3.16

Object

Representation ID: 9007

Received: 01/10/2021

Respondent: Bedfordia Developments Ltd and Marcol Industrial Investments LLP

Agent: Lichfields

Highways Capacity and Development to the North of Bedford
3.1 TwinWoods is not a shortlisted site for the emerging 2040 Local Plan review. The reason for this appears to be almost solely due to traffic capacity issues at the Manton Lane/Clapham Road/A5141 roundabout on the A6, in north Bedford, as it is perceived through the Bedford Borough Transport Modelling (BBTM) results alone. In addition to TwinWoods, development of any other sites north of Bedford appears to have effectively been ruled out with no exceptions based on highway capacity grounds. There is no apparent consideration of measures to overcome these concerns through reallocation of roadspace, nor the opportunities to be gained through implementing policy compliant Garden Village principles central to the development of the TwinWoods proposals.
3.2 Vectos has undertaken a detailed review of BBC’s highways evidence, especially the modelling, this is appended to this consultation response at Appendix 1.
3.3 However, stepping back, we consider that the approach BBC has taken to its 2040 Local Plan site selection process is an incorrect one. It is not policy compliant in the context of the Climate Emergency declared by BBC, as it follows a ‘predict and provide’ approach to traffic capacity that ignores mobility as a whole, contrary to leading transport guidance. This guidance, amongst many other things, includes a commitment to embed transport decarbonisation principles in spatial planning and across transport policymaking and accelerate modal shift to public and active transport (Department for Transport paper – Decarbonising Transport published in July 20215).
3.4 The recent changes to the NPPF 2021 make moves in a similar direction including reference to the 17 Global Goals for Sustainable Development at paragraph 7, the need for plan making to promote sustainable patterns of development to align growth and infrastructure with improving the environment and mitigation climate change (paragraph 11a) and planning for larger scale development needing to be supported by necessary infrastructure and facilities including a genuine chose of transport modes (paragraph 73). A more minor change includes reference to planning policies aiming to achieve healthy, inclusive and safe places through the use of attractive, well-designed, clear and legible pedestrian and cycle routes.
Vision & Validate or Predict & Provide in Planning Policy
3.5 Vision & Validate (V&V) is an expression coined to represent current planning policy expressed in the NPPF. The labels have been applied to distinguish the approach from the discredited and abandoned, except in particular circumstances, Predict & Provide (P&P) which has been used in the BBTM evidence.
3.6 V&V embraces masterplanning, planning and transport. The constant threads, and highest priorities, are climate, health and economy (NPPF paragraph 8). In contrast, P&P was commuter traffic focussed (traditional morning and evening peak hours), and its highest priority was providing convenience for those that would prefer to drive at the busiest times. V&V is an inward out approach to decide, or establish, the vision for what is desirable, and design to achieve that.
3.7 The recently published DfT Paper ‘Decarbonising Transport’ (July 2021) endorses the V&V approach:
“We recognise that the Government has a role in helping Local Planning and Highways Authorities to better plan for sustainable transport and develop innovative policies to reduce car dependency. We need to move away from transport planning based on predicting future demand to provide capacity (‘predict and provide’) to planning that sets an outcome communities want to achieve and provides the transport solutions to deliver those outcomes (sometimes referred to as ‘vision and validate’). We will continue to work with MHCLG to identify how we can best support local authorities to develop innovative sustainable transport policies as part of the planning process, how this can be used to better assess planning applications, and better monitor local transport outcomes to deliver on our ambitions for sustainable transport use6.”
3.8 When it comes to considering traffic, there is a fundamental difference in thinking between national planning policy as it now is, and P&P as adopted by BBC’s approach to it’s Plan. In real life, traffic is a function of available roadspace. At busy times, increasing road capacity generates traffic, and reducing road capacity reduces traffic. Capacity is a tool. This can be seen by observed effect throughout the country. It is no coincidence that gridlock never occurs on a regular basis. A good example is in London, where since 2000 road capacity has been reduced across all areas, with a reduction of 30% in the Central Area. Research from the EU CREATE report, also reported in TfL’s Travel in London Report no. 9 states:
“Research as part of the CREATE project has found that in London over the last ten years up to 25% of road space on key routes in London has been reallocated from private vehicle to cycling, walking or public transport infrastructure. However average journey time / congestion today is broadly the same as ten years ago. This has been achieved whilst accommodating 7 million more journeys today (all modes) per day (increasing from 24m to 31m). This capacity has been unlocked thanks to the modal shifts. This shows that efficient reallocation of road space can unlock capacity for more journeys, accommodating population and economic growth, whilst keeping congestion constant.”
