Landscape Character Assessment: Pavenham Wooded Wolds and Oakley – Great Ouse Limestone Valley. • The potential effects of development proposed through the Felmersham and Radwell Neighbourhood Plan may have implications for the overall character and appearance of Felmersham and Radwell in the future. Historic Environment • The Neighbourhood Plan area contains one Grade I and 23 Grade II nationally designated listed buildings which are protected through the Listed Buildings and Conservation Areas Act 1990. • A conservation area is present within the Neighbourhood Plan area, which covers part of the built-up area of Felmersham; however, a conservation appraisal or management plan has not yet been prepared. • Bedfordshire Historic Environment Record records prehistoric/Romano British enclosure cropmarks and Iron Age/Romano cemeteries and settlements within Felmersham. Land, Soil and Water Resources • There is a lack of evidence to ascertain agricultural land quality within much of the Neighbourhood Plan area. National provisional quality datasets indicate that the majority of land within the Neighbourhood Plan area is Grade 3. There is therefore the potential for loss of high quality (‘best and most versatile’) agricultural land. • The Neighbourhood Plan area lies within a Nitrate Vulnerable Zone. • Within the Neighbourhood Plan area, the centre and western corner are located within SPZ3 (Total Catchment). • The Ouse (Newport Pagnell to Roxton) has an overall water quality classification as ‘moderate’. Population and Community • The population of Felmersham increased by 1.5% between 2001 and 2011, lower than the increases for Bedford, the East of England and England averages. • Generally, there are a higher proportion of residents within the 60+ age category within the Neighbourhood Plan area (26.9%) in comparison to the total for Bedford (21.7%), the East of England (23.9%) and England (22.3%). • The proportion of residents with the 60+ age category is likely to continue to increase.
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• The Neighbourhood Plan area contains one LSOA which is within the 40% least deprived areas within England. • A higher proportion of residents own their home outright or with a mortgage in the Neighbourhood Plan area in comparison to the regional and national trends. • The Neighbourhood Plan area has a range of local community facilities, clubs and organisations which serve the needs of the local community and play a vital role in supporting the Parish’s sense of identity. Health and Wellbeing • The 2016 public health profile for Bedford outlines that the health of people in Bedford is varied compared with the England average. About 17% (5,500) of children live in low income families. • 87.6% of residents in the Neighbourhood Plan area consider themselves as having ‘very good health’ or ‘good health’, greater than the totals for Bedford (82.9%), the East of England (82.5%) and England (81.4%). • A lower number of residents within the Neighbourhood Plan area report that their activities are limited in some way compared to regional and national averages. Transportation • There are no railway stations within the Neighbourhood Plan area. Bedford railway station lies approximately 7.9km south east of the Neighbourhood Plan area which provides services from London St Pancras to the East Midlands. • The Neighbourhood Plan area is well linked to the surrounding road network, with access to the A6 and a network of country roads. • Residents have access to a network of footpaths within the Neighbourhood Plan area. • New development taken forward through recent Local Plan allocations has the potential increase traffic and congestion issues in the Neighbourhood Plan area. SEA Framework 3.4 Baseline information (including the context review and baseline data) is presented in Appendix A. The SEA Framework is presented below.
SEA Objective Assessment questions Biodiversity and Geodiversity Protect and enhance Will the option/proposal help to: biodiversity and geodiversity • Support the status of the nationally and locally designated sites within and within proximity to the Neighbourhood Plan area including the Felmersham Gravel Pits SSSI?
• Achieve a net gain in biodiversity? • Support enhancements to multifunctional green infrastructure networks? • Support access to, interpretation and understanding of biodiversity and geodiversity?
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Climate change Reduce the contribution Will the option/proposal help to: to climate change made by activities within the • Reduce the number of journeys made? Neighbourhood Plan area • Reduce the need to travel? • Promote the use of sustainable modes of transport, including walking, cycling and public transport?
• Increase the number of new developments meeting or exceeding sustainable design criteria?
• Generate energy from low or zero carbon sources? • Reduce energy consumption from non-renewable resources?
Support the resilience of Will the option/proposal help to: the Neighbourhood Plan area to the potential • Ensure that inappropriate development does not take place in areas at effects of climate change, higher risk of flooding, taking into account the likely future effects of climate including flooding change? • Improve and extend green infrastructure networks in the plan area to support adaptation to the potential effects of climate change?
• Sustainably manage water run-off, reducing surface water runoff (either within the plan area or downstream)?
• Ensure the potential risks associated with climate change are considered through new development in the Neighbourhood Plan area? • Increase the resilience of biodiversity in the area to the effects of climate change, including through enhancements to ecological networks? Landscape Protect and enhance the Will the option/proposal help to: character and quality of • Conserve and enhance locally important landscape and villagescapes landscapes and features within the Neighbourhood Plan area? villagescapes • Conserve and enhance local diversity and character? • Will development be undertaken in conjunction with the development guidelines identified in the Bedford Borough Landscape Character Assessment for the relevant landscape character areas? Historic Environment Protect, conserve and Will the option/proposal help to: enhance heritage assets • Conserve and enhance the significance of buildings and structures of within the Neighbourhood architectural or historic interest, both designated and non-designated, and Plan area their setting? • Conserve and enhance the special interest, character and appearance of locally important features and their settings? • Support the integrity of the historic setting of key buildings of cultural heritage interest as listed on the Bedfordshire HER? • Support access to, interpretation and understanding of the historic evolution and character of the environment? • Conserve and enhance archaeological remains, including historic landscapes? • Support the undertaking of archaeological investigations and, where appropriate, recommend mitigation strategies?
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Land, Soil and Water Resources Ensure the efficient and Will the option/proposal help to: effective use of land. • Promote the use of previously developed land? • Avoid the development of the best and most versatile agricultural land, which in the parish may comprise Grade 2 and 3a agricultural land? • Protect the integrity of mineral safeguarding areas?
Promote sustainable Will the option/proposal help to: waste management solutions that encourage • Reduce the amount of waste produced? the reduction, re-use and • Support the minimisation, reuse and recycling of waste? recycling of waste. • Maximise opportunities for local management of waste in order to minimise export of waste to areas outside? • Encourage recycling of materials and minimise consumption of resources during construction?
Use and manage water Will the option/proposal help to: resources in a sustainable manner. • Support improvements to water quality? • Minimise water consumption? • Protect surface water resources? • Protect groundwater resources? Population and Community Cater for existing and Will the option/proposal help to: future residents’ needs as well as the needs of • Encourage and promote social cohesion and encourage active involvement different groups in the of local people in community activities? community, and improve • Minimise fuel poverty? access to local, high- quality community • Maintain or enhance the quality of life of existing local residents? services and facilities. • Improve the availability and accessibility of key local facilities, including specialist services for disabled and older people? Reduce deprivation and promote a more inclusive • Support the provision of land for allotments and cemeteries? and self-contained community. Provide everyone with Will the option/proposal help to: the opportunity to live in good quality, affordable • Support the provision of a range of house types and sizes? housing, and ensure an • Support enhancements to the current housing stock? appropriate mix of dwelling sizes, types and • Meet the needs of all sectors of the community? tenures. • Provide quality and flexible homes that meet people’s needs? • Promote the use of sustainable building techniques, including use of sustainable building materials in construction? • Provide housing in sustainable locations that allow easy access to a range of local services and facilities?
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Health and Wellbeing Improve the health and Will the option/proposal help to: wellbeing of residents within the Neighbourhood • Promote accessibility to a range of leisure, health and community facilities, Plan area. for all age groups? • Provide and enhance the provision of community access to green infrastructure, in accordance with Accessible Natural Greenspace Standards?
• Promote the use of healthier modes of travel? • Improve access to the countryside for recreational use? • Avoiding any negative impacts to the quality and extent of existing recreational assets, such as formal or informal footpaths? Transportation Promote sustainable Will the option/proposal help to: transport use and reduce the need to travel. • Encourage modal shift to more sustainable forms of travel? • Facilitate working from home and remote working?
• Improve road safety? • Reduce the impact on residents from the road network?
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4. What has plan making / SEA involved up to this point? Introduction
4.1 The ‘narrative’ of plan-making / SEA up to this point is told within this part of the Environmental Report.
4.2 A key element of the SEA process is the appraisal of ‘reasonable alternatives’ for the Felmersham and Radwell Neighbourhood Plan. The SEA Regulations6 are not prescriptive as to what constitutes a reasonable alternative, stating only that the Environmental Report should present an appraisal of the ‘plan and reasonable alternatives taking into account the objectives and geographical scope of the plan’
4.3 In accordance with the SEA Regulations the Environmental Report must include…
• An outline of the reasons for selecting the alternatives dealt with; and
• The likely significant effects on the environment associated with alternatives / an outline of the reasons for selecting the preferred approach in light of alternatives appraised.
4.4 The following sections therefore describe how the SEA process to date has informed the preferred development strategy for the Neighbourhood Plan area and potential locations for development. Specifically, this chapter explains how the Felmersham and Radwell Neighbourhood Plan’s development strategy has been shaped through considering alternative approaches for the location of housing in the Neighbourhood Plan area. Overview of plan making / SEA work undertaken since 2015 4.5 The Neighbourhood Plan has been prepared by Felmersham and Radwell Parish Council, who appointed an administrator and set up a Steering Group. Within the Steering Group, working groups reported into the process and contributed to policy themes.
4.6 The Steering Group has consulted with the community, landowners, local businesses and organisations on a wide range of issues that will influence the well-being, sustainability and long term preservation of the local community. A Community Engagement Strategy was adopted by the Parish Council in March 2016 to help guide this process. Consultation methods have included:
• Gaining feedback from launch days and open days;
• Completing surveys and questionnaires with residents, gathering views and opinions;
• Regular meetings with the Steering Group to discuss key themes and issues; and
• Updates provided on the Neighbourhood Plan website.
4.7 Additionally, the Steering Group undertook an issues and options consultation event with members of the local community in Autumn 2018. Further details are provided in the consultation statement accompanying the Neighbourhood Plan. Housing numbers to deliver through the Neighbourhood Plan 4.8 As discussed within Chapter 2, the Felmersham and Radwell Neighbourhood Plan has been prepared in conjunction with the provisions of the Bedford Local Plan 2030 (adopted in January 2020).
6 Environmental Assessment of Plans and Programmes Regulations 2004
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Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
4.9 The Local Plan does not provide an indicative number of houses for Felmersham and Radwell parish. However, Policy 5S ‘Development in villages with a Settlement Policy Area’ states that within Settlement Policy Area boundaries (which includes Felmersham), development or redevelopment will be acceptable in principle providing it is consistent with the other policies of the development plan. Policy 6 ‘Development in Small Settlements’ goes on to state that within the built form of Small Settlements (which includes Radwell) development will be supported where the proposal contributes positively to the character of the settlement and is appropriate to its structure, form, character and size.
4.10 As per the provisions of Policy 58S in the Local Plan, affordable housing will be required on sites of ten or more residential units or on sites which exceed 0.5 hectares. This is due to the significant need for affordable housing in the borough and the fact that the Local Plan makes no allocations for villages or small settlements.
4.11 However, viability work undertaken to support the Neighbourhood Plan confirmed that in general terms, there is no barrier in viability terms to the provision of affordable housing. In this respect, the Neighbourhood Plan sought to consider the potential for delivering small scale development in the parish providing it is supported by adequate and enhanced local facilities and services to ensure a high quality of life for both current and future residents.
4.12 Providing the context for the delivery of new housing in the parish during the plan period, the following overview is presented in the current version of the Neighbourhood Plan:
“The community has expressed a very strong view that new development should be on a needs basis and should be limited in scale, in order to respect the character of the village and level of infrastructure provision in the village. In terms of establishing local need, a Housing Needs Survey (HNS) was undertaken for Felmersham and Radwell in February 2017 by Bedfordshire Rural Communities Charity (BRCC) which identified a local need for properties of various types, sizes and tenures in the period to 2035. The HNS identified (i) a small need for affordable rented and shared ownership housing for local people in, or with strong links to, the Parish), which is unlikely to be met by normal market provision (5 units) and (ii) a need for 2-3 bedroom market houses and bungalows or otherwise suitable properties (e.g. houses built to Lifetime Homes criteria), if Felmersham and Radwell is to meet the identified current and future needs of existing owner occupier residents wishing to stay in the village (14 units).”
4.13 In light of the findings of the HNS, and the outcomes of community consultation which highlighted a clear preference for development to take place on smaller sites with access to local services (rather than on one large site), the Neighbourhood Plan seeks to allocate 13 homes on multiple sites. The proposed allocation of land for 13 homes recognises that the HNS covered the period to 2035, rather than the shorter plan period to 2030.
4.14 In response to this, the Felmersham and Radwell Neighbourhood Plan Steering Group were keen to consider where in the parish new housing could be delivered through the Neighbourhood Plan to meet this requirement. Assessment of reasonable alternatives for site allocations Neighbourhood Plan site assessment and initial shortlisting of sites
4.15 A site assessment process was completed between March 2017 and July 2018 by an independent planning consultancy on behalf of Felmersham and Radwell Parish Council. This considered sites which were put forward through the most recent SHLAA process7 undertaken by Bedford Borough Council to support the Local Plan 2030, alongside sites which were identified through a local ‘call for sites’ process.
4.16 To support the consideration of the suitability of the shortlisted sites for a potential allocation of a type appropriate for the Neighbourhood Plan (i.e. small scale sites), the site assessment process appraised the key constraints and opportunities present at each of the relevant sites.
7 Bedford Borough Council (2020): ‘Call for Sites Submissions’, [online] available to access via:
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These sites were assessed against a range of criteria relating to suitability, availability and achievability, with a ‘traffic light’ rating given based on whether the site is an appropriate candidate to be considered for allocation in the Neighbourhood Plan. In this respect:
• ‘Green’ was given to sites free from constraints, or which have constraints that can be resolved, and therefore are suitable for development. Sites rated green are therefore considered appropriate to take forward for considering as allocations for the Neighbourhood Plan (providing they are viable).
• ‘Amber’ sites have constraints that would need to be resolved or mitigated and therefore, these sites are potentially appropriate to take forward for the purposes of the Neighbourhood Plan (providing they are viable).
• ‘Red’ sites are those which have significant constraints and are therefore unsuitable for development. These sites are not considered appropriate to take forward for the purposes of the Neighbourhood Plan.
4.17 The sites included in the assessment (along with their ratings) are outlined below in Table 4.1.
Table 4.1: Sites identified through the ‘call for sites’ process and the SHLAA8
Site Name / address of site Location Size (Ha) RAG Site taken forward Assessment (adjacent to or Score for reasonable Reference within) alternatives? 108 Town Lot Lane Felmersham 0.14 Amber Yes 109 Land at Radwell Road Felmersham 2.36 Red No 110 Land at Harrowdene Farm Felmersham 0.36 Red No 111 Land at Memorial Lane Felmersham 0.30 Green Yes 112 Land at Thursdays Farm Radwell 0.25 Red No 433 Land at Thursdays Farm In between 0.75 Red No Felmersham and Radwell 442 Land at Thursdays Farm Radwell 0.30 Red No 466 Land at Town Lot Lane Felmersham 0.83 Amber Yes 474/689 Land south west of Pavenham Felmersham 1.01 Amber Yes Road 475 The Leys Pavenham Road Felmersham 2.63 Red No 494 Old Road Felmersham 2.50 Amber Yes 528 Radwell Lake To the east of 133.00 N/A No Radwell 602 Land at The Old Road Felmersham 4.10 Green Yes 810 Land at Harrowdene Farm Felmersham 0.60 Red No (includes part of Site 110) Perch Heights Perch Heights, Carlton Road Felmersham 1.34 Green Yes
Assessment of shortlisted sites through the SEA process 4.18 Subsequent to this process, seven sites were shortlisted as being appropriate for further consideration as potential allocations for the Neighbourhood Plan due to their ‘deliverability’ and ‘achievability’. All seven sites are located on land which is located adjacent to the Settlement Policy Area Boundary (SPAB) for the village of Felmersham.
8 Bedford Borough Council (2020): ‘Potential Development Sites: Felmersham and Radwell’, [online] available to access via:
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4.19 To support the consideration of the suitability of these seven sites for potential allocation in the Neighbourhood Plan, the SEA process has undertaken a separate appraisal of the key environmental constraints present at each of the sites and potential effects that may arise as a result of housing development at these locations. In this context, the sites have been considered in relation to the SEA Framework of objectives and decision-making questions developed during SEA scoping (Chapter 3) and the baseline information.
Table 4.2: Sites taken forward as reasonable alternatives
SEA Name of site, address Size (Ha) Potential site capacities9 Site ID. 1 Town Lot Lane 0.14 Up to six dwellings 2 Land at Memorial Lane 0.30 Up to six dwellings 3 Land at Town Lot Lane 0.83 Up to 25 dwellings 4 Land south west of Pavenham Road 1.01 Up to 20 dwellings 5 Old Road 2.50 Up to 30 dwellings 6 Land at The Old Road 4.10 Up to six dwellings 7 Perch Heights, Carlton Road 1.34 Up to seven dwellings
4.20 This appraisal has been undertaken by AECOM as an independent and objective desk-based assessment, with reference to the following principal sources of information: MAGIC Interactive Map; UK Government Flood Maps for Planning; Bedford Borough Council’s Landscape Character Assessment10, Bedford Borough Council’s Interactive Planning Maps11 (layers correct as of October 2018), Ordnance Survey mapping (accessed online using Bing Maps); and Natural England’s Regional Agricultural Land Classification Mapping12 (including the likelihood of ‘best and most versatile’ mapping)13.
4.21 It should be noted that, for consistency and fairness, the boundaries of the sites assessed through the SEA process mirror the boundaries of the sites appraised during the site assessment undertaken for the Neighbourhood Plan (and which informed the Issues and Options Consultation stage of the Neighbourhood Plan process). The two separate assessments subsequently provided key evidence to support the Regulation 14 version of the Neighbourhood Plan.
4.22 The locations of the seven sites assessed through the SEA process are presented in Figure 4.1 below. The tables which follow present a summary of this appraisal and provide an indication of each site’s sustainability performance in relation to the eight SEA themes.
9 Capacities have been taken from the site assessment report completed by an independent planning consultancy on behalf of Felmersham and Radwell Parish Council. 10 Bedford Borough Council (2014): ‘Landscape Character Assessment’, [online] available to access via:
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Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA site assessment findings Table 4.3: Site 1
SEA theme Commentary, Site 1: Town Lot Lane
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals Biodiversity and likely to come forward at this location are unlikely to exceed the IRZ thresholds Geodiversity for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural England is unlikely to be required. At the local level, there are no Biodiversity Action Plan (BAP) Priority Habitats present on site. The trees located along the site boundaries should be retained and enhanced (where possible) through development proposals.
