Comment

Bedford Borough Local Plan 2040 Plan for Submission

Representation ID: 9685

Received: 26/07/2022

Respondent: Historic England

Representation Summary:

This new settlement proposal is a large strategic allocation for at least 4000 homes and employment development.
The site contains a scheduled monument, The Kempston Hardwick Moated Site. Kempston Hardwick is a fine example of a Bedfordshire moated site, the interior of which is substantially undisturbed and the waterlogged moat of which provides conditions suitable for the survival of organic remains.
Manor Road is the site of the linear medieval manorial deserted village, and part of the setting of the monument is this linear settlement.
Stewartby Conservation Area and its associated listed buildings lies to the south of the site whilst Wootton Conservation Area and listed buildings lie to the west of the site.
Any development of this site has the potential to impact upon these heritage assets and their settings.
An HIA has been prepared for the western portion of the site. However, this assessment does not follow the full 5 step methodology for HIAs. It identifies assets and considers impact but does not make any recommendations regarding potential mitigation and enhancements. This should be undertaken to inform the policy.
There does not appear to be an HIA for the rest of the site. An HIA should be prepared to cover the whole site.
However, we note that the promoters supporting statement does refer to an agreed stand-off distance for the scheduled monument. However, this was negotiated in relation to a specific application for employment development rather than a larger new settlement proposal.
An HIA should also be prepared for the rest of the site that considers the context of the new settlement.
We welcome criterion vi. However, the policy needs to be more specific in relation to mitigation and enhancement measures for the scheduled monument (see requirement above for completion of HIA).
Figure 7 page 64 shows a concept diagram for the site. Our initial view, though subject to the findings and recommendations of the HIAs, is that there should be more open space to the west of the monument (removing some of the land for employment in this area) and greater set back along the line of Manor Road, leaving a wider green corridor in this area.