3.9 P&P looked at it a different way. It made the judgement that a notional forecast of traffic would come what may, and because of that it needed to be accommodated, often by road building. This was self-fulfilling and is one of the reasons why P&P can now be the antithesis of national planning policy in delivering sustainable development. Indeed, there is no expression in the NPPF which promotes P&P, but promotes an approach that has been characterised by the phrase V&V which includes a commitment to mitigating climate change and specifically, the need to provide a genuine choice of transport modes in supporting new settlements, i.e. not just expecting and modelling for unsustainable car-based journeys. Liveable neighbourhoods and sustainable transportation modes need to be built into the design of a large-scale development to comply with the NPPF.
3.10 Even before the latest changes to the NPPF, there have been clear examples of this interpretation.
3.11 In 2013, the Inspector for the Hartford, Cheshire West and Chester, Hartford and School Lane Section 78 Inquiries included in his determination that “it is not the aim of policy to protect the convenience of commuting car drivers”. The decision was called in by the Secretary of State, who agreed with the Inspector’s conclusions and recommendation and allowed the Appeals for a total of 650 homes7.
6 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf, page 158
7 Appeal References: APP/A0665/A/12/2179410 & APP/A0665/A/12/2179374
3.12 In 2016, Stevenage Borough Council submitted a Mobility Strategy in support of its Local Plan, and with the agreement of Hertfordshire County Council as highway authority. The strategy explained that it steered away from the historic and contra policy P&P, and that instead of prioritising road building the strategy was to prioritise mobility as a whole. It assumed no peak period traffic growth beyond the designed capacity of the network, taking into account some pinch point works, focussing its infrastructure funding on more sustainable means of movement. The Local Plan Inspector endorsed this approach8.
3.13 In 2016 Cardiff County Council promoted a 50:50 approach to traffic in Cardiff. It built a traffic model and loaded it with traffic forecasts for a Local Development Plan growth of about 40,000 homes and 40,000 jobs, and, by design, no new road infrastructure except where it provided bus priority. They removed traffic from the model until it ‘functioned’. They assumed that traffic levels would only exist up to the limit of the network (the capacity of the network determines the traffic volume) and then determined what the movement mode split would be in Cardiff for all movement demand to be satisfied, coming up with the expectation that by the end of the Plan period the mode split would be 50:50.
3.14 The V&V approach is unequivocally set out in the Garden City principles (which the NPPF para 73 c directs the reader to) and endorsed by the industry bodies including the Department for Transport (Decarbonising Transport – A Better Greener Britain), the Royal Town Planning Institute9, the Chartered Institution of Highways and Transportation10, the Town and Country Planning Association11 and TRICS12.
3.15 Equally, these industry bodies explain that P&P is abandoned and is used to the detriment of planning better places.
3.16 It is not the case that V&V has no regard to traffic and traffic effects. There are circumstances where maximising road capacity is considered beneficial in planning, for instance in considering regional economic performance. There are also safety implications, particularly in respect of the strategic road network, such as motorway slip roads, where capacity is used for safety as opposed to convenience reasons.
3.17 Following the V&V approach is in accordance with national planning policy and, especially in light of the changes to the NPPF 2021, it is harder to justify how the P&P approach could achieve all the sustainability and climate change commitments of the Framework, and therefore risks the soundness of the Plan.
Highways, Placemaking, Health, Climate Change
3.18 P&P approach to transport planning places too much emphasis on individual travel rather than planning communities which are centred around active travel and public transport which facilitate the behavioural changes that are required for decarbonisation of the transport sector.