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). In terms of flooding, the whole of the site is within Flood Zone 1 and has a low risk of fluvial flooding. The whole of the site also has a very low surface water Climate Change flood risk potential. However, there are areas of Town Lot Lane (directly to the north east of the site) that have a low surface water flood risk potential. Additionally, there is a corridor of land located approximately 50m to the west of the site that contains areas of low to medium surface water flood risk potential. As such, any increases in the levels of hardstanding within the site boundaries has the potential to increase the surface water run-off to surrounding areas, exacerbating the existing flood risk issues at these locations. This should be appropriately mitigated through the design of any development proposals.
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SEA theme Commentary, Site 1: Town Lot Lane
Felmersham and Radwell is not within or within proximity to a National Park or an Area of Outstanding Natural Beauty (AONB) and does not contain any Green Belt land. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within landscape character area (LCA) 2B ‘Pavenham Wooded Wold’. Strategic sensitivities to the LCA include: the loss of hedgerows; the strong network of rural roads and lanes which are vulnerable to increases in traffic and resurfacing techniques; infill development and spread along roads; loss of tranquillity from village Landscape expansion and increased use of roads. Given the size of the site and the scale of proposals likely to come forward at this location, new development areas are unlikely to have any significant adverse impacts to local landscape character. However, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along Town Lot Lane. There are no Tree Preservation Orders (TPOs), either individual or areas, located within or adjacent to the site.
There are no nationally designated heritage assets located within the site boundary. However, the Grade II listed ‘Wills Farmhouse’ is located immediately to the north west of the site, with some views possible from the site. Therefore, an allocation at this location has the potential to impact upon the fabric and setting of this nationally designated heritage asset in the Historic absence of sensitive design. Land located directly to the north of the site is Environment within the boundaries of the Felmersham Conservation Area, and the site itself is within an area of archaeological interest as shown on Bedford Borough Council’s interactive map. At the local level, it is currently not possible to determine whether any features on the Bedford Borough Historic Environment Record (HER) are located within or within proximity to the site.
The undeveloped areas of the site have a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for agricultural purposes. This broadly aligns with the national dataset provided by Natural England which indicates that the site is underlain by Grade 3 (good to moderate quality) agricultural land. Land, Soil and Currently used for storage, there are a few buildings located within the site Water Resources boundaries. Redevelopment at these locations will promote the efficient use of land and potentially remediate areas of contaminated land. Focusing new development at these locations would help to safeguard any areas of best and most versatile agricultural land from harm. In terms of the water environment, there are no watercourses located within or within proximity to the site.
Located adjacent to the existing settlement policy area boundary (SPAB) for Population and Felmersham, the site provides relatively good connectivity and accessibility to Community services and facilities within the village centre. An allocation at this location will contribute positively towards meeting local needs.
The nearest GP Surgery is located approximately 1.5km to the north of the Health and site in the neighbouring settlement of Sharnbrook. The site is within proximity Wellbeing to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
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SEA theme Commentary, Site 1: Town Lot Lane
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. Transportation Town Tot Lane is a no through road, of single lane width and poorly surfaced. Pedestrian access into the village centre would be possible via footpaths located along Grange Road and The High Road. The local bus network is accessible in the village centre, with two stops located along The High Road. Key
Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Table 4.4: Site 2
SEA theme Commentary, Site 2: Land at Memorial Lane
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals Biodiversity and likely to come forward at this location are unlikely to exceed the IRZ thresholds Geodiversity for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural England is unlikely to be required. At the local level, there are no BAP Priority Habitats present on site. However, the trees and vegetation located alongside the site boundaries should be retained and enhanced (where possible) through development proposals.
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SEA theme Commentary, Site 2: Land at Memorial Lane
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the Climate Change services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). In terms of flooding, the whole of the site is within Flood Zone 1 and has a low risk of fluvial flooding. The whole of the site also has a very low surface water flood risk potential.
Felmersham and Radwell is not within or within proximity to a National Park or an AONB and does not contain any Green Belt land. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within LCA 3A ‘Harrold - Great Ouse Limestone Valleys’. Strategic sensitivities to the LCA include: the nucleated villages with historic cores; significant sites and structures which contribute to landscape character, such as churches and Felmersham Tithe Barn; the minor roads and bridges over the Great Ouse which reinforce the rural character; and views of church spires located on the lower valley sides. Landscape Given the size of the site and the scale of proposals likely to come forward at this location, new development areas are unlikely to have any adverse impacts to local landscape character. However, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along Memorial Lane There are no TPOs, either individual or areas, located within or adjacent to the site.
There are no nationally designated heritage assets located within the site boundary. However, there are two Grade II listed buildings located approximately 50m to the north and north east of the site, namely: ‘College Farmhouse’ and ‘The Manor’. Whilst the vegetation along the northern site boundary is likely to provide some screening, these nationally designated heritage assets are likely to have some visibility from the site at some locations. Historic The western half of the site is within the boundaries of the Felmersham Environment Conservation Area. Land located directly to the north and north east of the site is also within the boundaries of the Conservation Area. Therefore, an allocation at this location has the potential to directly impact upon the special character and setting of the Conservation Area in the absence on sensitive design. Additionally, the whole site is within an area of archaeological interest as shown on Bedford Borough Council’s interactive map. At the local level, it is currently not possible to determine whether any features on the Bedford Borough HER are located within or within proximity to the site.
The undeveloped areas of the site have a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for agricultural purposes. This broadly aligns with the national dataset provided by Natural England which indicates that the site is underlain by Grade 3 (good Land, Soil and to moderate quality) agricultural land. Water Resources Redevelopment of the existing buildings on site would promote the most efficient use of land. Focusing new development at these locations would help to safeguard any areas of best and most versatile agricultural land from harm. In terms of the water environment, there are no watercourses located within or within proximity to the site.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 22
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 2: Land at Memorial Lane
Located adjacent to the existing SPAB for Felmersham, the site provides Population and relatively good connectivity and accessibility to services and facilities within Community the village centre. An allocation at this location will contribute positively towards meeting local needs.
The nearest GP Surgery is located approximately 1.5km to the north of the Health and site in the neighbouring settlement of Sharnbrook. The site is within proximity Wellbeing to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. There is an existing gated entrance into the eastern section of the site via a Transportation turning from Memorial Lane. Whilst the road is relatively narrow and there are no footpaths, the road is currently well used by existing residents as a route into the village centre, with residents able to follow a footpath along Church End. The local bus network is accessible in the village centre, with two stops located along The High Road. Key
Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 23
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
Table 4.5: Site 3
SEA theme Commentary, Site 3: Land at Town Lot Lane
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals likely to come forward at this location are unlikely to exceed the IRZ thresholds Biodiversity and for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural Geodiversity England is unlikely to be required. At the local level, there are no BAP Priority Habitats present on site. However, the existing vegetation and hedgerows located along the southern and western site boundaries should be retained and enhanced (where possible) through development proposals.
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). In terms of flooding, the whole of the site is within Flood Zone 1 and has a low Climate Change risk of fluvial flooding. The whole of the site also has a very low surface water flood risk potential. However, there are some areas of land along Pavenham Road (adjacent to the existing site access point) which have a medium to high surface water flood risk potential. As such, any increases in the levels of hardstanding within the site boundaries has the potential to increase the surface water flood run-off to surrounding areas, exacerbating the existing flood risk issues at these locations. This should be appropriately mitigated through the design of any development proposals.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 24
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 3: Land at Town Lot Lane
Felmersham and Radwell is not within or within proximity to a National Park or an AONB and does not contain any Green Belt land. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within LCA 2B ‘Pavenham Wooded Wold’. Strategic sensitivities to the LCA include: the loss of hedgerows; the strong network of rural roads and lanes which are vulnerable to increases in traffic and resurfacing techniques; infill development and spread along roads; loss of tranquillity from village expansion and increased use of roads. Landscape Development of the whole site would extend the built edge of the village out into open countryside which may have negative landscape character impacts. Suitable landscaping and design could provide mitigation. However, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along Pavenham Road, and from the gardens of some properties located along Grange Road. There are no TPOs, either individual or areas, located within or adjacent to the site.
There are no nationally designated heritage assets located within the site boundary. However, the Grade II listed ‘The Cottage’ is located approximately 50m to the south east of the site. Whilst the vegetation located along the southern site boundary and surrounding the listed building itself provides a level of visual screening, ‘The Cottage’ is potentially visible from within the site boundaries at some locations. The site is not within or adjacent to the Felmersham Conservation Area. The Historic Conservation Area itself is located approximately 200m to the north of the site. Environment The site is not likely to be visible from the Conservation Area given the screening provided by properties located along Grange Road and Town Lot Lane. A small area of land in the eastern section of the site (overlapping with the existing entrance off Pavenham Road) is within an area of archaeological interest as shown on Bedford Borough Council’s interactive map. Land to the east and south of the site is also within the area of archaeological interest. At the local level, it is currently not possible to determine whether any features on the Bedford Borough HER are located within or within proximity to the site.
The site is an area of greenfield land which has a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for Land, Soil and agricultural purposes. This broadly aligns with the national dataset provided Water Resources by Natural England which indicates that the site is underlain by Grade 3 (good to moderate quality) agricultural land. In terms of the water environment, there are no watercourses located within or within proximity to the site.
Located adjacent to the existing SPAB for Felmersham, the site provides Population and relatively good connectivity and accessibility to services and facilities within Community the village centre. An allocation at this location will contribute positively towards meeting local needs.
The nearest GP Surgery is located approximately 1.5km to the north of the Health and site in the neighbouring settlement of Sharnbrook. The site is within proximity Wellbeing to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 25
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 3: Land at Town Lot Lane
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. Access could be taken from Pavenham Road, as the track leading to Pastures Transportation Farm is sufficiently wide. Although there are no footpaths located along Pavenham Road, pedestrian access into the village centre would be possible via footpaths located along Grange Road and The High Road. The local bus network is accessible in the village centre, with two stops located along The High Road. Key Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Table 4.6: Site 4
SEA theme Commentary, Site 4: Land south west of Pavenham Road
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals likely to come forward at this location are unlikely to exceed the IRZ thresholds Biodiversity and for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural Geodiversity England is unlikely to be required. At the local level, there are no BAP Priority Habitats present on site. However, the existing vegetation and hedgerows located along the western site boundary should be retained and enhanced (where possible) through development proposals.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 26
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 4: Land south west of Pavenham Road
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). In terms of flooding, the whole of the site is within Flood Zone 1 and has a low Climate Change risk of fluvial flooding. The whole of the site also has a very low surface water flood risk potential. However, there are areas of land located approximately 25m to the north east of the site that have a medium to high surface water flood risk potential. As such, any increases in the levels of hardstanding within the site boundaries has the potential to increase the surface water flood run- off to surrounding areas, exacerbating the existing flood risk issues at these locations. This should be appropriately mitigated through the design of any development proposals.
Felmersham and Radwell is not within or within proximity to a National Park or an AONB and does not contain any Green Belt land. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within LCA 2B ‘Pavenham Wooded Wold’. Strategic sensitivities to the LCA include: the loss of hedgerows; the strong network of rural roads and lanes which are vulnerable to increases in traffic and resurfacing techniques; infill development and spread along roads; loss of tranquillity from village expansion and increased use of roads. Landscape Development of the whole site would extend the built edge of the village out into open countryside which may have negative landscape character impacts. Suitable landscaping and design could provide mitigation. However, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along Pavenham Road, and from the gardens of some properties located along Grange Road. There are no TPOs, either individual or areas, located within or adjacent to the site.
The site does not contain and is not within proximity to a nationally designated heritage asset. Additionally, the site is not within or adjacent to the Felmersham Conservation Area. The Conservation Area itself is located approximately 100m to the north of the site. The site is not likely to be visible from the Conservation Area given the screening provided by properties Historic located along Grange Road and Town Lot Lane. Environment The western half of the site is within an area of archaeological interest as shown on Bedford Borough Council’s interactive map. Land directly to the east and north west of the site is also within the area of archaeological interest. At the local level, it is currently not possible to determine whether any features on the Bedford Borough HER are located within or within proximity to the site.
The site is an area of greenfield land that has a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for Land, Soil and agricultural purposes. This broadly aligns with the national dataset provided Water Resources by Natural England which indicates that the site is underlain by Grade 3 (good to moderate quality) agricultural land. In terms of the water environment, there are no watercourses located within or within proximity to the site.
Located adjacent to the existing SPAB for Felmersham, the site provides Population and relatively good connectivity and accessibility to services and facilities within Community the village centre. An allocation at this location will contribute positively towards meeting local needs.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 27
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 4: Land south west of Pavenham Road
The nearest GP Surgery is located approximately 1.5km to the north of the Health and site in the neighbouring settlement of Sharnbrook. The site is within proximity Wellbeing to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. Access could be taken from Pavenham Road, as the track leading to Pastures Transportation Farm is sufficiently wide. However, the access would pass through the neighbouring field located to the south of the site. Although there are no footpaths located along Pavenham Road, pedestrian access into the village centre would be possible via footpaths located along Grange Road and The High Road. The local bus network is accessible in the village centre, with two stops located along The High Road. Key
Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Table 4.7: Site 5
SEA theme Commentary, Site 5: Old Road
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals likely to come forward at this location are unlikely to exceed the IRZ thresholds Biodiversity and for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural Geodiversity England is unlikely to be required. At the local level, there are no BAP Priority Habitats present on site. However, the existing trees and vegetation located along the northern site boundary should be retained and enhanced (where possible) through development proposals.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 28
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 5: Old Road
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). In terms of flooding, the whole of the site is within Flood Zone 1 and has a low Climate Change risk of fluvial flooding. Most of the site also has a very low surface water flood risk potential. However, there are areas of land in the northern section of the site (adjacent to the properties along The Old Road) which have a low to medium surface water flood risk potential. As such, any increases in the levels of hardstanding within the site boundaries has the potential to exacerbate the existing flood risk issues at these locations. This should be appropriately mitigated through the design of any development proposals.
Felmersham and Radwell is not within or within proximity to a National Park or an AONB and does not contain any Green Belt land. Development at this location would extend the built edge of the village out into open countryside which may have negative landscape character impacts, but suitable landscaping and design could provide mitigation. However, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within LCA 3A ‘Harrold - Great Landscape Ouse Limestone Valleys’. Strategic sensitivities to the LCA include: the nucleated villages with historic cores; significant sites and structures which contribute to landscape character, such as churches and Felmersham Tithe Barn; the minor roads and bridges over the Great Ouse which reinforce the rural character; and views of church spires located on the lower valley sides. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along The Old Road and Memorial Lane, and from Pinchmill Primary School, Village Hall and Play Area. There are no TPOs, either individual or areas, located within or adjacent to the site.
There are no nationally designated heritage assets located within the site boundary. However, the Grade II listed ‘The Manor’ is located approximately 50m to the north west of the site. This nationally designated heritage feature is unlikely to be visible from within the site boundaries due to the visual screening provided by existing trees and buildings along Memorial Lane and The Old Road, which surround ‘The Manor’. The Felmersham Conservation Area is located approximately 25m to the west Historic of the site (at its nearest point). Some views into the Conservation Area are Environment possible from within the site boundaries given the relatively flat topography and openness of the landscape between the site and the village. Nonetheless, the vegetation located along the north western boundary likely provides some visual screening. At the local level, land located directly to the west and north west of the site is within an area of archaeological interest as shown on Bedford Borough Council’s interactive map. It is currently not possible to determine whether any features on the Bedford Borough HER are located within or within proximity to the site.
The site is an area of greenfield land that has a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for Land, Soil and agricultural purposes. This broadly aligns with the national dataset provided Water Resources by Natural England which indicates that the site is underlain by Grade 3 (good to moderate quality) agricultural land. In terms of the water environment, there are no watercourses located within or within proximity to the site.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 29
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 5: Old Road
Located adjacent to the existing SPAB for Felmersham, the site provides Population and relatively good connectivity and accessibility to services and facilities within Community the village centre (including Pinchmill Primary School). An allocation at this location will contribute positively towards meeting local needs.
The northern section of the land, fronting Old Road, includes the Pinchmill Play Area. Development at this location would therefore result in the loss of a Health and locally important community asset. Wellbeing The nearest GP Surgery is located approximately 1.5km to the north of the site in the neighbouring settlement of Sharnbrook. The site is within proximity to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. Access into the northern section of the site could potentially be established via The Old Road. However, this would impact upon the Pinchmill Play Area. Transportation There is also a potential to establish access into the western section of the site via Memorial Lane. Whilst Old Road and Memorial Lane are both narrow and there are no footpaths, the roads are currently well used by existing residents being in a central location and close to the school. The local bus network is accessible in the village centre, with two stops located along The High Road. Key
Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 30
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
Table 4.8: Site 6
SEA theme Commentary, Site 6: Land at The Old Road
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals likely to come forward at this location are unlikely to exceed the IRZ thresholds Biodiversity and for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural Geodiversity England is unlikely to be required. At the local level, there are no BAP Priority Habitats present on site. However, the existing corridor of trees located in the northern section of the site and the hedgerows and vegetation located along the eastern, southern and western site boundaries should be retained and enhanced (where possible) through development proposals.
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). Climate Change In terms of flooding, the site is mostly located within Flood Zone 1 and has a low risk from fluvial flooding. The site also has a low to very low surface water flood risk potential. However, there is a corridor of land in the northern section of the site (adjacent to the River Great Ouse) which is in Flood Zone 2 and 3. This corridor of land overlaps with an existing area of trees, which provide a natural flood defence barrier. These features should therefore be retained and incorporated into the design of any new development areas.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 31
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 6: Land at The Old Road
Felmersham and Radwell is not within or within proximity to a National Park or an AONB and does not contain any Green Belt land. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within LCA 3A ‘Harrold - Great Ouse Limestone Valleys’. Strategic sensitivities to the LCA include: the nucleated villages with historic cores; significant sites and structures which contribute to landscape character, such as churches and Felmersham Tithe Barn; the minor roads and bridges over the Great Ouse which reinforce the rural character; and views of church spires located on the lower valley sides. Landscape Development of the whole site would extend the built edge of the village out into open countryside which may have negative landscape character impacts. Suitable landscaping and design could provide mitigation. However, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along The Old Road and from Pinchmill Primary School, Village Hall and Play Area. There are no TPOs, either individual or areas, located within or adjacent to the site.
