Object

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9671

Received: 26/07/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Whilst there are no designated heritage assets within HOU5, the site lies to the south-west of a very high concentration of heritage assets in Elstow - one of the key jewels in Bedford’s heritage crown.
Elstow is a distinct medieval settlement on the southern side of Bedford, separate from the main built up area and with its own distinct identity and character. This separation is important to its significance.
The setting of the Elstow Abbey in particular (comprising the Manor House Scheduled Monument, Grade I listed Hillersdon House, Grade I listed Church of St Mary and St Helena, and Grade I listed Church Tower) within the meadows, and views of the Abbey from the approach into Bedford along the A6 are important.
We welcome the preparation of an HIA for the site which considers both built heritage and archaeology but consider that it downplays the contribution made by the wider setting of Elstow Abbey to its heritage significance.
Although the significance of the heritage assets comprising Elstow Abbey are drawn primarily from their immediate setting and architectural, archaeological, historic interests, nonetheless their importance is enhanced by their landscape context and wider rural setting.
Elstow Abbey sits in a typical location for a monastery/nunnery. Monasteries and other religious institutions were reliant upon their wider agricultural estate to support them and were often sited away from large conurbations to provide an area of peace and reflection away from the outside world. The wider rural setting is important to the experience of the Abbey as a place of worship, and local landmark, as well as illustrating its historic association with agriculture. It therefore makes an important contribution to its significance.
While we acknowledge that the land immediately to the south and west of the Abbey is to be retained as green open space, nonetheless any built development within HOU5 would divorce the Abbey from its wider rural context, altering its historic illustrative value as a rural monastic site, and thereby resulting in a loss of significance. We do not consider that there is any potential for further mitigation since any measures which retain the open character would render the developable area too small for a viable allocation. We therefore recommend that the site is deleted.
If you are minded to proceed with this allocation, then further landscape work specifically considering the wider setting of Elstow Abbey will need to be produced in advance of the EiP, setting out with appropriate justification where development could be sited. This further work should then inform revisions to policy wording to establish key design parameters for the site. We would be grateful to have a conversation with you to agree the scope of this further work with you.
While we note that there is reference to a Landscape and Visual Appraisal (LVA) in the Vision Strategy (Savills, August 2020), we have been unable to access it. Without having had the opportunity to review this technical work, we have been unable to determine whether it satisfies the concerns and next steps that we have outlined above.
Without this further evidence, the allocation is not justified and therefore is not sound.