3.19 The promotion of 20-minute neighbourhoods is recognised in DfT’s Decarbonising Transport report (July 2021), which has an aspiration to “place cycling, walking and public transport provision at the heart of local plan making and decision taking for new developments” (page 158).
3.20 The policy approach, represented by the phrase V&V, is all encompassing. Traffic is not a subject in its own right, and neither is transport. There is an interaction between masterplanning, land
8 Report on the Examination of the Stevenage Borough Local Plan 2011-2031, Reference: PINS/K1935/429/6
9 Net Zero Transport (RTPI Research Paper, January 2021)
10 Better Planning, Better Transport, Better Places (CIHT, August 2019)
11 Garden City Standards – Guide 13: Sustainable Transport (TCPA, September 2020)
12 TRICS Guidance Note: On the Practical Implementation of the Decide and Provide Approach (February 2021)
use, landscape, economy, mobility, accessibility and traffic. Each affects the other, and there is an iterative procedure required before finalising on the best “place-based solution”13.
3.21 The V&V approach at TwinWoods has embraced this with provision of everything communities need in 20-minute neighbourhoods14, reducing the need for individual travel. The strategic modelling approach undertaken in the BBTM has not and does not. It appears to be a stand-alone traffic-based exercise with some adjustments made for limited mode shift. For this reason the modelling results are not appropriate to make planning decisions in isolation.
How has this impacted TwinWoods?
3.22 In transport modelling terms, the BCC approach to assessing TwinWoods does not look at the new settlement as a new self-sustaining town, but only as additional housing all attracted to Bedford and beyond. This is an archaic view of development, not reflective of what is proposed at TwinWoods, and contrary to BBC’s own visions and objectives.
3.23 In BBC’s ‘Strategy Options and Draft Policies Consultation’ (June 2021) document the Transport Strategy states (p.3.19-3.22):
“The basic premise for transport investment is that business as usual will not get us to where we want to be…
What this means is that in order to deliver sustainable growth; transport investment, travel behaviour and the way we think about moving around will need to change. The impact of continuing with current travel behaviour will have a detrimental impact on the very things that make the area successful…
Increased economic activity and growing populations, if left to continue in traditional patterns of movement and behaviour, will mean people spend longer on congested transport networks, the environment will be degraded, and quality of life expectations will not be met.
The EEH Strategy includes…
• Focus on decarbonisation of the transport system by harnessing innovation and supporting solutions which create green economic opportunities
• Promote investment in digital infrastructure as a means of improving connectivity, in order to reduce the need to travel
• Use delivery of East West Rail and mass rapid transit systems…
Champion increased investment in active travel and shared transport solutions to improve local connectivity to ensure that everyone has the opportunity to realise their potential” (emphasis added).
3.24 An allocation of a new settlement at TwinWoods would meet all of these objectives, and it could be argued that some sites selected in the draft Plan have not demonstrated this but instead rely on new strategic road infrastructure releasing highway capacity at a local level. Using the P&P
13 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf, page 144
14 The 15 minutes-city: for a new chrono-urbanism! – Professor Carlos Moreno; https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/1009448/decarbonising-transport-a-better-greener-britain.pdf, page 158
modelling results as a pass/fail for development on solely highway capacity terms is the antithesis of BBC’s own aspirations for sustainable growth.
3.25 In section 4.0 of these representations we note that the updated NPPF requires a 30-year vision for the Plan. It will be necessary for BBC to revisit its strategic choices to 2040 in light of the long term vision for the Borough which must recognise that over this longer period – if not by 2040 – there will be structural shifts in sustainable transport that render the current P&P approach underpinning the Plan out-of-date.
How can this be addressed?
Types of Model
3.26 The BBTM is a strategic model which has been designed for the purpose of analysing the traffic performance across the Borough for the 2040 Local Plan. This is a Saturn model and given its strategic purpose, it will ‘load’ traffic onto individual junctions in a manner which cannot occur in reality (i.e. this much traffic simply cannot exist within such a time period). The coarse nature of the software means it often overestimates traffic flows at individual junctions therefore and, when closely scrutinised, will forecast ‘chaos’ in this respect. It cannot be relied upon in isolation as a means of informing decisions around the operation of the highway network.