There are no nationally designated heritage assets located within the site boundary. However, the Grade II listed building, ‘The Manor’, is located approximately 25m to the south west of the site. The existing vegetation and buildings along The Old Road are likely to provide some visual screening. Nonetheless, this nationally designated heritage asset is potentially visible from within the site boundaries at some locations. Historic A small section of land in the south western section of the site is within an area Environment of archaeological interest as shown on Bedford Borough Council’s interactive map. The Felmersham Conservation Area is located directly to the south west of the site. Therefore, it is important to acknowledge that development in these locations has the potential to negatively impact on the setting of the Felmersham Conservation Area in the absence of sensitive design. At the local level, it is currently not possible to determine whether any features on the Bedford Borough HER are located within or within proximity to the site.
The site is an area of greenfield land that has a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for agricultural purposes. This broadly aligns with the national dataset provided by Natural England which indicates that the site is underlain by Grade 3 (good to moderate quality) agricultural land. Land, Soil and In terms of the water environment, the River Great Ouse is located directly to Water Resources the north of the site, albeit screened from a corridor of trees. This area of trees should be retained through development proposals to minimise the risk of excessive surface water entering the watercourses. Sustainable drainage systems (including SuDS) should also be incorporated into the design of any proposals to help limit suspended solids entering watercourses from surface water run-off.
Located adjacent to the existing SPAB for Felmersham, the site provides Population and relatively good connectivity and accessibility to services and facilities within Community the village centre (including Pinchmill Primary School). An allocation at this location will contribute positively towards meeting local needs.
The nearest GP Surgery is located approximately 1.5km to the north of the Health and site in the neighbouring settlement of Sharnbrook. The site is within proximity Wellbeing to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 32
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 6: Land at The Old Road
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. Transportation The Old Road is a narrow land with no footpaths. However, the site is within 50m from a footpath along Church End, providing pedestrian access into the village centre. The local bus network is accessible in the village centre, with two stops located along The High Road. Key
Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Table 4.9: Site 7
SEA theme Commentary, Site 7: Perch Heights, Carlton Road
There are no European or nationally designated sites for biodiversity within the site. Although the site does overlap with SSSI IRZs for residential, rural residential and rural non-residential development types, the scale of proposals likely to come forward at this location are unlikely to exceed the IRZ thresholds Biodiversity and for the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural Geodiversity England is unlikely to be required. At the local level, there is an existing wooded area on site which should be retained and enhanced (where possible) through development proposals. This will indirectly benefit the area of deciduous woodland BAP priority habitat located directly to the west and north west of the site, through ‘buffering’ any impacts to this ecologically valued area from development.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 33
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 7: Perch Heights, Carlton Road
Development of the site will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the village and an intensification of uses at this location. The site is in good proximity to the services and facilities in the village centre, helping to limit the need to travel to local facilities (and associated greenhouse gas emissions). In terms of flooding, the site is wholly located within Flood Zone 1 and has a Climate Change low risk from fluvial flooding. The site also has a low to very low surface water flood risk potential. However, there are areas of land located along Hunts Lane and Grange Road (approximately 25m to the east of the site) which have a medium to high surface water flood risk potential. As such, any increases in the levels of hardstanding within the site boundaries has the potential to increase the surface water flood run-off to surrounding areas, exacerbating the existing flood risk issues at these locations. This should be appropriately mitigated through the design of any development proposals.
Felmersham and Radwell is not within or within proximity to a National Park or an AONB and does not contain any Green Belt land. Completed in 2014, the results of Bedford Borough’s Landscape Character Assessment confirm that the site is located within LCA 2B ‘Pavenham Wooded Wold’. Strategic sensitivities to the LCA include: the loss of hedgerows; the strong network of rural roads and lanes which are vulnerable to increases in traffic and resurfacing techniques; infill development and spread along roads; loss of tranquillity from village expansion and increased use of roads. An allocation at this location would extend the village to the west. However, Landscape the scale of proposals likely to come forward at this location are unlikely to have any adverse impacts to local landscape character, particularly if the existing vegetation within the site boundaries is retained through proposals. Nonetheless, due to the greenfield nature of the site, there is a potential for minor impacts to local landscape character depending on the design and layout of the proposals. From a visual perspective, there are likely to be some direct views into the site from neighbouring properties located along Carlton Road and Grange Road. The site does not contain any TPOs. However, there is a TPO area located directly to the north east of the site (reference: 01/1967), on the other side of Carlton Road.
There are no nationally designated heritage assets located within the site boundary. However, the Grade II listed ‘The Old Farmhouse’ is adjacent to the south eastern corner of the site, with some views of the heritage asset possible from within the site boundaries. There are a further three Grade II listed buildings located approximately 50m to the north east and south east of the site, namely: ‘West Grange’, ‘East Grange’ and ‘Six Ringers Inn’. However, these heritage assets are not visible from the site due to the screening provided by existing buildings and vegetation located along Carlton Road and Historic Grange Road. Environment The Felmersham Conservation Area lies to the east and adjoins the site boundary in part. As such, new development has the potential to negatively impact on the setting of the Felmersham Conservation Area and nearby heritage assets in the absence of sensitive design. At the local level, a corridor of land within the eastern section of the site is located within an area of archaeological interest, as shown on Bedford Borough Council’s interactive map. It is currently not possible to determine whether any features on the Bedford Borough HER are located within or within proximity to the site.
Prepared for: Felmersham and Radwell Neighbourhood Plan Steering Group AECOM 34
Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
SEA theme Commentary, Site 7: Perch Heights, Carlton Road
The undeveloped areas of the site have a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for agricultural purposes. This broadly aligns with the national dataset provided by Natural England which indicates that the site is underlain by Grade 3 (good to moderate quality) agricultural land. Land, Soil and Water Resources The site is partly residential and comprises one dwelling. Redevelopment of these areas will promote the most efficient use of land. Focusing new development at these locations would help to safeguard any areas of best and most versatile agricultural land from harm. In terms of the water environment, there are no watercourses located within or within proximity to the site.
Located adjacent to the existing SPAB for Felmersham, the site provides Population and relatively good connectivity and accessibility to services and facilities within Community the village centre. An allocation at this location will contribute positively towards meeting local needs.
The nearest GP Surgery is located approximately 1.5km to the north of the Health and site in the neighbouring settlement of Sharnbrook. The site is within proximity Wellbeing to local footpaths alongside the River Great Ouse, and there are walking trails around Felmersham Gravel Pits Nature Reserve.
The site is located at relative proximity to services and facilities in Felmersham village centre which will limit the need for residents to travel for some day-to- day services and facilities. A single access to the existing residential dwelling exists on Carlton Road. Transportation Whilst there is no pedestrian connectivity into the village centre along Hunts Lane, the site is approximately 150m from a footpath located along Grange Road which provides pedestrian connectivity into the village centre. The local bus network is accessible in the village centre, with two stops located along The High Road. Key
Likely adverse effect (without mitigation Likely positive effect measures)
Neutral/no effect Uncertain effect
Table 4.10: Summary of SEA site appraisal findings
Biodiversity Land, Soil Population and Climate Historic and Water and Health and Site Geodiversity Change Landscape Env. Resources Community Wellbeing Transport
Site 1 Site 2 Site 3 Site 4 Site 5 Site 6 Site 7
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Strategic Environmental Assessment for the Environmental Report to accompany the Felmersham and Radwell Neighbourhood Plan Regulation 14 version of the Neighbourhood Plan
Current approach in the Neighbourhood Plan and the development of Neighbourhood Plan policies Choice of sites taken forward for the purposes of the Neighbourhood Plan 4.23 Following the consideration of the findings of the site assessments undertaken for the Neighbourhood Plan, consultation events, an ongoing consideration of viability and achievability, and the SEA findings presented above, the Neighbourhood Plan Steering Group identified three preferred sites for allocation: Site 2 ‘Land at Memorial Lane, Felmersham’, Site 6 ‘Land at The Old Road, Felmersham’ and Site 7 ‘Land at Perch Heights, Carlton Road, Felmersham’.
4.24 Subsequent to the site assessment process, the Neighbourhood Plan Steering Group received notification that one of the preferred sites for allocation, Site 2 ‘Land at Memorial Lane’, was no longer available for consideration. As such, the Neighbourhood Plan seeks to deliver the housing target of 13 dwellings across the remaining two preferred site allocations, as follows:
• Site 6: ‘Land at The Old Road, Felmersham’ (up to six dwellings); and
• Site 7: ‘Land at Perch Heights, Carlton Road, Felmersham’ (up to seven dwellings).
4.25 These sites have been allocated in the Neighbourhood Plan in conjunction with the following criteria:
• With reference to the proposed site allocation on ‘Land at The Old Road, Felmersham’ (see Policy FR3 in the Neighbourhood Plan) the following community benefits should form part of the development site: a play area or other sports facility; a new car park for use by the Pinchmill Primary School, the church and the village hall; and suitable pedestrian crossing from the car park to the school.
• With reference to the proposed site allocation on ‘Land at Perch Heights, Carlton Road, Felmersham’ (see Policy FR4) the development should provide community benefit through the provision of a new access to the nearby woodland; a significant, valued and popular area of green space which would be retained by the Parish Council and made accessible to the local community (developed to incorporate community managed facilities. The woodland would serve as a local community area containing nature trails; garden, picnic and performance area; and conservation efforts area).
4.26 The Neighbourhood Plan Steering Group also recognised that the sites both have the potential to negatively impact the historic environment, given their location adjacent to the Felmersham Conservation Area and proximity to designated heritage assets. Therefore, the Neighbourhood Plan policies seek to ensure that the design of proposals respects the character and appearance of these heritage designations, whilst also enhancing the fabric and setting of these assets. This is further discussed in the appraisal of the draft plan (see Chapter 5). Neighbourhood Plan policies 4.27 To support the implementation of the vision statement for the Neighbourhood Plan, the Regulation 14 version of the Felmersham and Radwell Neighbourhood Plan puts forward 13 policies to guide new development within the Neighbourhood Plan area, along with along with 17 non-policy actions (NPA) to help achieve the vision of the Plan.
4.28 These were developed following extensive community consultation and evidence gathering and are listed in Table 4.11 below.
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Table 4.11: Neighbourhood Plan policies and non-policy actions
Reference Policy Name / Non-Policy Action Summary Housing Policy FR1 General Development Principles Policy FR2 Local Housing Need Policy FR3 Land at The Old Road, Felmersham Policy FR4 Perch Heights, Carlton Road, Felmersham Policy FR5 Development Design Criteria Infrastructure Policy FR6 Transportation Policy FR7 Residential Parking in New Developments Policy FR8 Creating a Sustainable Community Environment and Heritage Policy FR9 Protection of Heritage Assets Community Facilities Policy FR10 Protection of Village Facilities Policy FR11 Provision of New Community Facilities Policy FR12 Next Generation Broadband Business and Employment Policy FR13 Supporting Small Businesses Non-Policy Actions The Parish Council recognise the need to alleviate the pressure from limited "off- NPA1 street" parking provision in Felmersham and Radwell. The Parish Council will work with the Highway Authority to improve the awareness NPA2 of local traffic and road safety issues. The Parish Council will work with the Highway Authority to assess the cost/benefits NPA3 of traffic calming measures and seek to secure measures to reduce speed and improve local safety. The Parish Council will work with the Highway Authority to introduce, in appropriate NPA4 locations, the introduction of white lines along the side of roads to mark recommended places for pedestrians and cyclists. The Parish Council will work together with the Highway Authority and other NPA5 relevant agencies to develop a long term sustainable strategy for improvements to the existing highway network. The Parish Council will work to create more formal and informal green spaces in NPA6 the village and to ensure the better landscaping of public areas. The Parish Council will identify areas of land for new tree planting in the parish and NPA7 promote and implement a tree planting scheme for the area. The Parish Council will seek to encourage the protection of locally designated and NPA8 non-designated wildlife sites/areas and habitats and will support the development of wildlife corridors.
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Reference Policy Name / Non-Policy Action Summary The Parish Council will expect new developments to demonstrate connectivity to NPA9 the existing Public Rights of Way network and to provide new footpaths and cycle paths (where appropriate). The Parish Council will work with Bedford Borough Council to develop improved NPA10 linkages for Public Rights of Way connecting to neighbouring parishes in order to support and enhance health and wellbeing. The Parish Council will work with Bedford Borough Council to promote and NPA11 enhance the existing network of Parish Walks through signage and environmental improvements to improve accessibility for all. The Parish Council will work with Bedford Borough Council, Historic England, the NPA12 local community and other appropriate interested parties to explore and develop a Local List of historically important buildings for Felmersham and Radwell. Local facilities and services will be protected and supported by the Parish Council NPA13 that seek to ensure the continued viability of the rural economy and that endeavour to support the sustainability of local services. The Parish Council will support well considered investment proposals to enable NPA14 Pinchmill Primary School to realise its ambition and provide educational excellence for young people in the village and the immediate locality. The Parish Council will work with the Church Authorities and local landowners to NPA15 identify suitable land for additional cemetery provision to meet the future needs of the community. The provision of new or enhanced recreational facilities in the Parish will be NPA16 supported, provided that the design and scale are in keeping with local character and there are no adverse impacts to residential amenity. The Parish Council will continue to promote the use of Felmersham Village Hall NPA17 and support appropriate plans to improve community provision. The Parish Council will also support and promote other existing clubs and facilities in the area.
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5. What are the appraisal findings at this current stage? Introduction 5.1 The aim of this chapter is to present appraisal findings and recommendations in relation to the Regulation 14 consultation version of the Felmersham and Radwell Neighbourhood Plan. This chapter presents:
• An appraisal of the current version of the Neighbourhood Plan under the eight SEA theme headings; and
• The overall conclusions at this current stage and recommendations for the next stage of plan-making. Approach to this appraisal 5.2 The appraisal is structured under the eight themes taken forward for the purposes of the SEA.
5.3 For each theme, ‘significant effects’ of the current version of the plan on the baseline are predicted and evaluated. Account is taken of the criteria presented within Schedule 2 of the Regulations. So, for example, account is taken of the probability, duration, frequency and reversibility of effects as far as possible. These effect ‘characteristics’ are described within the assessment as appropriate.
5.4 Every effort is made to identify / evaluate effects accurately; however, this is inherently challenging given the high-level nature of the plan. The ability to predict effects accurately is also limited by understanding of the baseline and the nature of future planning applications. Because of the uncertainties involved, there is a need to exercise caution when identifying and evaluating significant effects and ensure all assumptions are explained. In many instances it is not possible to predict significant effects, but it is possible to comment on merits (or otherwise) in more general terms. Biodiversity and Geodiversity 5.5 The nearest European designated sites, the ‘Upper Nene Valley Gravel Pits’ Ramsar and Special Protection Area (SPA) are located approximately 11km to the north west of the Neighbourhood Plan area, at their nearest points. The Felmersham Gravel Pits Site of Special Scientific Interest (SSSI) is located approximately 250m to the north of the parish and the Harold Odell Country Park Local Nature Reserve (LNR) is adjacent to the western boundary of the parish, containing habitats and species listed in the annexes of both the European Habitats Directive (92/43/EEC) and the European Birds Directive (79/409/EEC). Furthermore, there are areas of BAP Priority Habitats located within and adjacent to the Neighbourhood Plan area, primarily areas of deciduous woodland. Whilst no significant negative effects on biodiversity can be readily identified, there will be a need for potential effects on biodiversity linked to future development in the Neighbourhood Plan area to be avoided and mitigated.
5.6 Whilst the proposed site allocations through Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Land at Perch Heights, Carlton Road, Felmersham’ overlap within SSSI IRZs for the type of development likely to come forward at these locations, the quantum of development proposed (totalling 13 dwellings) does not exceed the IRZ thresholds associated with the Felmersham Gravel Pits SSSI. Therefore, consultation with Natural England will unlikely be required prior to development. Given the Neighbourhood Plan aligns with the provisions of the adopted Bedford Local Plan 2030 in terms of housing numbers, no additional effects are anticipated in relation to the integrity of the European or nationally designated sites located within or within proximity to Felmersham and Radwell.
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5.7 Several Neighbourhood Plan policies will 1) help limit potential effects from new development on features and areas of biodiversity interest and 2) support the resilience of ecological networks. For example, Policy FR1 ‘General Development Principles’ outlines a presumption in favour of sustainable development in the settlement boundary. From an ecological perspective, proposals should ensure that the following design criteria listed in the policy are met:
• Landscaping and boundary treatments should use native species and, where practical and possible, retain mature trees. Where this is not possible, non-native species which are beneficial for wildlife will be acceptable alternatives (objective C); and
• Existing local habitats and wildlife corridors should be protected and enhanced, with new ones created where practical and possible (objective E).
5.8 In terms of the allocations taken forward through the Neighbourhood Plan, Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Perch Heights, Carlton Road, Felmersham’ are supported providing that the design and layout respects and enhances the natural environment. Additionally, the proposed site allocation through Policy FR4 shall be encouraged to retain the existing wooded area on site. This will indirectly benefit the area of deciduous woodland BAP priority habitat located directly to the west of the site, through ‘buffering’ any impacts to this ecologically valued area.
5.9 Published in June 2019, paragraph 170 (d) within the revised NPPF14 states that planning policies and decisions should contribute to and enhance the natural and local environment by ‘minimising impacts on and providing net gains for biodiversity, including by establishing coherent ecological networks’, with paragraph 32 outlining that spatial development strategies should demonstrate how opportunities for net gains have been addressed. An environmental net gain principle for development is also embedded within the goals and policies of the UK Government’s 25-Year Environment Plan15 which was published in January 2018. In this regard, non-priority action 7 (NPA7) indicates that the Parish Council will identify areas of land for new tree planting in the parish and promote and implement a tree planting scheme for the area. Similarly, NPA8 suggests that the Parish Council will seek to encourage the protection of locally designated and non-designated wildlife sites/areas and habitats, supporting the development of wildlife corridors and the extension of green spaces and new nature conservation sites wherever possible.
5.10 Further supporting ecological networks, Policy FR5 ‘Development Design Criteria’ stipulates that proposals should incorporate high quality green infrastructure to improve links, together with protecting and enhancing wildlife habitats (objective F). This will support the integrity of protected species by maintaining corridors and connectivity within and between habitats. Climate Change 5.11 Several policies within the Neighbourhood Plan emphasise the importance of mitigating and adapting to the climate crisis, seeking to embed environmentally sustainable practices in response to the challenges faced.
