Comment

Representation ID: 9690

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the site lies to the west of two grade II listed buildings (a barn and 199-200 Wilstead Road). To the north east of the site lies the Elstow Conservation Area, Elstow Manor House (Scheduled), Hillersdon House (grade I), the Church of St Mary and St Helena (grade I) , Church Tower (grade I, Moot Hall (grade II*) as well as many grade II listed buildings. Any development of this site has the potential to impact upon these heritage assets and their settings.
Elstow has a very high concentration of heritage assets and is one of the key jewels in Bedford’s heritage crown. The setting of the Abbey within the meadows, and glimpsed views of the Abbey from the approach into Bedford in this direction are important. Famous for its John Bunyan connections, the village is significant to the heritage of Bedford as a whole.
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.
Development of this scale carries with it the risk of a severe degree of harm to the significance of the important collection of heritage assets at Elstow. We therefore have considerable concerns about employment development at this site and question whether this is the most appropriate location for such a scale of development.
A heritage appraisal has been completed for the site. The appraisal suggests that there will be no impact on these assets from development of the site. However, we disagree with this conclusion.
It is our view that the scale and mass of employment development on the site is indeed likely to impact upon the wider rural setting of the Elstow cluster of heritage assets. The open rural aspect to the south west of Elstow and the rural approach from the south along this corridor, is important to the setting of these assets and would, in our view, be harmed by large scale development on this site. We therefore have concerns about development on this site.
We do appreciate that the policy does include some criteria aimed at protecting the nearby heritage assets (criteria iii, iv, vi, ix and x). However, the fundamental scale of warehousing and distribution could have a negative impact on this setting.
We therefore suggest that consideration is given to restricting the scale (particularly height and mass) of uses on the site in the policy to further protect the highly grade heritage assets to the north east.
We appreciate that an LVA has been prepared but this is really a baseline assessment and does not include wirelines, photomontages or other images. It also does not include a viewpoint from the Abbey and edge of Conservation Area or from the A6, close to the site. We find this document lacking.
Further assessment is needed prior to EiP to demonstrate whether mitigation may be possible or if development would still be harmful. If mitigation would be appropriate, the assessment should explore what this would mean in terms of height, mass, colour etc on this site, particularly in the context of the sensitive heritage setting of Elstow and the wider views to the countryside from the assets and the rural approach into Bedford at this point. If the site is still considered suitable, subject to mitigation, the policy wording should then be amended to establish key design parameters for the site, informed by the further assessment.
We consider that development of this scale would result in harm and that the existing supporting evidence is lacking. Without further evidence as advised above, the allocation is not justified and therefore is not sound.