3.27 A microsimulation model is more appropriate for the assessment of TwinWoods and an individual junction or corridor. This would allow for a more reliable analysis of the behaviour of vehicles at the Manton Lane roundabout by determining the most appropriate highway ‘interventions’. As a result of the greater detail in the model, the outputs are closer to reality than from a strategic model and capacity is more accurately reflected. It is therefore both adequate and proportionate to the task of developing policies for the allocation of TwinWoods in the new Local Plan. As such, its use complies with national policy and is sound in principle.
3.28 As different types of model they have different functions. They are both tools that can be used to inform the Local Plan and demonstrate the soundness of the Local Plan and selected sites, but in different ways. The results must then inform the planning decisions made, rather than dictate them as it appears has been done in Bedford.
3.29 The requirement for soundness is that the Plan should be prepared in accord with National planning policy (NPPF para. 35). NPPF para.31 says: “The preparation and review of all policies should be underpinned by relevant and up-to-date evidence. This should be adequate and proportionate, focused tightly on supporting and justifying the policies concerned, and take into account relevant market signals.”
Alternative Mitigation
3.30 Despite the BBTM not being the correct tool to accurately forecast traffic impacts on specific junctions, BBC has used its results to rationalise what is, in effect, a moratorium on new development to the north of Bedford that will constrain the Plan beyond it’s Plan period and infect its 30-year vision now required by the NPPF.
3.31 The issues at the Manton Lane roundabout become ‘significant’ with the inclusion of an additional 10 years of traffic growth excluding potential 2040 allocation sites. The inclusion of this growth is questionable as it means that the mitigation strategy derived through the modelling is one which can only reinforce existing travel patterns and exacerbate car dependence by continuing to seek to provide capacity for predicted traffic movements. As identified, this is not in line with the direction of national (or indeed local) policy.
3.32 As new allocated developments come forward within Bedford the reality is that they will be developed in line with policy aspirations and will buck historic trends in travel patterns. In this case, congestion at the Manton Lane roundabout is unlikely to occur in the fashion predicted by the BBTM.
3.33 It is not evident that meaningful alternative measures (to road capacity enhancements) have been identified such as re-allocation of road space to higher capacity modes, and the supporting joined-up infrastructure to make these modes a viable form of travel. This is not tested in the BBTM. The below is an image extract from the document ‘Ticket to the future. 3 Stops to Sustainable Mobility’.
Mobility. Figure 3.1 Number of people crossing a 3.5 metre-wide space in an urban environment during a one hour period
Source: Ticket to the future. 3 Stops to Sustainable Mobility. UITP International Association of Public Transport, Brussels. 2003 based on Botma and Pependrecht Traffic operation of bicycle traffic. TU Delft 1991
3.34 Critically however, it is a questionable assumption that drivers will continue to load onto a junction that is operating at capacity without acting to minimise their own inconvenience. This is not realistic and hence excluding beneficial development on this basis is not in accordance with a balanced approach.
Development to the North of Bedford
3.35 TwinWoods is designed as an exemplar Garden Community which embodies the placemaking and transport principles of modern policy. The proposal is for a new town that consumes much of its own movement in the same way as an established town does, but better. It does this through careful design, accommodating those features which make liveable towns successful and futureproofing for emerging innovations.
3.36 The vast benefits of an allocation in this location appears to have been discarded in lieu of the BBTM results.
3.37 It is clear from a wide variety of national planning and transport policy that using highway capacity as a determining factor to new development is outdated, and not sustainable as we move towards the Net Zero targets set out to address the declared Climate Emergency in the UK.
It has been demonstrated that justification for closing north of Bedford to new development is flawed in the following ways:
• The function of the BBTM is not to measure individual junction effects, nor is it to be the whole determinant of site selection in the planning process;
• Alternative measures to increasing road capacity have not been considered, such as reallocation of roadspace to higher capacity modes, and facilitating a reduced need to travel in the first instance;
• Traffic and indeed transport is not an isolated topic in development selection;
• Highway capacity constraints are not a barrier to development, this follows a P&P methodology rather than a V&V approach as endorsed by DfT as well as other industry bodies.