5.12 In terms of climate change mitigation, road transport is an increasingly significant contributor to greenhouse gas emissions in the Neighbourhood Plan area. Based on the 2011 Census data, the most regularly used method of travelling to work in the parish is via driving, with 96.3% of households having access to at least one car or van. This is higher than the regional and national averages. In this respect, active travel within the Neighbourhood Plan area is supported through the provisions of Policy FR6 ‘Transportation’ which affirms that proposals should provide connections to existing footpaths to enable residents to walk to village amenities. Similarly, NPA9-11 indicate that the Parish Council will work with key stakeholder groups to extend the public right of way network within Felmersham and Radwell. This will encourage a limitation of emissions though protecting and enhancing local walking and cycle
14 MHCLG (2018): ‘Revised National Planning Policy Framework’, [online] available to access via:
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routes in the parish. These aspects are further discussed within the appraisal presented under the ‘Transportation’ theme.
5.13 Policy FR1 ‘General Development Principles’ outlines a presumption in favour of sustainable development within the defined settlement boundary. The proposed site allocations through Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Perch Heights, Carlton Road, Felmersham’ are located adjacent to the settlement boundary, within walking distance to services and facilities in the village centre. This will help limit the need to travel to local amenities within the village centre (and associated greenhouse gas emissions), positively contributing to climate change mitigation efforts. However, it is important to acknowledge that development at these locations will lead to inevitable increases in greenhouse gas emissions from an increase in the built footprint of the parish.
5.14 In relation to adapting to the effects of climate change, the proposed site allocations are mostly located within Flood Zone 1 and have a low risk from fluvial flooding. Both sites also have a low to very low surface water flood risk potential. However, there is a corridor of land in the northern section of the proposed site allocation through Policy FR3 (adjacent to the River Great Ouse) which is in Flood Zone 2 and 3. This corridor of land overlaps with an existing area of trees, which provide a natural flood defence barrier. Given the size of the site, these features could therefore be retained and incorporated into the design of the development. It is also anticipated that the provisions of the NPPF will also help to ensure that developments are located way from the areas at highest risk of flooding.
5.15 Additionally, protecting and enhancing open spaces and habitats within the Neighbourhood Plan area through Policy FR10 ‘Protection of Village Facilities’, NPA7 and NPA8, will safeguard natural carbon sequesters located within the landscape (i.e. trees and hedgerows). This will positively respond to the potential effects of climate change (particularly from extreme weather events) through providing summer shading and reducing surface water run-off. Landscape 5.16 Felmersham and Radwell is not within or within proximity to a National Park or an Area of Outstanding Natural Beauty and does not contain any Green Belt land. Nevertheless, policies within the Neighbourhood Plan have a strong focus on protecting the sense of place and special qualities of Felmersham and Radwell which contribute to its local character, distinctiveness and sense of place.
5.17 Policy FR1 ‘General Development Principles’ outlines a presumption in favour of sustainable development within the settlement boundary. From a landscape perspective, proposals should ensure that the scale, form and character of the existing settlement is maintained (objective A). The policy goes on to state that proposals located outside of the village will be resisted in order to maintain the intrinsic value of the open countryside. With reference to the proposed site allocations through Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Perch Heights, Carlton Road, Felmersham’, both are located adjacent to the settlement boundary. By focusing development within proximity to the existing village, this will minimise the impacts to landscape character and retain the sense of openness across the rural areas of the parish.
5.18 Neighbourhood Plan policies also focus on delivering high quality design through development proposals. Key policies in this regard include Policy FR5 ‘Development Design Criteria’ which affirms that development will only be supported where it makes a positive contribution to the distinctive character of the village, preserving and enhancing local distinctiveness in keeping with the scale and character of the immediate surroundings (objective A). Policy FR1 also states that landscape character should be protected from any noise, light or other pollution (objective D). These policies will safeguard the open countryside from inappropriate scales of development, enabling residents to experience the full night sky and supporting tranquillity.
5.19 NPA7 indicates that the Parish Council will identify areas of land for new tree planting in the parish and promote and implement a tree planting scheme for the area. Similarly, NPA8 suggests that the Parish Council will seek to encourage the protection of locally designated and non-designated wildlife sites/areas and habitats, supporting the development of wildlife corridors and the extension of green spaces. This will protect the integrity of these valuable
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landscape features, including the tree preservation orders in the Neighbourhood Plan area which have been designated by Bedford Borough Council in recognition of their amenity value.
5.20 Regarding any potential non-residential development proposals likely to come forward during the plan period, proposals for recreational or amenity provision located outside of the settlement boundary will be supported in principle through Policy FR11 ‘Provision of New Community Facilities’ providing that they would not adversely impact on rural landscape character. Policy FR12 ‘Next Generation Broadband’ states that the development of new communications infrastructure to serve the villages of Felmersham and Radwell will be supported where the siting and appearance of the proposed apparatus and associated structures seek to minimise impact on the visual amenity, character or appearance of the surrounding area. Furthermore, Policy FR13 ‘Supporting Small Businesses’ states that proposals which support the local economy will be assessed against the potential impact to the landscape and character of the area. Historic Environment 5.21 The Neighbourhood Plan area has a rich historic environment, recognised through the diversity of features and areas that are nationally and locally valued for their heritage interest. This includes one Grade I and 23 Grade II nationally designated listed buildings which are protected through the Listed Buildings and Conservation Areas Act 1990, along with the Felmersham Conservation Area. Additionally, the Historic Environment Record (HER) for Bedfordshire also identifies 133 locally important heritage features located wholly or partly within the Neighbourhood Plan area. This includes records of prehistoric/Romano British enclosure cropmarks, Iron Age/Romano cemeteries and settlements within Felmersham, Bronze Age ditches and barrows, and several archaeological find spots including pottery dating to the Roman and Iron Ages.
5.22 With reference to the proposed site allocations, residential development through Policy FR3 ‘Land at The Old Road, Felmersham’ has the potential to impact upon the fabric and setting of the Grade II listed building ‘The Manor’ (located approximately 25m to the south west of the site) and the Felmersham Conservation Area (located directly to the south west of the site) in the absence of sensitive design. Similarly, residential development through Policy FR4 ‘Perch Heights, Carlton Road’ has the potential to impact upon the Grade II listed building ‘The Old Farmhouse’ (located adjacent to the south eastern corner of the site) and the Felmersham Conservation Area (which adjoins the eastern site boundary). Both sites are also partly within an area of archaeological interest, as shown on Bedford Borough Council’s interactive map.
5.23 In this respect, both policies seek to ensure that the design of proposals respects the character and appearance of these heritage designations, whilst also enhancing the special character of these assets. For example, Policy FR3 encourages proposals to preserve or enhance the special interest of the Felmersham Conservation Area. This is reaffirmed through the provisions of Policy FR4, alongside preserving the special architectural interest and historic significance of the Grade II listed ‘The Old Farmhouse’. Furthermore, the policies confirm that development proposals at both locations should be accompanied by a pre-determination archaeological evaluation to safeguard the integrity of the area of archaeological interest.
5.24 Historic environment sensitivities in the Neighbourhood Plan area are further reflected by several of the Neighbourhood Plan policies which have a strong focus on conserving and enhancing the significance of buildings and structures of architectural or historic interest, both designated and non-designated, and their settings. A key policy in this regard is Policy FR9 ‘Protection of Heritage Assets’ which states that proposals for developments within the Felmersham Conservation Area (or sites forming part of its setting) should preserve or enhance its character and appearance. Additionally, the policy states that proposals with the potential to directly impact (or impact the setting of) designated and non-designated heritage assets should demonstrate that consideration has been given to preserving:
• The special architectural and historic interest of listed buildings;
• The important character of the building or site itself;
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• Its most distinctive and important features;
• The positive elements of its setting and its relationship to its immediate surroundings; and
• The contribution that the building or the site and its setting makes to the character of the local area.
5.25 Policy FR1 ‘General Development Principles’ encourages proposals to ensure that new development preserves or enhances the character and appearance of Felmersham Conservation Area and preserves the special architectural and historic interest of listed buildings and the significance of non-designated heritage assets (objective B). The policy goes on to state that proposals located outside of the village will be resisted in order to maintain the intrinsic value of the historic environment. This is reinforced through Policy FR5 ‘Development Design Criteria’, affirming that development proposals should comply with the requirements of the Village Design Advice (located in Appendix 2 to accompany the Neighbourhood Plan). Specifically, proposals should contribute positively to village heritage and reflect the identity of local surroundings and materials (objective D). In this respect, these policies are likely to provide opportunities for new development to positively contribute to the fabric and setting of heritage assets, incorporating high-quality design which reflects the historic character and special qualities of the Neighbourhood Plan area.
5.26 With reference to locally important heritage features, NPA12 confirms that the Parish Council will work with Bedford Borough Council, Historic England, the local community and other appropriate interested parties to explore and develop a local list of historically important buildings for Felmersham and Radwell. At locations where development is considered likely to impact on important archaeological remains, Policy FR9 outlines that a pre-determination evaluation should be undertaken, followed by appropriate mitigation if necessary. This will further support the integrity of heritage assets within the parish. Land, Soil and Water Resources 5.27 Although a detailed agricultural land classification assessment has not been undertaken for most of the parish, it is noted in the predictive land quality assessment that the proposed site allocations taken forward through Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Perch Heights, Carlton Road, Felmersham’ have a greater than 60% likelihood of containing land which is classified as ‘best and most versatile’ land for agricultural purposes. This broadly aligns with the national dataset provided by Natural England which indicates that the sites are underlain by Grade 3 (good to moderate quality) agricultural land. Therefore, new development will potentially result in the permanent loss of the best and most versatile agricultural land at these locations. However, it is difficult to be certain in the absence of a detailed assessment. Whilst this cannot be mitigated, the reuse of previously developed land in some areas of the proposed allocation through Policy FR4 will promote the most efficient use of land in these locations.
5.28 Neighbourhood Plan policies also seek to safeguard the open countryside and rural hinterland from high levels of inappropriate development to positively safeguard land, soil and water resources. For example, Policy FR1 ‘General Development Principles’ seeks to minimise development outside of the village in order to maintain the intrinsic value of the open countryside. Policy FR13 ‘Supporting Small Businesses’ supports proposals which involve the conversion of existing buildings or the diversification of existing rural enterprises. This will encourage the most efficient use of land in the more rural parts of the parish.
5.29 The water resources located within and within proximity to the Neighbourhood Plan area include the River Great Ouse (located adjacent to the eastern and northern parish boundaries) and a network of drainage ditches. Concerning the protection of watercourses, NPA7 and NPA8 confirm that the Parish Council will seek to deliver ecological net gains within the Neighbourhood Plan area through a tree planting scheme, extending green spaces and developing wildlife corridors. This will minimise the risk of excessive surface water entering the watercourses, indirectly contributing to water quality improvements through limiting suspended solids entering watercourses from surface water run-off. This in turn will positively contribute to the Water Framework Directive’s objective of achieving ‘good status’ for as many watercourses
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as possible by 2027. This is important in the local context, as the River Great Ouse was classified as having a ‘moderate’ overall status in the most recently completed water quality assessments completed by the Environment Agency in 2016.
5.30 More broadly, Neighbourhood Plan policies also seek to protect key features of landscape and biodiversity interest and promote green space and open space. Key policies in this regard include Policy FR5 ‘Development Design Criteria’ and Policy FR10 ‘Protection of Village Facilities’. While these policies do not specifically seek to address land, soil and water resources, the policies will indirectly help promote and protect these resources, including the promotion of high-quality green networks in the Neighbourhood Plan area and the protection and enhancement of key landscape features. This will help support the capacity of the landscape and villagescape to regulate soil and water quality. Population and Community 5.31 A housing target of 13 dwellings will be met through the following two site allocations:
• Policy FR3 ‘Land at The Old Road, Felmersham’ (up to six dwellings); and
• Policy FR4 ‘Land at Perch Heights, Carlton Road, Felmersham’ (up to seven dwellings).
5.32 Policy FR1 ‘General Development Principles’ outlines a presumption in favour of sustainable development within the Settlement Policy Area Boundary (SPAB), subject to the design principles listed within the policy. Development proposals located outside of the SPAB will be resisted unless it can be demonstrated that the proposal would enhance the rural economy (amongst other considerations). In this regard, the proposed site allocations through Policy FR3 and Policy FR4 are located adjacent to the SPAB, within walking distance to services and facilities in the village centre. With reference to the proposed site allocation through Policy FR3, the following community benefits shall form part of the development site: a play area or other sports facility; a new car park for use by the Pinchmill Primary School, the church and the village hall; and suitable pedestrian crossing from the car park to the school.
5.33 The narrative behind the decision making process for these site allocations is discussed through the consideration of reasonable alternatives for the Neighbourhood Plan in Chapter 4 of the Environmental Report (see paragraphs 4.22 to 4.25).
5.34 The Neighbourhood Plan also seeks to support the delivery of high-quality design within housing, in addition to supporting the delivery of housing appropriate for local people through explicitly seeking to deliver homes of a type to reflect local needs. Key policies in this regard include Policy FR2 ‘Local Housing Need’, confirming that the type, tenure and cost of new housing should meet the needs of the local area (as indicated through the results of the housing needs survey). Affordable homes should also be provided as an integral part of development proposals. This is reaffirmed for the proposed site allocations through Policy FR3 and Policy FR4. Policy FR5 ‘Development Design Criteria’ stipulates that new development should be able to be adapted to accommodate changing lifestyles and technologies (objective E). The policy also states that all planning applications should provide a written statement which demonstrates how the criteria listed within the policy (including the criteria listed within the Village Design Advice) has been considered and incorporated into the proposal. This will positively contribute to the creation of mixed, balanced and sustainable communities.
5.35 The Neighbourhood Plan also has a strong focus on supporting the vitality of the parish and new community provision. For example, Policy FR10 ‘Protection of Village Facilities’ identifies six locally important facilities to be safeguarded from development proposals, including the Pinchmill Primary School, Church of St Mary and the village hall. In this respect, the loss of these facilities will only be permitted where it can be demonstrated that a) alternative provision can be made, b) there is no longer economic justification to protect the asset, and c) the community benefits of the proposal would outweigh the loss of the existing facility. Additionally, proposals that diversity or enhance the range of community facilities will be supported through Policy FR11 ‘Provision of New Community Facilities’. This is reaffirmed through NPA13.
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5.36 Furthermore, several non-priority actions in the Neighbourhood Plan seek to support investment in new community infrastructure provision, including the Pinchmill Primary School (NPA14), land for the provision of a new cemetery (NPA15), enhancing the recreational offer (NPA16) and promoting the use of the village hall (NPA17). Moreover, enhancements to community facilities and improvements to communications infrastructure are identified as priority projects for Community Infrastructure Levy (CIL) investment in local community infrastructure, as outlined in Policy FR8 ‘Creating a Sustainable Community’.
5.37 The Neighbourhood Plan also seeks to promote the economic vitality of the Neighbourhood Plan area and support employment opportunities. In this respect, Policy FR13 ‘Supporting Small Businesses’ supports proposals which involve the conversion of existing buildings or the diversification of existing rural enterprises, subject to the conditions listed within the policy. This will support the rural economy. Likewise, support will be given to appropriate proposals that help to provide improved or additional connectivity for the parish. The key policy in this regard is Policy FR12 ‘Next Generation Broadband’, confirming that all new residential, commercial and community buildings within the Neighbourhood Plan area should be served by a superfast broadband (fibre-optic) connection to the premises. Where this is not possible, practical or economically viable, the policy suggests that sufficient and suitable ducting should be provided within the site and to the property to facilitate installation at a future date. This will support running a business from home and home working. Health and Wellbeing 5.38 Reflecting the outcomes of the Joint Strategic Needs Assessment, the Public Health Profile for Bedford Borough contains a variety of key statistics which help to build an understanding of the community needs. The findings outline that the ageing population will continue to increase, levels of physical activity are lower than average, and the mental health of residents is a key concern. The policies contained within the Neighbourhood Plan will being a range of benefits for the wellbeing of residents within the parish, as well as addressing some of the key issues highlighted within the health profile.
5.39 To encourage healthier lifestyles within the Neighbourhood Plan area, residential development through Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Perch Heights, Carlton Road, Felmersham’ will be supported providing that private amenity space is incorporated into the design. Additionally, the proposed site allocation through Policy FR4 shall be encouraged to retain the existing wooded area on site and enhance connectivity and accessibility to the neighbouring woodland. Further supporting healthier lifestyles, the promotion and improvement of parish walks (locally important routes) is identified as a priority project for community investment through Policy FR8 ‘Creating a Sustainable Community’.
5.40 Regarding community cohesion and quality of life, Policy FR1 ‘General Development Principles’ outlines a presumption in favour of sustainable development within the settlement boundary. Proposals should protect residential amenity from any noise, light or other pollution (objective D). Outside of the settlement boundary, proposals for recreational or amenity provision will be supported in principle through Policy FR11 ‘Provision of New Community Facilities’, providing the proposals do not results in unacceptable noise, fumes, smell or disturbance to other residential properties. This is reaffirmed through Policy FR5 ‘Development Design Criteria’ which states that development proposals should ensure that there is no unacceptable loss of amenity to neighbouring developments through loss of privacy, light, visual intrusions, noise and pollution (objective D). Proposals should also be designed to the size and shape of the building plot, protecting and enhancing the existing street scene and the residential amenity for existing and future residents (objective B). This will support the quality of the public realm.
5.41 More broadly, the Neighbourhood Plan policies will bring a range of further benefits for health and wellbeing. The main impacts of the Neighbourhood Plan’s policies on health and wellbeing will be through protecting and enhancing the Neighbourhood Plan area’s high-quality environment and public realm and green infrastructure provision. Policy FR10 ‘Protection of Village Facilities’ identifies six locally important facilities to be safeguarded from development proposals, including the play area and playing fields, and the Margaret Alleway Memorial Garden. Likewise, NPA6 states that the Parish Council will work to create more formal and
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informal green spaces in the village and to ensure the better landscaping of public areas. Furthermore, Policy FR5 stipulates that proposals should incorporate high quality green infrastructure to improve links, together with protecting and enhancing wildlife habitats (objective F). This will support the physical and mental health and wellbeing of residents. Transportation 5.42 Each Local Transport Authority in England and Wales has a statutory duty to produce, adopt and regularly review their Local Transport Plan (LTP) through the Local Transport Act 2000, as amended by the Local Transport Act 2008. In this regard, the Bedford Local Transport Plan 2011-202116 has a vision ‘to create a transport system in which walking, cycling and public transport are the natural choices of travel for most journeys because they are affordable, healthy, convenient and safe alternatives to the private car’. The policies contained within the Neighbourhood Plan will focus on supporting a modal shift towards more sustainable methods of travel, whilst also encouraging active travel.
