Object

Representation ID: 9068

Received: 12/11/2021

Respondent: Colmworth Parish Council

Agent: Troy Planning + Design

10. Heritage
10.1. The Council’s evidence base in relation to Heritage is unsound and severely lacking particularly in relation to the fact that BBC has not prepared Heritage Impact Assessments on its options to comply with the NPPF and Historic England’s Advice Notes.

10.2. Chapter 16 of the NPPF places an emphasis on the need to conserve and enhance the historic environment. In the context of Bedford Borough, this sentiment is mirrored in the Bedford Borough Landscape Character Assessment (2020), which states that “it is important that the many opportunities for the enhancement of the borough’s historic environment, including its historic landscape character, are realised. Any adverse impacts on the historic environment arising from development should be minimised to avoid degradation. The historic environment provides character and identity to places, and a positive template for new development. It can play a key role in creating a ‘sense of place’ and identities as new communities are created and existing ones enhanced”. Despite this, the Draft Local Plan and its evidence base provide very little information relating to the historic environment. CPC is therefore concerned that the absence of historic information could result in the degradation of heritage assets.
10.3. The Bedford Borough Landscape Character Assessment refers to the Church of St Denys, Colmworth, as is states that “the spires of stone-built churches (such as St Denys at Colmworth) are landmarks in this fairly level, open plateaux landscape”. It is worth noting that the Church of St Denys is a Grade I listed church dating back to 1430.
10.4. The Figures below highlight the view from Honeydon Road to the Church of St Denys in relation to the site plan of the proposed Dennybrook scheme. As shown below, the western boundary of the proposed development would sit within the historic setting of the Church of St Denys. With this in mind, it is clear that the Regulation 18 Local Plan does not align with paragraph 195 of the NPPF, as the local planning authority has failed to assess the significance of the Church of St Deny that how it (and its surroundings) would be affected by a proposal.

INCLUDES FIGURE 10.1: VIEW CONE OF PHOTO AND PHOTO OF VIEW ON HONEYDON ROAD WITH THE DENNYBROOK SITE HIGHLIGHTED

10.5. In relation to the Dennybrook site and the impact on the Church of St Deny’s, the Wyboston Garden Village Heritage Impact Assessment (2021) states that “there are views to the Grade I listed Parish Church of St Denys at Colmworth from the western area of the Site (Plate 2), and distant views to the tower from parts of the central area of the Site. The use of open space in the western area of the Site as indicated in the Concept Masterplan would put built form over 1.5km east of the church. It would also avoid built form within the church’s historic parish (Colmworth). While there might be some loss of views to the spire from the wider area, it is not anticipated that this in itself would be sufficient to adversely impact the significance of the listed building.” This argument cannot be justified, as, in acknowledgement that key views to and from the Church of St Denys would be lost, the Wyboston Garden Village is in conflict with paragraph 130c) and d) of the NPPF, as it is clear that the Wyboston Garden Village proposal is not sympathetic to the surrounding built environment and will in fact erode the local area’s sense of place.
10.6. It is also worth noting that a recent appeal regarding 49 dwellings in a Suffolk village was partly dismissed on the grounds that the inspector deemed there to be a high impact on a manor house and two barns and a medium impact on a grade II* church. The Inspector felt that the public benefits of the development did not outweigh the harm to heritage assets and therefore this provided a clear reason for refusal in accordance with paragraph 11d) of the NPPF. Similar to the above, the Wyboston Garden Village Heritage Impact Assessment (2021) notes that the following Grade II listed buildings are within or immediately adjacent to the proposed site: “Dairy Farmhouse (1114114), at the northern edge of the Site, west of Honeydon; Chestnuts Farmhouse(4321615), at the northern edge of the Site on the southern side of Honeydon; Sudbury Farmhouse (1146461), within the central area of the Site; Eaton Tithe Farmhouse (1157864), within the eastern area of the Site; Moat Cottage (1146457)”. By applying clause b ii) of paragraph 11 of the NPPF, it is clear that the adverse impacts of the Wyboston Garden Village proposal would significantly and demonstrably outweigh the benefits of the proposal, and on that basis this site should not be considered for development.
10.7. Historic England has prepared a number of Advice Notes with its guidance on how authorities should approach heritage in the Local Plan and in their selection of potential sites including the potential impacts on heritage that might result from the proposals. There are two of these Advice Notes we would like to bring to the attention of BBC:
• The Historic Environment and Site Allocations in Local Plans (Historic England Advice Note 3) October 201543.
• Statements of Heritage Significance: Analysing Significance in Heritage Assets (Historic England Advice Note 12) October 2019
10.8. There is no evidence available in the Local Plan or its supporting documents that sets out how the Local Plan process has complied with the NPPF (and the Historic England guidance) in respect of heritage (including archaeological, architectural, artistic or historic, or a combination of these) in terms of considering which development options to select and then the need to assess the heritage impact from these proposals. At a minimum the Council should have undertaken the following staged approach as set out in Advice Note 12 (see paragraph 6):
1. Understand the form, materials and history of the affected heritage asset(s), and / or the nature and extent of the archaeological deposits
2. Understand the significance of the assets
3. Understand the impact of the proposal on that significance
4. Avoid, minimise, and mitigate negative impact, in a way that meets the objectives of the NPPF
5. Look for opportunities to better reveal or enhance significance

SEE OBJECTION TO SITE 977 DENNYBROOK FOR CONTEXT AND MORE INFORMATION