3.38 Ultimately traffic is a function of roadspace; we design for what we aim to achieve; the Vision. People act to minimise their own inconvenience and thus in reality gridlock does not occur on a regular basis as people increasingly choose to work remotely, order shopping online, travel at a different time, change modes etc. When these principles are accepted by decision makers and the choice is as readily available as jumping in a car, highway congestion is no longer a barrier to the right development in the right location.

Object

Representation ID: 9034

Received: 04/10/2021

Respondent: Historic England

There are four emerging preferred options 2a – 2d.
These options include different combinations of the following:
a) Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites
b) Expansion of the Bedford / Kempston urban area;
c) Rail based parishes Kempston Hardwick, Stewartby, Wixams
d) Southern parishes – Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton
e) East parishes Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston
f) Wyboston New Settlement
g) Little Barford New Settlement
We have analysed each of these potential areas for growth in terms of their potential to impact upon the historic environment. These aspects are outlined below. W have focussed our attention on designated heritage assets.
For the avoidance of doubt, we have not considered archaeological issues in this brief, desk-based assessment but would refer you to the HER who should be able to advise in this regard. We have also not identified non-designated assets. It should be noted that there are areas of archaeological interest beyond scheduled monuments and historic landscape issues beyond registered historic parks & gardens.
Wider archaeological and landscape/townscape impacts are important considerations and need to be factored into site assessment. The possible cumulative impact of a
number of site allocations in one location could also cause considerable harm to the historic landscape /townscape.
All sites should be scoped for archaeological potential before taking them forward to the next stage, as there is a high likelihood of archaeological sites not on the HER.
Archaeological assessment and evaluation should be in line with the NPPF and best practice guidance so that impacts can be assessed at the earliest opportunity.
a) Further regeneration within the Bedford / Kempston urban area, particularly of any available brownfield sites;
Regeneration and densification can be useful in accommodating the required growth.
However, where there are opportunities for densification, this must be managed carefully in a way that seeks to conserve and enhance the historic environment.
Much of the central area of Bedford is designated as a Conservation Area.
We refer you to our publication, ‘Increasing residential density in historic environments’ which can be found here. This study explores the factors that can
contribute to successfully delivering developments which increase residential density in historic environments. It uses a combination of literature review and case studies
to provide a series of recommendations to support decision making. Whilst taller buildings may be appropriate in some areas, there is an on-going
question of scale. It is important that densification, including tall buildings, respects and does not harm the historic environment. We recommend that you consider
undertaking a tall buildings study to inform your strategy and include a policy for tall buildings in your Plan.
Finally, densification is particularly appropriate in the context of brownfield development. Whilst densification of some areas may be appropriate, it is important
to protect and enhance open spaces within urban areas and villages as these open spaces can constitute an important aspect of the character of a place, may help
protect the setting of heritage assets or even be a heritage asset in their own right.
Open spaces can provide important green lungs and help in tackling climate change. And they may also serve as important recreation and leisure areas.
b) Expansion of the Bedford / Kempston urban area;
The NPPF (paragraph 73) states that the supply of large numbers of new home often can be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns. Criterion c of the paragraph states that they should ‘set clear expectations for the quality of the development and how this can be maintained (such as by following Garden City Principles).
That said, Bedford has already experienced large scale urban extensions. The river and its floodplain represent a constraint both to the east and west of the town. There
are also several historic villages and conservation areas around the existing built up area, which raises the issue of coalescence and the importance of maintaining the
integrity, separation and identity of these communities. To that end, urban extensions will need to be carefully considered, taking the impact on the historic environment
into account.
c) Rail based parishes Kempston Hardwick, Stewartby, Wixams The principal designated heritage assets in these parishes include the scheduled monument - Kempston Moated site, Stewartby Conservation Area including the Sir Malcolm Stewart Trust Common Room and Homes, both listed at grade II and the Stewartby brickworks (kilns and chimneys) also listed at grade II.