5.43 With reference to the Neighbourhood Plan area, there is a need to ensure that developments have good accessibility to a range of services and facilities. In this respect, Policy FR1 ‘General Development Principles’ outlines a presumption in favour of sustainable development within the defined settlement boundary. Similarly, the proposed site allocations through Policy FR3 ‘Land at The Old Road, Felmersham’ and Policy FR4 ‘Perch Heights, Carlton Road, Felmersham’ are located adjacent to the settlement boundary, within walking distance to services and facilities in the village centre. This will help to ensure that new developments are situated in the most sustainable locations in terms of the relative distance to the local centre, supporting the creation of inclusive communities and encouraging alternative options of transportation for undertaking day-to-day activities within the parish.
5.44 Supporting modal shift, Policy FR6 ‘Transportation’ encourages proposals which would contribute towards improvements to existing and/or new public and community transport services in the Neighbourhood Plan area (subject to other Neighbourhood Plan policies). Proposals for new development should also connect to existing footpaths to enable residents to walk to village amenities. Accessibility is also supported through NPA9-11, stipulating that the Parish Council will work with key stakeholder groups to extend the public right of way network within Felmersham and Radwell.
5.45 In terms of tackling congestion and traffic issues within the Neighbourhood Plan area, residential development taken forward through Policy FR3 and Policy FR4 will be supported providing that appropriate parking is incorporated into the design and it can be demonstrated that an appropriate standard of access can be achieved for both vehicles and pedestrians. Additionally, the proposed site allocation through Policy FR3 will be encouraged to provide a new car park as part of the development site for use by the Pinchmill Primary School, church and village hall. Furthermore, Policy FR5 ‘Development Design Criteria’ and Policy FR7 ‘Residential Parking in New Developments’ stipulates that new development proposals should provide a sufficient level of off-street parking to meet the assessed needs.
5.46 Further seeking to tackle congestion within the Neighbourhood Plan area, Policy FR5 affirms that proposals within and adjoining the Neighbourhood Plan area should demonstrate that the development would not have an unacceptable impact on the area in terms of additional traffic generation through a robust Transport Statement. Where the development proposed would involve an increase in traffic, the policy states that the developer(s) will be required to make provision for, and contribute to, appropriate mitigation measures. Furthermore, the following projects outlined in Policy FR8 ‘Creating a Sustainable Community’ are identified as priorities for CIL investment in local community infrastructure:
• Improvements to cycle paths and footpaths within the parish with improved surfaces and lighting; and
16 Bedford Borough Council (2011) Local Transport Plan 2011-2021 [online] available at:
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• Contribution to traffic surveys and implementation of improved traffic management in the village centres.
5.47 In terms of the potential non-residential development proposals likely to come forward during the plan period, proposals for recreational or amenity provision located outside of the settlement boundary will be supported in principle through Policy FR11 ‘Provision of New Community Facilities’. Specifically, proposals should not result in unacceptable traffic movements, provide appropriate parking, and facilitate opportunities for walking and cycling. Policy FR13 ‘Supporting Small Businesses’ states that access, traffic and car parking arrangements will be key considerations for assessing proposals which support the rural economy. This is also supported through several of the NPAs listed in the Neighbourhood Plan, specifically NPA1-5. Conclusions at this current stage 5.48 The assessment has concluded that the Regulation 14 version of the Neighbourhood Plan is likely to lead to significant positive effects in relation to the ‘Population and Community’ SEA theme. This relates to the focus of the Neighbourhood Plan on safeguarding and enhancing community infrastructure, facilitating the delivery of housing which meets local needs and through encouraging proposals which would seek to enhance the economic and community vitality of the parish. The Neighbourhood Plan will also bring significant positive effects in relation to the ‘Health and Wellbeing’ SEA theme, linked to its promotion of improved and accessible network of footpaths, enhancements to green infrastructure and open space provision to encourage active lifestyles, and the facilitation of public realm improvements.
5.49 The Neighbourhood Plan is also likely to lead to positive effects in relation to the ‘Landscape’ and ‘Historic Environment’ SEA themes. These benefits largely relate to the Neighbourhood Plan’s emphasis on protecting and enhancing the special qualities of the parish, supporting the quality of the public realm, and through incorporating high-quality and sensitive design through new development proposals. However, it is important to acknowledge that the proposed site allocations do have the potential to negatively impact on the setting of the Felmersham Conservation Area and nearby heritage assets in the absence of sensitive design. In this respect, the Neighbourhood Plan policies provide an appropriate level of protection for the special interest and character of these key assets of historic environment value.
5.50 Additionally, the Neighbourhood Plan will bring positive effects in relation to the ‘Biodiversity and Geodiversity’ SEA theme through retaining habitats, enhancing ecological networks and delivering net gains. However, given the approaches taken forward through the Neighbourhood Plan will help limit potential effects from new development areas rather than secure significant enhancements, these impacts are less likely to comprise significant positive effects overall.
5.51 Regarding the ‘Climate Change’ SEA theme, the Neighbourhood Plan will potentially lead to positive effects through supporting development proposals in accessible locations within proximity to services and facilities and locating development in areas which have a low flood risk potential. However, this is dependent on the extent to which development proposals incorporate these mitigation and adaptation measures through design. In this respect, it is recommended that the Neighbourhood Plan consider enhancing the wording of Policy FR3 ‘Land at The Old Road, Felmersham’ to include: “proposals should clearly demonstrate how any potential flood risk issues will be appropriately mitigated, including through incorporating sustainable urban drainage systems (SuDS) through design”. This is given the fluvial flood risk concerns in the northern section of the site, along with the proximity to the River Great Ouse.
5.52 The Neighbourhood Plan will also initiate several beneficial approaches regarding the ‘Transportation’ SEA theme, given its focus on reducing traffic congestion, providing additional parking through new development, supporting a modal shift towards sustainable transport and by ensuring that new developments provide appropriate access to local services and facilities. However, the scale of development through the proposed site allocations is unlikely to lead to significant increases to the levels of traffic along the key routes passing through the parish.
5.53 The Neighbourhood Plan will also initiate several beneficial approaches for the ‘Land, Soil and Water Resources’ SEA themes through the implementation of objectives which seek to limit
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pollution and improve the environmental quality of the parish. However, the Neighbourhood Plan will facilitate a proportion of new dwellings on greenfield sites which have a greater than 60% likelihood containing ‘best and most versatile’ agricultural land. This has the potential to lead to the permanent loss of productive agricultural land in the Neighbourhood Plan area, which cannot be mitigated.
6. What are the next steps?
6.1 This Environmental Report accompanies the Felmersham and Radwell Neighbourhood Plan for Regulation 14 consultation.
6.2 Following consultation, any representations made will be considered by the Neighbourhood Plan Steering Group, and the Neighbourhood Plan and Environmental Report will be updated as necessary. The updated Environmental Report will then accompany the Neighbourhood Plan for submission to the Local Planning Authority, Bedford Borough Council, for subsequent Independent Examination.
6.3 At Independent Examination, the Neighbourhood Plan will be considered in terms of whether it meets the Basic Conditions for Neighbourhood Plans and is in general conformity with local planning policy.
6.4 If the Independent Examination is favourable, Felmersham and Radwell Neighbourhood Plan will be subject to a referendum, organised by Bedford Borough Council. If more than 50% of those who vote agree with the Neighbourhood Plan, then it will be ‘made’. Once made, Felmersham and Radwell Neighbourhood Plan will become part of the Development Plan for the parish.
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Appendix A Context Review and Baseline A1 – Air Quality Context Review Key messages from the National Planning Policy Framework (NPPF) include:
• ‘Planning policies and decisions should sustain and contribute towards compliance with relevant limit values or national objectives for pollutants, taking into account the presence of Air Quality Management Areas and Clean Air Zones, and the cumulative impacts from individual sites in local areas. Opportunities to improve air quality or mitigate impacts should be identified, such as through traffic and travel management, and green infrastructure provision and enhancement. So far as possible these opportunities should be considered at the plan-making stage, to ensure a strategic approach and limit the need for issues to be reconsidered when determining individual applications. Planning decisions should ensure that any new development in Air Quality Management Areas and Clean Air Zones is consistent with the local air quality action plan.’ • ‘Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health.’ • New and existing developments should be prevented from contributing to, being put at unacceptable risk from, or being adversely affected by unacceptable levels of air pollution. Published in January 2018 by the UK Government, ‘A Green Future: Our 25 Year Plan to Improve the Environment’17 sets out a number of goals and policies in order to help the natural world regain and retain good health. In this context, Goal 1 ‘Clean Air’ and the policies contained within ‘Chapter 4: Increasing resource efficiency and reducing pollution and waste’ within the 25 year plan directly relate to the air quality SEA theme.
In terms of the local context, Bedford Borough Council is required under Section 82 of the Environment Act (1995) to monitor air quality across the area, report regularly to DEFRA, and take action where nationally set levels are likely to be exceeded. Monitoring is undertaken to assess levels of nitrogen dioxide (NO2), sulphur dioxide (SO2), ozone (O3), benzene (C6H6) and particulates (PM10). Where exceedances exist, areas are declared as Air Quality Management Areas (AQMAs) and local authorities are required to produce an Air Quality Action Plan (AQAP) to improve air quality in the area.
Policy 48 (Pollution, disturbance and contaminated land) from the Bedford Borough Local Plan 2030 also relates to the Air Quality SEA theme. Summary of Current Baseline As of September 2018, there are no Air Quality Management Areas (AQMAs) within the Neighbourhood Plan area as highlighted in the 2018 Air Quality Annual Status Report.18 The nearest AQMA is in Bedford town centre approximately 7.3km away.
There are no recent or anticipated exceedances of national air quality objectives in the Neighbourhood Plan area.
17 HM GOV (2018) A Green Future: Our 25 Year Plan to Improve the Environment [online] available at: https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/693158/25-year- environment-plan.pdf [accessed 07/01/20] 18 Bedford Borough Council (2018) 2018 Air Quality Annual Status Report (ASR) [online] available at: < https://bbcdevwebfiles.blob.core.windows.net/webfiles/Environmental%20Issues/Bedford%20Borough%20Council%202018%2 0ASR.pdf> [accessed 07/01/20]
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Summary of Future Baseline New housing and employment provision within the parish and the wider area, including through the Bedford Borough Local Plan 2030, has the potential for adverse effects on air quality through increasing traffic flows and associated levels of pollutants such as NO2. However, this is unlikely to lead to exceedances of air quality objectives in the Neighbourhood Plan area given the low air pollutant baseline which currently exists. A2 – Biodiversity and Geodiversity Context Review At the European level, the EU Biodiversity Strategy19 was adopted in May 2011 in order to deliver an established new Europe-wide target to ‘halt the loss of biodiversity and the degradation of ecosystem services in the EU by 2020’.
Key messages from the National Planning Policy Framework (NPPF) include:
• One of the three overarching objectives of the NPPF is an environmental objective to ‘contribute to protecting and enhancing our natural, built and historic environment’ including by ‘helping to improve biodiversity.’ • ‘Plans should: distinguish between the hierarchy of international, national and locally designated sites; allocate land with the least environmental or amenity value[…], take a strategic approach to maintaining and enhancing networks of habitats and green infrastructure; and plan for the enhancement of natural capital at a catchment or landscape scape across local authority boundaries.’ • ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils (in a manner commensurate with the statutory status or identified quality in the development plan); and minimising impacts on and providing net gains for biodiversity, including establishing coherent ecological networks that are more resilient to current and future pressures.’ • ‘To protect and enhance biodiversity and geodiversity, plans should: a) Identify, map and safeguard components of local wildlife-rich habitats and wider ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity; wildlife corridors and stepping stones that connect them; and areas identified by national and local partnerships for habitat management, enhancement, restoration or creation; and b) Promote the conservation, restoration and enhancement of priority habitats, ecological networks and the protection and recovery of priority species; and identify and pursue opportunities for securing measurable net gains for biodiversity’. The Natural Environment White Paper (NEWP)20 sets out the importance of a healthy, functioning natural environment to sustained economic growth, prospering communities and personal well-being. It was in part a response to the UK’s failure to halt and reverse the decline in biodiversity by 2010 and it signalled a move away from the traditional approach of protecting biodiversity in nature reserves to adopting a landscape approach to protecting and enhancing biodiversity. The NEWP also aims to create a green economy in which economic growth and the health of our natural resources sustain each other and markets, business and Government better reflect the value of nature. It includes commitments to:
• Halt biodiversity loss, support functioning ecosystems and establish coherent ecological networks by 2020; • Establish a new voluntary approach to biodiversity offsetting to be tested in pilot areas;
19 European Commission (2011) Our life insurance, our natural capital: an EU biodiversity strategy to 2020 [online] available at:
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• Enable partnerships of local authorities, local communities and landowners, the private sector and conservation organisations to establish new Nature Improvement Areas; and • Address barriers to using green infrastructure to promote sustainable growth. Reflecting the commitments within the Natural Environment White Paper and the EU Biodiversity Strategy, ‘Biodiversity 2020: A strategy for England’s wildlife and ecosystem services’ aims to ‘halt overall biodiversity loss, support healthy well-functioning ecosystems and establish coherent ecological networks, with more and better places for nature for the benefit of wildlife and people’21.
The recently published 25 Year Environment Plan22 sets out the Government’s environmental plan of action over the next quarter century, in the context of Brexit. The Plan aims to tackle the growing problems of waste and soil degradation, improving social justice through tackling pollution and promoting the mental and physical health benefits of the natural world. It also sets out how the Government will address the effects of climate change. These aims are supported by a range of policies which are focused on the following six key areas:
• Using and managing land sustainably; • Recovering nature and enhancing the beauty of landscapes; • Connecting people with the environment to improve health and wellbeing; • Increasing resource efficiency, and reducing pollution and waste; • Securing clean, productive and biologically diverse seas and oceans; and • Protecting and improving the global environment. In this context, Goal 3 ‘Thriving plants and wildlife’ and the policies contained within Chapter 2 ‘Recovering nature and enhancing the beauty of landscapes’ and Chapter 5 ‘Securing clean, productive and biologically diverse seas and oceans’ directly relate to the Biodiversity and Geodiversity SEA theme.
At the local level, policies in the Bedford Borough Local Plan 2030 that relate to the Biodiversity and Geodiversity theme include:
• 36S: Green Infrastructure; • 40: Retention of trees; • 41: Hedgerows; • 43S: Protecting biodiversity and geodiversity; • 44: Enhancing biodiversity; and • 46: Local Green Space. Summary of Current Baseline European and Nationally designated sites
There are no European designated sites within the Neighbourhood Plan area. The nearest Special Protection Area (SPA) is Upper Nene Valley Gravel Pits SPA which is approximately 9.8km north west of the Neighbourhood Plan area.
21 DEFRA (2011): ‘Biodiversity 2020: A strategy for England’s wildlife and ecosystem services’, [online] Available to download from:
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Felmersham Gravel Pits SSSI
Felmersham Gravel Pits SSSI lies just outside of the Neighbourhood Plan area, approximately 75m from the parish boundary. Notified in April 1986, ‘Felmersham Gravel Pits SSSI’ is approximately 21.5 ha in size. The citation statement for the SSSI states the following23:
‘Located on River Gravels between Sharnbrook and Felmersham, this site consists of a series of flooded pits which were active until about 1945. Many habitats have developed, with tall fen communities surrounding open water, neutral grassland, scrub and broadleaved woodland. This variety of habitat supports a very diverse flora, including several species rare and declining in the county and an exceptionally high number of dragonfly Odonata species.
The shallower margins of the pits are largely dominated by common reed Phragmites australis with common bulrush Schoenoplectus lacustris, clubrush Typha latifolia and occasional flowering rush Butomus umbellatus, lesser bulrush Typha angustifolia and water dock Rumex hydrolapathum. Several small ponds support branched bur-reed Sparganium erectum and sharp-flowered rush Juncus acutiflorus.
The locally rare water-plants, whorled water-milfoil Myriophyllum verticillatum and bladderwort Utricularia australis are recorded for this site.
The drier banks and islands support alders Alnus glutinosa, with a ground flora including yellow loosestrife Lysimachia vulgaris, purple loosestrife Lythrum salicaria, and orange balsam Impatiens capensis.
The neutral unimproved grassland is dominated by grasses such as Yorkshire fog Holcus lanatus and meadow foxtail Alopecurus pratensis, with a good variety of herbs including tufted vetch Vicia cracca, rough chervil Chaerophyllum temulentum and common fleabane Pulicaria dysenterica. There is also evidence of a more calcareous influence with species such as wild carrot Daucus carota, black knapweed Centaurea nigra and fescues Festuca spp.
Additional habitats are provided by the recent development of scrub and broadleaved woodland. These habitats are dominated by willows Salix sp., alder and hawthorn Crataegus monogyna, with occasional species such as field maple Acer campestre, ash Fraxinus excelsior and wild cherry Prunus avium. Common spotted orchid Dactylorhiza fuchsii and broadleaved helleborine Epipactis helleborine are included in the ground flora.
The site provides a very important habitat for insects, and all the common amphibians are present. Among the reptiles grass snakes Natrix natrix are common. The wide variety of habitats also supports a very diverse bird community.’
The most recent condition assessments for the SSSI indicate that 100% of the SSSI is considered to be in a ‘unfavourable - recovering’ condition.
SSSI Impact Risk Zones
SSSI Impact Risk Zones (IRZ) are a GIS tool/dataset which maps zones around each SSSI according to the sensitivities of the features for which it is notified. They specify the types of development that have the potential to have adverse impacts at a given location, including residential, rural-residential and rural non-residential. Natural England is a statutory consultee on development proposals that might impact on SSSIs.
In this context, part of the Neighbourhood Plan area surrounding Felmersham Gravel Pits is located within an IRZ for residential and/or rural-residential developments, including the northern part of the built up area of Felmersham. For residential, this applies to residential development of 100 units or more. For rural residential, this applies for any residential development of 50 or more houses outside existing settlements/ urban areas.
23 Natural England (no date): ‘Felmsersham Gravel Pits SSSI’, [online] available at: https://designatedsites.naturalengland.org.uk/SiteDetail.aspx?SiteCode=S1000541 [accessed 07/01/20]
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Locally important sites There are a variety of BAP Priority Habitats located within and/or adjacent to the Neighbourhood Plan area, predominantly areas of deciduous woodland and lowland meadows.
Figure A2.1 below shows the designated wildlife sites and BAP priority habitats located within and adjacent to the Neighbourhood Plan area. Summary of Future Baseline Habitats and species are likely to continue to be offered protection through the higher-level planning framework, however; they will potentially face increasing pressures from future development within the Neighbourhood Plan area with the potential for negative effects on the wider ecological network. These pressures have the potential to be exacerbated by the effects of climate change.