This area has already experienced significant growth. Further growth will need to conserve and enhance these heritage assets.
d) Southern parishes – Cotton End, Elstow, Kempston Rural, Shortstown, Wilstead and Wootton
There is a wide variety of designated heritage assets within these southern parishes.
We have listed these assets below:
• Cotton End includes a number of listed buildings including the grade II* Manor house and several grade II listed buildings.
• Elstow – the parish of Elstow includes Elstow Conservation which contains the scheduled monument, Elstow Manor House, Moot Hall (scheduled and grade
II*), grade I listed parish church of St Mary and St Helena, grade I Hillersdon Mansion, grade II* Bunyan’s Mead. There are also a large number of grade II
listed buildings both within the conservation area and to the south along Wilstead Road.
• Kempston Rural includes the grade I listed All Saints Church and Church Tower, Grade II* Box End and a large number of grade II listed buildings scattered throughout the parish.
• Shortstown – There are 5 grade II listed buildings in the northern part of the parish and to the south of the parish, the Cardington Shed’s are both listed at grade II*.
• Wilstead – the church of All Saints is listed at grade II* but the remaining listed buildings in the village are all listed at grade II.
• Wootton – The parish of Wootton includes the Wootton Conservation Area, grade I listed St Mary the Virgin church, grade II* Wootton House and numerous grade II listed buildings, mostly focussed on the conservation area and village itself but also some isolated farmsteads.
Elstow, Kempston Rural and Wootton have most highly graded assets and are likely to be most sensitive to development in terms of impacts on the historic environment.
Development within all of the southern parishes has the potential to impact upon these designated heritage assets and their settings. Clearly without knowing exactly
where development will be located it is hard to state whether this level of development will be acceptable. In considering sites, it will be important to give consideration to impacts on the historic environment. This will necessitate the need
for Heritage Impact Assessments of sites, both to judge the suitability of the site per se and also to identify any mitigation measures needed or opportunities for
enhancing heritage assets.
e) East parishes Cardington, Cople, Great Barford, Little Barford, Roxton, Willington and Wyboston
Again there is a wide variety of designated heritage assets within these southern parishes. We have listed these assets below:
• Cardington - The Parish of Cardington includes Cardington Conservation Area. The conservation area includes the grade II Registered Park and Garden to Hoard’s House, as well as numerous listed buildings including Howards House, listed at grade II* with the remaining listed buildings both inside and outside of the conservation area being listed at grade II. There are
also several scheduled monuments in the parish including the site of a deserted village, a settlement site north of Chapel End Farm as a well as a
Neolithic and Bronze Age mortuary.
• Cople - includes a number of listed buildings. The majority of these are grade II listed although the church of All Saints is listed at grade I. There are several
scheduled monuments in the northern part of the parish, several of which are
associated with a Neolithic and Bronze Age mortuary complex as well as several barrows.
• Great Barford - There are 3 Conservation Areas in Great Barford (Great Barford, Great Barford Hill and Green End). Barford Bridge is scheduled and listed at Grade I. The parish church of All Saints are listed at Grade II* and there are numerous grade II listed buildings throughout the village.
• Little Barford - The parish includes the grade II* Church of Saint Denys as well as three grade II listed buildings; Lower Farmhouse, a barn to the north of Lower Farmhouse and cottages 1-4.
• Roxton - The Parish of Roxton includes Roxton Conservation Area. There are also a number of listed buildings including the Congregational Chapel and
Parish Church of Saint Mary Magdalen, both listed at grade II* with the remaining listed buildings all grade II.
• Willington - The Dovecote and Stables at the former Manor house are both listed at grade I and scheduled. The Docks moated site is also scheduled.
There are also a large number of grade II listed buildings throughout the village. Birchfield Farm is a scheduled moated site with associated fishponds and leats in the northern part of the parish.
• Wyboston – The parish of Wyboston includes a number of scattered grade II listed buildings and three scheduled monuments - Palaceyard Wood medieval moated enclosure and associated enclosures, woodland bank and cultivation earthworks, Chawston Manor medieval moated site and associated fishpond and a Moated enclosure and associated building platforms at The Lane,
Wyboston.