The Neighbourhood Plan presents an opportunity to maximise benefits for biodiversity by including consideration of important habitats, species, undesignated sites, and connections between designated sites and undesignated sites at a localised scale, and at an early stage of planning for future growth. This is particularly relevant in the siting of new small scale housing development.
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A3 – Climate Change Context Review The UK Climate Change Risk Assessment is published on a 5-yearly cycle in accordance with the requirements of the Climate Change Act 2008. It required the Government to compile an assessment of the risks for the UK arising from climate change, and then to develop an adaptation programme to address those risks and deliver resilience to climate change on the ground. For both the 2012 and the 2017 UK Climate Change Risk Assessment, the Adaptation Sub-Committee commissioned an evidence report aiming to understand the current and future climate risks and opportunities. The evidence report contains six priority risk areas requiring additional action in the next five years, see below24 :
• Flooding and coastal change risks to communities, businesses and infrastructure; • Risks to health, well-being and productivity from high temperatures; • Risk of shortages in the public water supply, and for agriculture, energy generation and industry; • Risks to natural capital, including terrestrial, coastal, marine and freshwater ecosystems, soils and biodiversity; • Risks to domestic and international food production and trade; and • New and emerging pests and diseases, and invasive non-native species, affecting people, plants and animals. The UK Climate Change Act25 was passed in 2008 and established a framework to develop an economically credible emissions reduction path. It also highlighted the role it would take in contributing to collective action to tackle climate change under the Kyoto Protocol, and more recently as part of the UN-led Paris Agreement.
The Climate Change Act includes the following:
• 2050 Target. The Act commits the UK to reducing emissions by at least 80% in 2050 from 1990 levels. • Carbon Budgets. The Act requires the Government to set legally binding ‘carbon budgets’. A carbon budget is a cap on the amount of greenhouse gases emitted in the UK over a five-year period. The carbon budgets are designed to reflect the cost-effective path to achieving the UK’s long-term objectives. The first five carbon budgets have been put into legislation and run up to 2032. • The Committee on Climate Change was set up to advise the Government on emissions targets, and report to Parliament on progress made in reducing greenhouse gas emissions. • The National Adaptation Programme requires the Government to assess the risks to the UK from climate change, prepare a strategy to address them, and encourage key organisations to do the same. For more detail, visit the UK adaptation policy page 26. Key messages from the National Planning Policy Framework (NPPF) include:
• One of the three overarching objectives of the NPPF is an environmental objective to ‘contribute to protecting and enhancing our natural, built and historic environment’ including by ‘mitigating and adapting to climate change’ and ‘moving to a low carbon economy.’ ‘The planning system should support the transition to a low carbon future in a changing climate, taking full account of flood risk and coastal change. It should help to: shape places in ways that contribute to radical reductions in greenhouse gas emissions, minimise vulnerability and improve resilience;
24 GOV UK: ‘UK Climate Change Risk Assessment Report January 2017’, [online] available at:
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encourage the reuse of existing resources, including the conversion of existing buildings; and support renewable and low carbon energy and associated infrastructure.’ • ‘Plans should take a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for flood risk, coastal change, water supply, biodiversity and landscapes, and the risk of overheating from rising temperatures. Policies should support appropriate measures to ensure the future resilience of communities and infrastructure to climate change impacts, such as providing space for physical protection measures, or making provision for the possible future relocation of vulnerable development and infrastructure.’ • ‘Local planning authorities should support community-led initiatives for renewable and low carbon energy, including developments outside areas identified in local plans or other strategic policies that are being taken forward through neighbourhood planning.’ • Direct development away from areas at highest risk of flooding (whether existing or future). ‘Where development is necessary, it should be made safe for its lifetime without increasing flood risk elsewhere.’ The Flood and Water Management Act27 highlights that alternatives to traditional engineering approaches to flood risk management include:
• Incorporating greater resilience measures into the design of new buildings, and retro-fitting properties at risk (including historic buildings); • Utilising the environment in order to reduce flooding, for example through the management of land to reduce runoff and through harnessing the ability of wetlands to store water; • Identifying areas suitable for inundation and water storage to reduce the risk of flooding elsewhere; • Planning to roll back development in coastal areas to avoid damage from flooding or coastal erosion; and • Creating sustainable drainage systems (SuDS).28 At the local level, policies in the Bedford Borough Local Plan 2030 that relate to the Climate Change theme include:
• 52S: Climate change strategic approach; • 55: Energy efficiency; • 56: Renewable energy – district heating; • 57: Renewable energy – broad locations; • 58: Renewable energy – broad locations suitable for renewable energy development; • 93: Electric vehicle infrastructure; and • 96: Flood risk. Summary of Current Baseline Contribution to climate change
In relation to greenhouse gas emissions, source data from the Department of Energy and Climate Change suggests that Bedford Borough has lower per capita emissions in comparison to the East of England and England as a whole since 2005. Bedford has seen a 33.3% reduction in the percentage of total emissions per capita between 2005 and 2016 which is the same as the reductions for the East of England (33.3%) but lower than the reductions for England (37.6%)29.
27 Flood and Water Management Act (2010) [online] available at:
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Potential effects of climate change
Following the success of the UK Climate Projections released in 2009 (UKCP09), the Met Office recently released the UK Climate Projections for 2018 (UKCP18).30 UKCP18 provides the most up to date climate observations and projections out to 2100, using cutting-edge climate science. Projections are broken down to a regional level across the UK and are shown in probabilistic form, which illustrate the potential range of changes and the level of confidence in each prediction.
As highlighted by the research, the effects of climate change (under medium emissions scenarios 50th percentile) for East England during the period 2040-2059 compared to the period 1981-2000 are likely to be as follows31:
• The central estimate of increase in annual mean temperatures of between 2ºC and 3ºC; and • The central estimate of change in annual mean precipitation of +20 to +30% in winter and -10% to -20% in summer. Resulting from these changes, a range of risks may exist for the Neighbourhood Plan area, including:
• Increased incidence of heat related illnesses and deaths during the summer; • Increased incidence of illnesses and deaths related to exposure to sunlight (e.g. skin cancer, cataracts); • Increased incidence of pathogen related diseases (e.g. legionella and salmonella); • Increase in health problems related to rise in local ozone levels during summer; • Increased risk of injuries and deaths due to increased number of storm events; • Effects on water resources from climate change; • Reduction in availability of groundwater for abstraction; • Adverse effect on water quality from low stream levels and turbulent stream flow after heavy rain; • Increased risk of flooding, including increased vulnerability to 1:100-year floods; • Changes in insurance provisions for flood damage; • A need to increase the capacity of wastewater treatment plants and sewers; • A need to upgrade flood defences; • Soil erosion due to flash flooding; • Loss of species that are at the edge of their southerly distribution; • Spread of species at the northern edge of their distribution; • Deterioration in working conditions due to increased temperatures; • Changes to global supply chain; • Increased difficulty of food preparation, handling and storage due to higher temperatures; • An increased move by the insurance industry towards a more risk-based approach to insurance underwriting, leading to higher cost premiums for business; • Increased demand for air-conditioning; • Increased drought and flood related problems such as soil shrinkages and subsidence; • Risk of road surfaces melting more frequently due to increased temperature; and • Flooding of roads.
30 Data released 26th November 2018 [online] available at: https://www.metoffice.gov.uk/research/collaboration/ukcp [accessed 16/12/19] 31 Met Office (2018): ‘Land Projection Maps: Probabilistic Projections’, [online map] available to access via:
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Flood risk
The majority of the Neighbourhood Plan area is located within Flood Zone 1, showing that there is a <0.1% chance (1 in 1000) of river flooding in any given year. However, there are large areas of land adjacent to River Great Ouse which are located within Flood Risk Zone 3 and have a >1% chance of being flooded each year. This includes areas to the north of Felmersham village, and areas to the south of Radwell32.
The 2020 Strategic Flood Risk Assessment (SFRA) for Bedford Borough33 also outlines that the primary source of flood risk in Bedford Borough is fluvial flooding from the River Great Ouse. Within the SFRA, Felmersham and Radwell are identified as built up areas which have some risk of flooding.
Surface water drainage and sewer flooding is a risk for some parts of the Neighbourhood Plan area, with sections of medium-high risk predominantly located around River Great Ouse and its tributaries34. Summary of Future Baseline Climate change has the potential to increase the occurrence of extreme weather events in the Neighbourhood Plan area, with increases in mean summer and winter temperatures, increases in mean precipitation in winter and decreases in mean precipitation in summer. This is likely to increase the risks associated with climate change, with an increased need for resilience and adaptation.
In terms of climate change contribution, per capita greenhouse gas emissions generated in the Neighbourhood Plan area may continue to decrease with wider adoption of energy efficiency measures, renewable energy production and new technologies, including electric cars and buses. However, increases in the built footprint of the Neighbourhood Plan area would contribute to increases in the absolute levels of greenhouse gas emissions. A4 – Historic Environment Context Review Key messages from the National Planning Policy Framework (NPPF) include:
• Heritage assets should be recognised as an ‘irreplaceable resource’ that should be conserved in a ‘manner appropriate to their significance’, taking account of ‘the wider social, cultural, economic and environmental benefits’ of conservation, whilst also recognising the positive contribution new development can make to local character and distinctiveness. • Plans should set out a ‘positive strategy’ for the ‘conservation and enjoyment of the historic environment’, including those heritage assets that are most at risk. • ‘When considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation (and the more important the asset, the greater the weight should be). This is irrespective of whether any potential harm amounts to substantial harm, total loss or less than substantial harm to its significance.’ The policies contained within Chapter 2 ‘Recovering nature and enhancing the beauty of landscapes’ and Goal 6 ‘Enhanced beauty, heritage and engagement with the natural environment’ of the Government’s ‘‘A Green Future: Our 25 Year Plan to Improve the Environment’ directly relates to the Landscape and Historic Environment SEA theme.
The Government’s Statement on the Historic Environment for England35 sets out its vision for the historic environment. It calls for those who have the power to shape the historic environment to
32 GOV UK (2020): ‘Flood Map for Planning’, [online] available at:
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recognise its value and to manage it in an intelligent manner in light of the contribution that it can make to social, economic and cultural life.
Historic England is the statutory body that helps people care for, enjoy and celebrate England’s spectacular historic environment. Guidance and advice notes provide essential information for local planning authorities, neighbourhood groups, developers, consultants, landowners and other interested parties on historic environment considerations, and are regularly reviewed and updated in light of legislative changes. The following guidance and advice notes are particularly relevant and should be read in conjunction with the others.
Conservation Area Designation, Appraisal and Management: Historic England Advice Note 1 (February 2019)36 outlines ways to manage change that conserves and enhances historic areas in order to positively contribute to sustainable development. Principally, the advice note emphasises the importance of:
• Understanding the different types of special architectural and historic interest which underpin the designations; and • Recognising the value of implementing controls through the appraisal and/or management plan which positively contribute to the significance and value of conservation areas. Sustainability Appraisal (SA) and Strategic Environment Assessment (SEA): Historic England Advice Note 8 (December 2016)37 provides support to all stakeholders involved in assessing the effects of certain plans and programmes on the historic environment. It offers advice on heritage considerations during each stage of the SA/SEA process and helps to establish the basis for robust and comprehensive assessments.
Historic Environment Good Practice Advice in Planning Note 3: The Setting of Heritage Assets (2nd Edition) (December 2017)38 provides general advice on understanding setting, and how it may contribute to the significance of heritage assets and allow that significance to be appreciated, as well as advice on how views can contribute to setting. Specifically, Part 2 of the advice note outlines a five stepped approach to conducting a broad assessment of setting:
• Step 1: Identify which heritage assets and their settings are affected; • Step 2: Asses the degree to which these settings make a contribution to the significance of the heritage asset(s) or allow significance to be appreciated; • Step 3: Assess the effects of the proposed development, whether beneficial or harmful, on that significance or on the ability to appreciate it; • Step 4: Explore ways to maximise enhancement and avoid or minimise harm; and • Step 5: Make and document the decision and monitor outcomes. Neighbourhood Planning and the Historic Environment: Historic England Advice Note 11 (October 2018)39 outlines the importance of considering the historic environment whilst preparing the plan (section 1), which culminates in a checklist of relevant of issues to consider, followed by an overview of what this means in terms of evidence gathering (section 2). Sections 3 to 5 of the advice note focus on how to translate evidence into policy, understand the SEA process and Historic England’s role in neighbourhood planning.
At the local level, policy 42S (Historic environment and heritage assets) from the Bedford Borough Local Plan 2030 relates to the Historic Environment SEA theme.
36 Historic England (2019): ‘Conservation Area Designation, Appraisal and Management: Advice Note 1’, [online] available at: < https://historicengland.org.uk/images-books/publications/conservation-area-appraisal-designation-management-advice-note- 1/heag-268-conservation-area-appraisal-designation-management/> [accessed 08/01/20] 37 Historic England (2016): ‘SA and SEA: Advice Note 8’ [online] available at:
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Summary of Current Baseline Listed buildings
Historic England is the statutory consultee for certain categories of listed building consent and all applications for scheduled monument consent. The historic environment is protected through the planning system, via conditions imposed on developers and other mechanisms.
The Neighbourhood Plan area contains one Grade I and 24 Grade II listed buildings. Many of the listed buildings are located within the Felmersham Conservation Area. The Grade I listed building (Church of St Mary the Virgin) and ten Grade II listed buildings lie within the Conservation Area. The listed buildings within the Neighbourhood Plan area are listed below:
• Felmersham Bridge (Grade II); • Hall Farmhouse (Grade II); • Swan Cottage (Grade II); • Radwell Bridge (Grade II); • Cygnet Thatch (Grade II); • Greenway Cottage (Grade II); • Wills Farmhouse (Grade II); • Rose Cottage (Grade II); • The Stables (Grade II); • Harrowdene Farmhouse (Grade II); • Cottage West of Rose Cottage (Grade II); • White House (Grade II); • Tithe Barn (Grade II); • Underwood Farm (Grade II); • The Old Bakery (Grade II); • The Old Farmhouse (Grade II); • Corn Close (Grade II); • College Farmhhouse (Grade II); • Sun Inn (Grade II); • Six Ringers Inn (Grade II); • The Old Rectory and Rectory Cottage (Grade II); • East Grange (Grade II); • The Manor (Grade II); • West Grange (Grade II); • Parish Church of St Mary (Grade I); None of the listed buildings within the Neighbourhood Plan area are identified as ‘at risk’ on Historic England’s Heritage at Risk Register40.
40 Historic England (2020) Heritage at Risk Register [online] available at: https://www.historicengland.org.uk/advice/heritage-at- risk/search-register/ [accessed 08/01/20]
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Conservation Area
Conservation areas are designated because of their special architectural and historic interest41 . Conservation area appraisals are a tool to demonstrate the area’s special interest, explaining the reasons for designation and providing a greater understanding and articulation of its character - mentioned within the ‘Conservation Area Designation, Appraisal and Management’ advice note by Historic England. Ideally, appraisals should be regularly reviewed as part of the management of the conservation area and can be developed into a management plan.
A conservation area covers part of the built-up area of Felmersham within the centre of the Neighbourhood Plan area, where a cluster of listed buildings are present. However, a conservation area appraisal, which is frequently an invaluable source of information for understanding the key features and sensitivities protected by this designation, has not been prepared for this conservation area. Appraisals take a substantial amount of resources and time, so progress is gradual and it is therefore uncertain when a conservation area appraisal for Felmersham and Radwell will be complete. Locally Important Heritage Features
It should be noted that not all the area’s historic environment features are subject to statutory designations, and non-designated features comprise a large part of what people have contact with as part of daily life – whether at home, work or leisure. Although not designated, many buildings and areas are of historic interest and are important by local communities. For example, open spaces and key distinctive buildings in the area are likely to be of value for local people.
Following a high-level review of the Historic Environmental Record (HER) for Bedfordshire (accessed via the Heritage Gateway)42, there are 133 records within Felmersham Parish including a variety of structures and archaeological finds such as: ring-ditches, prehistoric/Romano British enclosure cropmarks and Iron Age/Romano cemeteries and settlements. Summary of Future Baseline New development areas in the Neighbourhood Plan area have the potential to impact on the fabric and setting of heritage assets; for example, through inappropriate design and layout. It should be noted, however, that existing historic environment designations offer a degree of protection to heritage assets and their settings.
Alongside, new development need not be harmful to the significance of a heritage asset, and in the context of the Neighbourhood Plan area there may be opportunity for new development to enhance the historic setting of the village and better reveal assets’ heritage significance.
41 Historic England (2019): ‘Conservation Areas’, [online] available at:
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A5 – Landscape Context Review Key messages from the National Planning Policy Framework (NPPF) include:
• ‘Great weight should be given to conserving and enhancing landscape and scenic beauty in National Parks, the Broads and Areas of Outstanding Natural Beauty […]. The conservation and enhancement of wildlife and cultural heritage are also important considerations in these areas and should be given great weight in National Parks and the Broads. The scale and extent of development within these designated areas should be limited.’ • Strategic policies should set out an overall strategy making provision for ‘conservation and enhancement of the natural, built and historic environment, including landscapes and green infrastructure.’ • Planning policies and decisions should ensure that developments ‘are sympathetic to local character and history, including the surrounding built environment and landscape setting, while not preventing or discouraging appropriate innovation of change (such as increased densities).’ • ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: i. protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils ii. recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland; and iii. remediating and mitigating despoiled, degraded, derelict, contaminated and unstable land, where appropriate.’ At the local level, policies in the Bedford Borough Local Plan 2030 that relate to the Landscape SEA theme include:
• 38: Landscape character; • 39: Landscaping in new development; • 40: Retention of trees; • 41: Hedgerows; • 46: Local Green Space; and • 54: Development layout and accessibility. Summary of Current Baseline National character areas
The Felmersham and Radwell Neighbourhood Plan area lies within the Bedfordshire and Cambridgeshire Claylands National Character Area (NCA).
The Bedfordshire and Cambridgeshire Claylands NCA43 covers most of north and mid Bedfordshire and western Cambridgeshire, and part of east Buckinghamshire and Northamptonshire. The underlying clay geology (shared with the adjacent Upper Thames Clay Vales NCA in the southwest) gives a gently undulating topography that is divided by broad, shallow river valleys that gradually widen as they approach The Fens NCA in the east. These lower-lying claylands completely enclose the Bedfordshire Greensand Ridge NCA. A distinct boundary exists in the east where the Bedfordshire and Cambridgeshire Claylands NCA meets The Fens NCA and to the south where it meets both the elevated East Anglian Chalk NCA and Chilterns NCA. There is more of a gradual transition towards the Upper Thames Clay Vales NCA and Midvale Ridge NCA in the south-west,
43 Natural England (2014) NCA Profile: 88 Bedfordshire and Cambridgeshire Claylands [online] available at: http://publications.naturalengland.org.uk/publication/6667269664931840 [accessed 08/01/20]
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Yardley Whittlewood Ridge NCA to the north, and Northamptonshire Vales NCA and Leicestershire Vales NCA in the north-west where the River Nene marks the boundary. Key characteristics of the Bedfordshire and Cambridgeshire Claylands NCA include:
• Underlying geology of Jurassic and Cretaceous clays overlain by more recent Quaternary glacial deposits of chalky boulder clay (till) and sand and gravel river terrace deposits within the river valleys. Limerich, loamy and clayey soils with impeded drainage predominate, with better-drained soils in the river valleys. • Variable, scattered woodland cover comprising smaller plantations, secondary woodland, pollarded willows and poplar along river valleys, and clusters of ancient woodland, particularly on higher ground to the northwest representing remnant ancient deer parks and Royal Hunting Forests. • Predominantly open, arable landscape of planned and regular fields bounded by open ditches and trimmed, often species-poor hedgerows which contrast with those fields that are irregular and piecemeal. • Wide variety of semi-natural habitats supporting a range of species – some notably rare and scarce – including sites designated for species associated with ancient woodland, wetland sites important for birds, great crested newt and species of stonewort, and traditional orchards and unimproved grassland supporting a rich diversity of wild flowers. • Rich geological and archaeological history evident in fossils, medieval earthworks, deserted villages and Roman roads. A number of historic parklands, designed landscapes and country houses – including Stowe House and Park, Kimbolton Park, Croxton Park, Wimpole Hall and Wrest Park – combine with Bletchley Park, Second World War airfields, the Cardington Airship Hangars and brickfields to provide a strong sense of history and place. • Diversity of building materials including brick, render, thatch and stone. Locally quarried limestone features in villages such as Lavendon, Harrold and Turvey on the upper stretches of the River Great Ouse. • Settlements cluster around major road and rail corridors, with smaller towns, villages and linear settlements widely dispersed throughout, giving a more rural feel. Small villages are usually nucleated around a church or village green, while fen-edge villages are often in a linear form along roads. • Major transport routes cross the area, including the M1, M11, A1, A6, A5 and A14 roads, the East Coast and Midlands mainline railways, and the Grand Union Canal. • Recreational assets include Grafham Water, the Grand Union Canal, Forest of Marston Vale Community Forest, Chilterns AONB, woodland and wetland sites, an extensive rights-of-way network and two National Cycle Routes. The cities of Cambridge and Peterborough and several of the historic market towns in the NCA are popular tourist destinations. Bedford Borough Landscape Character Assessment
At the local level, the Bedford Borough Landscape Character Assessment44 characterises Bedford into six landscape types which are further subdivided into landscape character areas. In total there are 13 landscape character areas in Bedford Borough.
The Neighbourhood Plan area lies within two landscape character areas (2B: Pavenham Wooded Wolds and 3B: Oakley – Great Ouse Limestone Valley).
Pavenham Wooded Wolds landscape character area covers the south west part of the Neighbourhood Plan area. It is described as a sloping, gently undulating landscape founded on limestone, overlain by drift deposits of boulder clay at the higher elevations. Key characteristics of the landscape character include:
• Sloping landform founded on Oolithic Limestone with drift deposits of Boulder Clay at higher elevations.
44 LUC (2014) Bedford Borough Landscape Character Assessment [online] available at: < http://www.forms.bedford.gov.uk/planning/BBCLCAFinal2014-11-28.pdf> [accessed 08/01/20]
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• Forms an intermediary landscape linking the flat floodplain of the River Great Ouse to the high ground of the Cranfield to Stagsden Clay Farmland (1a). • Small to medium scale landscape with an enclosed, peaceful character. • Land use characterised by arable farming, with pastoral landscapes being particularly associated with the historic parkland around Turvey House and Turvey Abbey. • Medium scale geometric fields are enclosed by dense hedgerows while limestone walls form the boundaries of gardens and historic estates. • Settlement consists of scattered farmsteads, hamlets and villages built mainly of limestone, tall church spires form distinctive landmarks. • Rural roads, often with wide grass verges, skirt the lower slopes at the edges of the adjacent valley landscape. The overall landscape strategy for the Pavenham Wooded Wold character area is to conserve the rural landscape of rolling arable farmland with its largely intact hedgerow network, its limestone villages and farmsteads, and historic parklands and earthworks, and woodlands of high biodiversity value while enhancing elements of the landscape which are in declining condition such as some section of hedgerows.
Landscape management guidelines for the Pavenham Wooded Wold character area include:
• Encourage the planting or regeneration of new broad-leaved woodland, in particular adjacent to and linking existing ancient woodland in the area and respecting the grain of the historic landscape. • Conserve and enhance the field patterns. • Enhance the hedgerow network, replanting hedgerows and hedgerow trees where necessary. • Safeguard the surviving fields of ridge and furrow, and the setting of the ancient monuments. • Ensure all ancient semi-natural woodland in the area receives appropriate management to conserve and enhance its biodiversity interest. Development guidelines for the Pavenham Wooded Wold character area include:
• Conserve the historic cores of the limestone villages, encouraging any new development to adopt the vernacular style of buildings and materials. • Conserve the historic form of scattered ‘Ends’ at Pavenham avoiding further merging of these through linear development along roads. • Conserve the views to the church towers. • Conserve the largely unsettled slopes above the Great Ouse Valley that form a rural backdrop to this lower lying, more settled landscape. Oakley- Great Ouse Limestone valley landscape character area covers the north east part of the Neighbourhood Plan area. It is described as a shallow valley founded on Oolitic Limestone, with Alluvium along the course of the river and Valley Gravel on the level valley floor. Key characteristics of the landscape character include:
• Wide, open, shallow valley founded on Oolitic Limestone, with Alluvium along the course of the river and Valley Gravel on the level valley floor. • The River Great Ouse meanders through the valley in wide loops lined by wetland vegetation including poplar and willow. • A landscape with a mixed land-use of arable farmland on the higher ground and pasture (grazed by sheep and cattle) on the valley floor. • Medium scale geometric fields are enclosed by hedgerows with some hedgerow trees although in some areas the hedgerows have been replaced by fences.
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• The sloping valley sides of the Hinwick and Pavenham Wooded Wolds provide a sense of enclosure and rural backdrop, particularly to the north of the area. The overall landscape strategy for the Oakley – Great Ouse Limestone Valley character area is to conserve the historic limestone villages the riverside features such as stone bridges and mills and the tranquil river corridor flaked by woodland belts. Elements to be enhanced would be the field boundaries where these are in poor condition or lost, the management/restoration of the riverside pastures/grassland and wetland vegetation for biodiversity and the integration of recent development with the surrounding rural landscape for instance through creation of new elements including wet woodland and river valley flood meadows. Such enhancement should also seek to contribute to cross country GI objectives for the Ouse (working with Buckinghamshire and Milton Keynes Natural Environment Partnership).
Landscape management guidelines for the Oakley – Great Ouse Limestone Valley character area include:
• Conserve, enhance and create areas of floodplain landscape with flood meadows and marshes where appropriate (reversion of arable farmland may be an opportunity) • Conserve and enhance the riparian vegetation that defines the course of the River Great Ouse, with opportunities for enhanced habitat management and restoration. • Conserve the hedgerow and hedgerow trees, enhancing the network where hedgerow has become degraded or damaged. • Conserve the ecological integrity of the SSSI sites- and manage recreation within these areas. • Conserve the rural character of the network of minor roads, discourage the introduction of suburban style materials e.g. kerbs and extensive lighting. Development guidelines for the Oakley – Great Ouse Limestone Valley character area include:
• Conserve the nucleated stone built villages and avoid linear extension along roads which may threaten the individual identify of the villages, • Improve settlement edges to maintain separation between settlements or where edges form an unsympathetic relationship with the open countryside- planting of floodplain woodland is a key opportunity. • Conserve the natural floodplain to landform and long views- avoid further introduction of embankments in the landscape which interrupt the landform and restrict views. • Consider views to church towers. Tree preservation orders
Implemented by local planning authorities, Tree Preservation Orders (TPOs) are designated to protect specific trees, groups of trees or woodlands in the interests of their amenity value. When considering ‘amenity’; the local planning authority will likely take into consideration the following criteria45:
• Visibility: the extent to which the trees or woodlands can be seen by the public; and • Individual, collective and wider impact: considering the importance of the trees or woodlands in relation to their cultural or historic value, contribution to and relationship with the landscape and/or their contribution to the character or appearance of a conservation area. In this context, Bedford Borough Council have allocated several TPOs within the Neighbourhood Plan area46.
45 GOV.UK (2014): ‘Tree Preservation Orders – General’, [online] available a:t
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Summary of Future Baseline New development has the potential to lead to incremental but small changes in landscape and villagescape character and quality in and around the Neighbourhood Plan area.
Inappropriate levels of development within the open countryside could negatively impact upon the landscape features which contribute to the distinctive character of Felmersham and Radwell. A6 – Land, Soil and Water Resources Context Review The EU’s Soil Thematic Strategy47 presents a strategy for protecting soil resources in Europe. The main aim of the strategy is to minimise soil degradation and limit associated detrimental effects linked to water quality and quantity, human health, climate change, biodiversity, and food safety.
Adopted in October 2000, the purpose of the EU Water Framework Directive (WFD) is to establish a framework for the protection of inland surface waters, transitional waters, coastal waters and groundwater, driving a catchment-based approach to water management. In England and Wales there are 100 water catchments and it is Defra’s intention is to establish a ‘framework for integrated catchment management’ across England. The Environment Agency is establishing ‘Significant Water Management Issues’ and recently presented second River Basin Management Plans to ministers. The plans seek to deliver the objectives of the WFD namely:
• Enhance the status and prevent the further deterioration of aquatic ecosystems and associated wetlands which depend on aquatic ecosystems; • Promote the sustainable use of water; • Reduce the pollution of water, especially by ‘priority’ and ‘priority hazardous’ substances; • Ensure the progressive reduction of groundwater pollution; and • Contribute to achieving ‘good’ water quality status for as many waterbodies as possible by 2027. Key messages from the NPPF include:
• ‘Planning policies and decisions should contribute to and enhance the natural and local environment by: i. protecting and enhancing valued landscapes, sites of biodiversity or geological value and soils; and ii. recognising the intrinsic character and beauty of the countryside, and the wider benefits from natural capital and ecosystem services – including the economic and other benefits of the best and most versatile agricultural land, and of trees and woodland.’ • Prevent new or existing development from being ‘adversely affected’ by the presence of ‘unacceptable levels’ of soil pollution or land instability and be willing to remediate and mitigate ‘despoiled, degraded, derelict, contaminated and unstable land, where appropriate’. • ‘Planning policies and decisions should promote an effective use of land in meeting the need for homes and other uses, while safeguarding and improving the environment and ensuring safe and healthy living conditions. Strategic policies should set out a clear strategy for accommodating objectively assessed needs, in a way that makes as much use as possible of previously- developed or ‘brownfield’ land.’ • ‘Encourage multiple benefits from both urban and rural land, including through mixed use schemes and taking opportunities to achieve net environmental gains.’ • Planning policies and decisions should ‘give substantial weight to the value of using suitable brownfield land within settlements for homes and other identified needs’, and ‘promote and support the development of under-utilised land and buildings.’
47 European Commission (2006) Soil Thematic Policy [online] available at:
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• Taking a proactive approach to mitigating and adapting to climate change, taking into account the long-term implications for water supply. • Prevent new and existing development from contributing to, being put at unacceptable risk from, or being adversely affected by unacceptable levels of water pollution. • The government has produced a separate plan that specifically deals with planning policy in relation to waste management; this should be read in conjunction with the NPPF. Along with the policies contained within Chapter 1 ‘Using and managing land sustainably’ and Chapter 4 ‘Increasing resource efficiency, and reducing pollution and waste’, Goal 2 ‘Clean and plentiful water’, Goal 5 ‘Using resources from nature more sustainably and efficiently’ and Goal 8 ‘Minimising waste’ of the Government’s ‘A Green Future: Our 25 Year Plan to Improve the Environment’ directly relates to the Land, Soil and Water Resources SEA theme.
Other key documents at the national level include Safeguarding our Soils: A Strategy for England48, which sets out a vision for soil use in England, and the Water White Paper49, which sets out the Government’s vision for a more resilient water sector. It states the measures that will be taken to tackle issues such as poorly performing ecosystems, and the combined impacts of climate change and population growth on stressed water resources. In terms of waste management, the Government Review of Waste Policy in England50 recognises that environmental benefits and economic growth can be the result of a more sustainable approach to the use of materials.
In terms of waste management, the Government Review of Waste Policy in England51 recognises that environmental benefits and economic growth can be the result of a more sustainable approach to the use of materials.
The National Waste Management Plan52 provides an analysis of the current waste management situation in England and evaluates how it will support the implementation of the objectives and provisions of the revised Waste Framework Directive53. This includes an assessment of the need for new collection schemes, additional waste infrastructure and investment channels, as well as providing general or strategic waste management policies.
At the local level, policies in the Bedford Borough Local Plan 2030 that relate to the Land, Soil and Water Resources SEA theme include:
• 47S: Use of previously developed land and undeveloped land; • 48: Pollution, disturbance and contaminated land; • 49: Minerals and waste restoration policy; • 50: Waste; • 51S: Water Resources; • 53 Water demand; and • 97: Sustainable drainage system (SuDS).
48 Defra (2009) Safeguarding our Soils: A strategy for England [online] available at:
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Summary of Current Baseline Soil resources
The Agricultural Land Classification (ALC) classifies land into size grades (plus ‘non-agricultural land’ and ‘urban’), where Grades 1 to 3a are recognised as being the ‘best and most versatile’ land and Grades 3b to 5 of poorer quality. In this context, there is a need to avoid loss of higher quality ‘best and most versatile’ agricultural land.
At the local level a detailed classification has only been undertaken for a small part of the Neighbourhood Plan area south of Felmersham. This shows that the land is predominantly Grade 3a with a small patch of land that is classified as Grade 2 and Grade 3b. As only a small part of the Neighbourhood Plan area has had a detailed classification, there is a need to rely on the national ‘Provisional Agricultural Land Quality’ dataset.
The Provisional Agricultural Land Quality dataset54 shows that the Neighbourhood Plan area is predominantly covered by areas of Grade 3 agricultural land with a smaller area of Grade 2 agricultural land along the southern boundary. Without the subset grading (3a or 3b) it is not possible to tell at this stage whether the Grade 3 agricultural land is considered to be ‘best and most versatile’. It is also important to note that the national dataset is of very low resolution and may not necessarily provide an accurate reflection of the agricultural land quality within the Neighbourhood Plan area. Water resources
The main watercourse flowing through the Neighbourhood Plan area is the River Great Ouse which flows around the parish in a horseshoe curve before flowing past Bedford, Huntingdon and eventually joining the North Sea at the Wash.
The Nitrates Directive (91/676/EEC) requires Member States to identify areas where groundwater have nitrate concentrations of more than 50 mg/l nitrate or are thought to be at risk of nitrate contamination. Areas associated with such groundwater are designated as Nitrate Vulnerable Zones (NVZs) within which, Member States are required to establish Action Programmes to reduce and prevent further nitrate contamination. In this regard, the entire Neighbourhood Plan area overlaps with the ‘Great Ouse’ NVZ.
Groundwater Source Protection Zones (SPZs) have been defined by the Environment Agency in England and Wales to protect groundwater sources such as wells, boreholes and springs that are used for public drinking water supply. The zones show the risk of contamination from activities that might cause groundwater pollution in the area. Within the Neighbourhood Plan area, the centre and western corner are within groundwater SPZ3 (Total Catchment). Water quality
Felmersham and Radwell is located within the Anglian River Basin District, overlapping with the ‘Ouse Upper and Bedford’ Management Catchment. There are five water bodies within the Operational Catchment.
Based on the most recently completed water quality assessments undertaken in 2016, the Environment Agency’s Catchment Data Explorer55 classifies Ouse (Newport Pagnell to Roxton)56 as having a ‘good’ chemical status and ‘moderate’ ecological status. The overall classification for the waterbody in 2016 was ‘moderate’. Summary of Future Baseline Future development has the potential to affect water quality through diffuse pollution, wastewater discharges, water run-off, and modification. However, water companies are likely to maintain adequate water supply and wastewater management over the plan period, and the requirements of
54 Natural England (2018) Agricultural Land Classification map London and the South East (ALC007) [online] available at < http://publications.naturalengland.org.uk/publication/141047?category=5954148537204736> [accessed 08/01/20] 55 Environment Agency (2020): ‘Catchment Data Explorer’, [online] available to access via:
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the Water Framework Directive (and its successor) are likely to lead to continued improvements to water quality within the Neighbourhood Plan area and wider area.
In the absence of a detailed Agricultural Land Classification assessment for the majority of the Parish, it remains uncertain whether new development on greenfield land in the Neighbourhood Plan area will lead to losses of higher quality (best and most versatile) agricultural land. A7 – Population and Community Context Review Key messages from the NPPF include:
• One of the three overarching objectives of the NPPF is a social objective to; ‘support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well- designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural wellbeing.’ • To support the Government’s objective of significantly boosting the supply of housing, strategic policies ‘should be informed by a local housing need assessment, conducted using the standard method in national planning guidance. In addition to the local housing need figure, any needs that cannot be met within neighbouring areas should also be taken into account in establishing the amount of housing to be planned for.’ • The size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies. Where a need for affordable housing is identified, planning policies should specify the type of affordable housing required, and expect it to be met on-site where possible. • Recognise the important contribution of small and medium sized development sites in meeting housing needs. Local Plans should identify land to accommodate at least 10% of their housing requirement on sites no larger than one hectare, and neighbourhood planning groups should also consider the opportunities for allocating small and medium-sized sites. • In rural areas, planning policies and decisions should be responsive to local circumstances and plan housing development to reflect local needs, particularly for affordable housing, including through rural exception sites where appropriate. Authorities should consider whether allowing some market housing would facilitate the provision of affordable housing to meet local needs. • Promote the retention and development of local services and community facilities such as local shops, meeting places, sports venues, open space, cultural buildings, public houses and places of worship. • Ensure that developments create safe and accessible environments where crime and disorder, and the fear of crime, do not undermine quality of life or community cohesion. Places should contain clear and legible pedestrian routes, and high-quality public spaces, which encourage the active and continual use of public areas. • Ensuring that there is a ‘sufficient choice of school places’ and taking a ‘proactive, positive and collaborative approach’ to bringing forward ‘development that will widen choice in education’. The ‘Ready for Ageing?’ report, published by the Select Committee on Public Service and Demographic Change57 warns that society is underprepared for an ageing population. The report states that ‘longer lives can be a great benefit, but there has been a collective failure to address the implications and without urgent action this great boon could turn into a series of miserable crises’. The report recognises that the supply of specialist housing for the older generation is insufficient for the demand. There is a need for central and local Government, housing associations, and house builders to ensure that these housing needs are better addressed, giving as much priority to
57 Select Committee on Public Service and Demographic Change (2013) Ready for Ageing? [online] available at:
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promoting an adequate market of social housing for the older generation as is given to the younger generation.