These eastern parishes have a particular concentration and clustering of scheduled monuments along the Ouse river valley. There are also a number of Conservation
areas along this valley too.
Development within these parishes and along this river corridor has the potential to impact upon these designated heritage assets and their settings. There are
particular settings issues associated with the scheduled monuments along this sensitive river corridor.
Clearly without knowing exactly where development will be located it is hard to state whether this level of development will be acceptable. In considering sites, it will be important to give consideration to impacts on the historic environment. Heritage Impact Assessments will be required for sites, both to judge the suitability of the site per se and also to identify any mitigation measures needed or opportunities for enhancing heritage assets.
f) Wyboston New Settlement (Denybrook Garden Village) ID977
On-site Designated Heritage assets
There are a number of designated heritage assets within the site boundary include the grade II listed Dairy Farmhouse, Chestnuts Farmhouse, Eaton Tithe Farmhouse, Sudbury Farmhouse, Moat Cottage. There is also a scheduled monument (Moated Enclosure and associated building platforms, The Lane, Wyboston) that appears to
lie just within the site boundary.
Nearby Designated Heritage Assets
There are a number of nearby heritage assets nearby including several grade II listed buildings in Chawston, Colesden, Channels End and Colmworth. To the north west of the site there are several scheduled monuments nearby the moated site know as ‘The Camps’ and associated fishponds as well as Bushmead’s Priory (include the grade I listed Priory and several other listed buildings). To the south of the site lies another scheduled monument, Chawston Manor medieval moated site and
associated fishpond.
Chawston Manor forms one of a pair of moated sites in the vicinity of Wyboston. This proximity will allow chronological and social comparisons between the two sites.
Documentary evidence concerning the history of Chawston Manor moated site further enhances its importance. The silts within the ditches and the water-logged
deposits in the fishpond will contain environmental and artefactual evidence related to the occupation of the site; and, despite some disturbance caused by later constructions, the island will retain the buried remains of earlier buildings. The major part of the western enclosure is undisturbed and will also retain buried archaeological features.
Development of a new settlement has the potential to impact upon these designated assets and their settings as well as non-designated heritage assets. We strongly
advise that a heritage impact assessment is undertaken of this site to better understand the potential impacts of development on these heritage assets.
We understand that the developers have provided an HIA. We would be interested to see this assessment and will need to ensure that the scope is sufficient. It will
need to take into account heritage assets in the wider area including Bushmead Priory etc.
We note that this site is currently rated amber in your historic environment comments.
g) Little Barford New Settlement (Top Farm, land east and west of Barford Road, Little Barford) ID907
On-site Designated Heritage assets Assuming we have identified the correct site ID for this proposed new settlement, the site includes the grade II* Church of Saint Denys as well as three grade II listed buildings – Lower Farmhouse, a barn to the north of Lower Farmhouse and cottages 1-4.
Nearby Designated Heritage Assets
There are a number of grade II listed buildings to the east of the site along the A1 and the St Neots Conservation area and associated listed buildings lies to the north
of the site. Tempsford Langford End Conservation Area and associated listed buildings lies to the South of the site and to the south west lies Roxton Conservation
Area and associated listed buildings. To the east lie two isolated listed buildings, Lansbury Farmhouse and Hardwicke Farmhouse, both listed at grade II and further
to the east lies Abbotsley Conservation Area including the grade II* listed church and a number of other listed buildings
Development of a new settlement has the potential to impact upon these designated assets and their settings as well as non-designated heritage assets. The presence of the grade II* listed church will require particular attention. We strongly advise that a heritage impact assessment is undertaken of this site to better understand the potential impacts of development on these heritage assets.
We note that your historic environment RAG assessments are red for this site. We too have concerns, given the highly graded asset within the site boundary and also in the absence of any HIA to date.
h) Comments on the other new settlement options considered in Development Strategy Topic Paper
i) Twinwoods
Twinwoods wraps around to the north, south and east of the village of Milton Ernest.
It incorporates or is immediately adjacent to three scheduled monuments and potentially affects the setting of two grade I and some grade II listed buildings. Two
of the scheduled monuments relate to the shrunken medieval village, the other a set of enclosures. The grade I listed buildings are Milton Ernest Hall which is William
Butterfield's only complete country house and the parish church of All Saints.
We appreciate this is not currently one of the preferred options being considered. There are clearly some highly grade heritage assets in the surrounding area. The
impact on these assets would require careful examination through Heritage Impact Assessment, were this option to be reconsidered as a possibility in the future.
ii) Colworth
Lee Farm / Colworth has been identified as a potential new settlement site. There are a number of designated assets within the site including the grade II* listed
Colworth House, and New Farmhouse and Antonie Farmhouse, both listed at grade II. There are also numerous heritage assets located around the site. The site lies adjacent to and includes a small part of the Sharnbrook Conservation Area. The Conservation Area includes the grade I listed Church of St Peter, together with approximately 40 buildings or structures listed at grade II.
A further cluster of listed buildings, including All Saints Church and a further 11 buildings listed at grade II lie to the north west of the site within the village of Souldrop. Hinwick Lodge and Barn, both listed at grade II, lie to the north of the site whilst to the north west Hinwick House is listed at grade I and Hinwick Hall and the garden entrance gates both at grade II*. In addition, there are a further 25 buildings listed at grade II in the vicinity and Hinwick House Registered Park and Garden is
listed at grade II.
The Podington Conservation area contains a further 24 listed buildings including the grade I listed church of St Mary and to the south west, Odell Conservation Area
contains approximately 20 listed buildings including the grade I listed All Saints Church. Hobbs Green Farmhouse (grade II) lies outside of the conservation area but
closer to the site allocation. In addition, there is a scheduled monument, a moated site in Castle Close, just to the south east of the site as well as Wold Farm Moated
Enclosure, a scheduled monument, to the west of the site.
The HER indicates that this is an area of very high archaeological potential with a high concentration of records in this area dating from the late prehistoric through to twentieth century features. These include late pre-historic enclosure, iron age cropmarks, iron age ditches, rectangular enclosure, iron age pottery, a Roman road, a Roman site, Tofte Manor, medieval bloomeries (iron works) and a World War II searching battery.
Given this rich concentration of heritage assets, any development at Colworth therefore has the potential to impact upon these assets or their settings.
Again, we appreciate this is not currently one of the preferred options being considered. There are clearly some highly grade heritage assets in the surrounding
area. The impact on these assets would require careful examination through Heritage Impact Assessment, were this option to be reconsidered as a possibility in
the future.
Summary and comparison of options 2a-2d.
As has been highlighted above, each of the different potential areas for growth contain a range of heritage assets and there is potential for development in these
areas to impact on those assets and, in particular, their settings. Much will depend on the precise location and quantum of development, as well as the ultimate design.
In considering options for growth, further assessment will be needed of the various impacts on the historic environment. To that end, the site assessment undertaken to date will also need to be combined with further, more detailed, heritage impact assessment, as outlined in the section above on-site assessment, to determine the suitability or otherwise both of individual sites and broader growth options.
Having reviewed the Sustainability Appraisal, we note that the assessment records uncertain effects for the historic environment for all the different growth options.
Whilst this is in part understandable, given precise locations for development are still to be determined, there has been little or no assessment of the relative merits of the broad spatial options in terms of the historic environment in the assessment. We suggest that a narrative comparing the different options and their likely impacts on the historic environment be prepared.
So to conclude, within the southern parishes we have identified several parishes as being perhaps more sensitive to development (particularly Elstow but also Wootton and Kempston Rural); in the eastern parishes there are sensitivity issues around the settings of a cluster of scheduled monuments as well as a number of Conservation Areas.
And of the two preferred new settlement options, it would seem that whilst Little Barford is perhaps slightly more sensitive to development than Wyboston in terms of
impacts on the listed buildings (having a grade II* church within the site), the scheduled monuments close to Wyboston give rise to different settings issues and
sensitivities that will need careful consideration and assessment.