At the local level, policies from Chapter 6 (Strategy), Chapter 10 (Housing), Chapter 11 (Economy), Chapter 12 (Plan implementation and infrastructure development) as well as other policies including 101 (New sports and leisure facilities) and 102 (New community facilities) in the Bedford Borough Local Plan 2030 relate to the Population and Community theme. Summary of Current Baseline Population
The population of Felmersham increased by 1.5% between 2001 and 2011, lower than the increases for Bedford, the East of England and England averages58. Age structure
Generally, there are a higher proportion of residents within the 60+ age category within the Neighbourhood Plan area (26.9%) in comparison to the total for Bedford (21.7%), the East of England (23.9%) and England (22.3%)59.
A similar proportion of residents are within the working age categories (25-44 and 45-59) in the Neighbourhood Plan area (46.5%) in comparison to the totals for Bedford (46.9%), the East of England (46.2%) and England (46.9%).
Additionally, 26.6% of residents within the Neighbourhood Plan area are within the younger age categories (0-15 and 16-24), lower than the total for Bedford (31.4%), the East of England (29.9%) and England (30.8%). Household deprivation
Census statistics measure deprivation across four ‘dimensions’ of deprivation, summarized below:
• Employment: Any person in the household (not a full-time student) that is either unemployed or long-term sick. • Education: No person in the household has at least a level 2 qualification and no person aged 16-18 is a full-time student. • Health and Disability: Any person in the household that has generally ‘bad’ or ‘very bad’ health or has a long term health problem. • Housing: The household accommodation is either overcrowded (with an occupancy rating of -1 or less), in a shared dwelling or has no central heating. In this respect, fewer households are deprived in one or more dimensions within the Neighbourhood Plan area (35.2%) in comparison to the totals for Bedford (54.5%), the East of England (55.2%) and England (57.5%). Out of the 35.2% of households which are deprived in the Neighbourhood Plan area, the majority are deprived in one or two dimensions, which is similar to the regional and national trends60. Index of Multiple Deprivation
The Index of Multiple Deprivation 2019 (IMD) is an overall relative measure of deprivation constructed by combining seven domains of deprivation according to their respective weights, as described below. The seven deprivation domains are as follows:
• Income: The proportion of the population experiencing deprivation relating to low income, including those individuals that are out-of-work and those that are in work but who have low earnings (satisfying the respective means tests).
58 ONS (no date): Census 2011: Population Density 2011 (Table QS102EW); Population Density 2001 (Table UV02) 59 ONS (no date): Census 2011: Age Structure 2011 (Table KS102EW) 60 ONS (no date): Census 2011: ‘Households by Deprivation Dimensions 2011 (Table QS119EW)
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• Employment: The proportion of the working-age population in an area involuntarily excluded from the labour market, including those individuals who would like to work but are unable to do so due to unemployment, sickness or disability, or caring responsibilities. • Education, Skills and Training: The lack of attainment and skills in the local population. • Health Deprivation and Disability: The risk of premature death and the impairment of quality of life through poor physical or mental health. Morbidity, disability and premature mortality are also considered, excluding the aspects of behaviour or environment that may be predictive of future health deprivation. • Crime: The risk of personal and material victimisation at local level. • Barriers to Housing and Services: The physical and financial accessibility of housing and local services, with indicators categorised in two sub-domains. a. ‘Geographical Barriers’: relating to the physical proximity of local services b. ‘Wider Barriers’: relating to access to housing, such as affordability. • Living Environment: The quality of the local environment, with indicators falling categorised in two sub-domains. c. ‘Indoors Living Environment’ measures the quality of housing. d. ‘Outdoors Living Environment’ measures air quality and road traffic accidents. • Two supplementary indices (subsets of the Income deprivation domains), are also included: 1. Income Deprivation Affecting Children Index: The proportion of all children aged 0 to 15 living in income deprived families. 2. Income Deprivation Affecting Older People Index: The proportion of all those aged 60 or over who experience income deprivation. Lower Super Output Areas (LSOAs) 61 are a geographic hierarchy designed to improve the reporting of small area statistics in England and Wales. They are standardized geographies designed to be as consistent in population as possible, with each LSOA containing approximately 1,000 to 1,500 people. In relation to the IMD 2019, LSOAs are ranked out of the 32,844 in England and Wales, with 1 being the most deprived. Ranks are normalized into deciles, with a value of 1 reflecting the top 10% most deprived LSOAs in England and Wales. The Neighbourhood Plan area is within one LSOA (Bedford 002A). Bedford 002A is within the 40% least deprived areas within England. Housing Tenure
Within the Neighbourhood Plan area, 87.6% of residents either own their home outright or with a mortgage, higher than the totals for Bedford (65.7%), the East of England (67.6%) and England (63.3%).
A lower proportion of residents live within privately rented and social rented housing in the Neighbourhood Plan area in comparison to the regional and national figures.
A lower percentage of residents in the Neighbourhood Plan area also live in rent-free accommodation or shared ownership accommodation in comparison to the regional and national trends62. Education
Based on the 2011 census data, 9.8% of residents in the Neighbourhood Plan area have no qualifications, lower than the totals for Bedford (20.4%), the East of England (22.5%) and England (20.7%).
61 DCLG (2019): Indices of Deprivation Explorer’, [online] available at: < https://dclgapps.communities.gov.uk/imd/iod_index.html> [accessed 12/12/19] 62 ONS (no date): Census 2011: Tenure-Households 2011 (Table QS405EW)
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Comparatively, 44.7% of residents within the Neighbourhood Plan area have a Level 4 qualification or above, which is greater than the total for Bedford (28.1%), the East of England (25.7%) and England (27.4%)63. Employment
Regarding employment within the Neighbourhood Plan area, the following three occupation categories support the most residents64:
• Professional occupations (23.4%); • Associate professionals and technical occupations (16.6%); and • Managers, directors, senior officials (16.1%). Overall, 56.1% of residents within the Neighbourhood Plan area are employed in one of the above three occupation categories, greater than the total for Bedford (41.3%), the East of England (50%) and England (41.2%). Community assets
The Neighbourhood Plan area has a range of local community facilities which serve the needs of the local community and play a vital role in supporting the Parish’s sense of identity. Such facilities include: Pinchmill Primary School and Village Hall, Pinchmill Pre-School the Church of St Mary and one pub (The Sun). However, the Neighbourhood Plan area has no shops or a Post Office. The nearest shops are in Sharnbrook approximately 1.7km from the Neighbourhood Plan area.
As discussed on the Felmersham website65, there are many social events in the Parish, including an annual Summer Fair, the Boxing Day walk, an annual show, Carol Service, a dawn chorus meet, a sunflower competition, annual litter pick and concerts. Pinchmill Hall committee room is host to a very active WI group, a Thursday Club for senior citizens, and clubs such as patchwork quilting, bridge, art and flower arranging. For girls, there is a Brownies Group. Felmersham Village Cricket Club is now based in Pavenham. The Parish has an active, well-supported Parish Paths Partnership (P3) group, a voluntary group set up and supported by Bedfordshire County Council and the Parish Council. Summary of Future Baseline As the population of the Neighbourhood Plan area continues to age, this could potentially negatively impact upon the future vitality of the local community and economy of certain parts of the Neighbourhood Plan area, whilst also placing additional pressures to existing services and facilities. The suitability (e.g. size and design) and affordability of housing for local requirements depends on the implementation of appropriate housing policies through the Local Plan and Neighbourhood Plan. Unplanned development may have wider implications in terms of transport and access to infrastructure, or the natural environment. New allocations through the Bedford Borough Local Plan 2030 is likely to place pressure on local services, facilities and amenities. A8 – Health and Wellbeing Context Review Key messages from the NPPF include:
• One of the three overarching objectives of the NPPF is a social objective to; ‘support strong, vibrant and healthy communities, by ensuring that a sufficient number and range of homes can be provided to meet the needs of present and future generations; and by fostering a well- designed and safe built environment, with accessible services and open spaces that reflect current and future needs and support communities’ health, social and cultural wellbeing.‘ • ‘Planning policies and decisions should aim to achieve healthy, inclusive and safe places which enable and support healthy lifestyles, especially where this would address identified local health
63 ONS (no date): Census 2011: Highest Level of Qualification 2011 (Table QS501EW) 64 ONS (no date): Census 2011: ‘Occupation 2011’ (Table KS608EW) 65 Felmersham (2006) The Felmersham & Radwell Parish Plan [online] available at:
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and wellbeing needs – for example through the provision of safe and accessible green infrastructure, sports facilities, local shops, access to healthier food, allotments and layouts that encourage walking and cycling.’ • Policies and decisions should take into account and support the delivery of local strategies to improve health, social and cultural well-being for all sections of the community. • Access to a network of high-quality open spaces and opportunities for sport and physical activity is important for the health and wellbeing of communities. Development should avoid building on existing open space, sports and recreational buildings and land, including playing fields. • Promote the retention and development of local services and community facilities such as local shops, meeting places, sports venues, cultural buildings, public houses and places of worship. In relation to other key national messages in relation to health, Fair Society, Healthy Lives66 (‘The Marmot Review’) investigated health inequalities in England and the actions needed in order to tackle them. Subsequently, a supplementary report was prepared providing additional evidence relating to spatial planning and health on the basis that that there is: “overwhelming evidence that health and environmental inequalities are inexorably linked and that poor environments contribute significantly to poor health and health inequalities”.
The increasing role that local level authorities are expected to play in providing health outcomes is demonstrated by recent government legislation. The Health and Social Care Act 2012 transferred responsibility for public health from the NHS to local government, giving local authorities a duty to improve the health of the people who live in their areas. This will require a more holistic approach to health across all local government functions.
At the local level, policies from the Bedford Borough Local Plan 2030 which relate to the Health and Wellbeing theme include:
• 1S: Healthy Communities; • 46: Local Green Space; and • 101: New sports and leisure facilities. Summary of Current Baseline Joint Strategic Needs Assessment
The Joint Strategic Needs Assessment (JSNA) for Bedford Borough67 provides an indication of the health and wellbeing of the people living there. It outlines that the average life expectancy in Bedford Borough is 79.9 years for men and 83.2 years for women but there are large inequalities in life expectancy depending on where people are born. Public Health Profile for Bedford
Published in September 2016 by Public Health England, the public health profile for Bedford outlines the following key trends68:
• The health of people in Bedford is varied compared with the England average. About 17% (5,500) of children live in low income families. • Life expectancy for both men and women is higher than the England average. • In Year 6, 18.6% (325) of children are classified as obese.
66 The Marmot Review (2011) The Marmot Review: Implications for Spatial Planning [online] available to download from: < https://www.nice.org.uk/media/default/About/what-we-do/NICE-guidance/NICE-guidelines/Public-health-guidelines/Additional- publications/Spatial-planning/the-marmot-review-implications-for-spatial-planning.pdf > [accessed 09/01/20] 67 JNSA (2019) Joint Strategic Needs Assessment Summary for Bedford Borough [online] available to access at:
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Health indicators and deprivation Deprivation is a significant contributor to poor health and can have adverse effects on wellbeing, with elements related to poor housing quality, living environment, income and employment previously discussed in detail in the Population and Community theme. 87.6% of residents in the Neighbourhood Plan area consider themselves as having ‘very good health’ or ‘good health’, greater than the totals for Bedford (82.9%), the East of England (82.5%) and England (81.4%)69.
Additionally, 2.3% of residents in the Neighbourhood Plan area consider themselves to have ‘bad health’ or ‘very bad health’, lower than the totals for Bedford (4.5%), the East of England (4.7%) and England (5.4%).
The total percentage of residents within the Neighbourhood Plan area who report that their activities are limited ‘a lot’ is less than the totals for Bedford, the East of England and England70.
89.7% of residents in the Neighbourhood Plan area confirm that their activities are ‘not limited’. This is similar to greater than the totals for Bedford (84.0%) the East of England (83.3%) and England (82.4%). Summary of Future Baseline Health and wellbeing levels within the Neighbourhood Plan area are generally good, with a high percentage of residents reporting ‘good’ or ‘very good’ health, and a low percentage of residents reporting that their activities are limited in some way.
As the population continues to age, this has the potential to place pressures on the existing services and facilities within the timeframe of the Neighbourhood Plan. This could negatively impact on the future vitality of the local community and economy.
Obesity is also seen as an increasing issue by health professionals, and one that will contribute to significant health impacts on individuals, including increasing the risk of a range of diseases, including heart disease, diabetes and some forms of cancer. A9 – Transportation Context Review European and UK transport policies and plans place emphasis on the modernisation and sustainability of the transport network. Specific objectives include reducing pollution and road congestion through improvements to public transport, walking and cycling networks and reducing the need to travel. National policy also focuses on the need for the transport network to support sustainable economic growth.
Key messages from the NPPF include:
• ‘Transport issues should be considered from the earliest stages of plan-making and development proposals, so that: i. The potential impacts of development on transport networks can be addressed ii. Opportunities from existing or proposed transport infrastructure, and changing transport technology and usage, are realised iii. Opportunities to promote walking, cycling and public transport use are identified and pursued iv. The environmental impacts of traffic and transport infrastructure can be identified, assessed and taken into account v. Patterns of movement, streets, parking and other transport considerations are integral to the design of schemes, and contribute to making high quality places.’
69 ONS (no date): Census 2011: ‘General Health 2011’ (Table QS302EW) 70 ONS (no date): Census 2011: ‘Long-term Health Problem or Disability 2011’ (Table QS303EW)
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• ‘Significant development should be focused on locations which are or can be made sustainable, through limiting the need to travel and offering a genuine choice of transport modes. This can help to reduce congestion and emissions, and improve air quality and public health. However, opportunities to maximise sustainable transport solutions will vary between urban and rural areas, and this should be taken into account in both plan-making and decision-making.’ At the local level, each Local Transport Authority in England and Wales has a statutory duty to produce and adopt a Local Transport Plan through the Local Transport Act 2000, as amended by the Local Transport Act 2008.71 The Bedford Local Transport Plan 2011-202172 has a vision ‘to create a transport system in which walking, cycling and public transport are the natural choices of travel for the majority of journeys because they are affordable, healthy, convenient and safe alternatives to the private car’.
The Local Transport Plan has five goals which are:
• A strong local economy, delivering high levels of sustainable growth and employment for the benefit of the Borough’s existing and future resident; • A natural environment which is valued and enjoyed by all; which encourages biodiversity, reduces emissions and contributes to the development of a low carbon community capable of adapting to the impacts of climate change; • Equal access to opportunities for all residents; • A Borough where people live safer (and healthier) lives; and • A healthy natural (and built) environment, which is valued and enjoyed by all, and people feel part of the wider community. At the local level, policies from the Bedford Borough Local Plan 2030 which relate to the Transportation theme include:
• 91: Public transport; • 92: Impact of transport on people, places and environment; and • 94S: Transport infrastructure and network improvements. Summary of Current Baseline Rail network
The Neighbourhood Plan area is not directly connected to the rail network, with no stations located within its boundaries. The nearest railway station to the Neighbourhood Plan area is Bedford (approximately 7.9km south east of the Neighbourhood Plan area). Bedford railway station is on the Midland main line and provides services from London St Pancras to the East Midlands. It is also the terminus of the Marston Vale line which provides services from Bletchley through Bedford St Johns.
Bus network
Regarding the local bus network, the Neighbourhood Plan area has four bus services running from two bus stops in Felmersham and two bus stops in Radwell.
The 50 provides a service between Kettering and Bedford (and return) and has hourly services with reduced services on Sundays. However, the 29 bus service runs just once a week (on Thursdays) between Pavenham and St Neots (and return). The 825 is a school bus providing a return service for students at Sharnbrook Academy.
Additionally, there is a Villager Bus which is one of Bedfordshire’s local community minibus schemes. It is managed and driven by volunteers and serves most of the villages in North-West Bedfordshire. On the second Tuesday of every month, there is a return service to Milton Keynes. On the second Friday of every month there is a return service to Peterborough. On the third money of every month
71 Local Transport Act 2008 [online] available at: http://www.legislation.gov.uk/ukpga/2008/26/contents [accessed 09/01/20] 72 Bedford Borough Council (2011) Local Transport Plan 2011-2021 [online] available at:
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there is a return service to St Ives. On Thursdays there is also a return service to Sharnbrook/ Carlton. The Villager Bus is also available for hire (with or without a driver). Road network and congestion
The Neighbourhood Plan area is relatively well connected to the wider road network with access from village roads onto the A6. The A6 provides a route south to Bedford where it connects to other A roads which provide routes to Northampton, Cambridge, Milton Keynes and Luton. Cycle and footpath network
In terms of the National Cycle Network, there are no routes which pass through the Neighbourhood Plan area. National Cycle Network73 Route 51 lies approximately 7.5km south east of the Neighbourhood Plan area in Bedford.
The parish also has a well-developed public rights of way network. Availability of cars and vans
Based on 2011 census data, 96.3% of households in the Neighbourhood Plan area have access to at least one car or van, which is greater than the totals for Bedford (79.4%), the East of England (81.5%) and England (74.2%). Travel to work
The most popular method of travelling to work in the Neighbourhood Plan area is via driving a car or van (49.7%) which is higher than the totals for Bedford (42.2%), the East of England (41.4%) and England (37.0%). 8.1% of residents in the Neighbourhood Plan area either catch a train, bus, minibus, coach or walk to work. This is lower than the percentage for Bedford (13%), the East of England (14.1%) and England (15.0%). Summary of Future Baseline New development has the potential to increase traffic and lead to additional congestion issues within the Neighbourhood Plan area.
Public transport use is likely to remain low compared with private car use. This is due to the relatively poor connectivity of the Neighbourhood Plan area via public transport.
There will be a continuing need for development to be situated in accessible locations which limit the need to travel by private car.
73 Sustrans (2019): ‘National Cycle Network Map’, [online] available at:
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aecom.com
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