Issues and Options

Bedford Local Plan Review Issues and Options Consultation July – September 2020 Thank you for consulting Historic England on the Bedford Local Plan Issues and Options consultation stage. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is fully taken into account at all stages and levels of the local planning process. Therefore we welcome the opportunity to comment on the Issues and Options consultation and Call for Sites. We have now had the opportunity to review the documents and can provide the following substantive comments. Introduction The county town Bedford lies towards the south of the borough. Founded at a ford on the River Great Ouse, the historic market town was granted borough status in 1165. The Borough has a rich and diverse historic environment with over 1,300 listed buildings including 50 listed at grade I, 68 scheduled monuments including many moated sites, 8 registered parks and gardens and 28 conservation areas. The north of the borough bordering Northamptonshire boasts a number of pretty villages with stone and thatched cottages as well as a number of Bedford Estate cottages. To the south of the borough, the heritage and legacy of the brickworks as well as the hangers at Cardington shape and dominate the landscape. Situated within the heart of the Ox Cam arc and with fantastic existing and potential transport connections in the form of the A421, M1, A1 as well as located on the Midland Mainline and the route of the new East West Rail, the area is set to experience considerable growth in the coming years. The challenge is to ensure that this is good growth that respects and takes the opportunity to enhance the historic environment.

No

You will recall that during the previous Local Plan review we raised concerns about the number of different plans and policies in place and the slightly confusing nature of these multiple documents. At the time we commented that it was unfortunate that the opportunity has not been taken to incorporate the Allocations and Designations Local Plan into the new Local Plan. This may lead to confusion and lack of transparency. It would be easier if all allocations and policies were included in one Plan. In our view it would be preferable if all allocations and policies were incorporated into one Plan. This is more user friendly both for planners and the public. As you will be aware the Planning White Paper indicates a fundamental shift in the approach to Local Plans, both in terms of plan preparation and plan content. It will be important that as these proposals are clarified the new Local Plan adheres to any new legislation and guidance.

The vision is quite long and overly detailed. It could be shortened and simplified. We welcome the reference to heritage and the historic environment at the end of paragraph 5. This could be further improved by including the vision to enhance the historic environment and increase access to heritage for all, as required by the NPPF. We welcome the plans for the town centre - reference could be added here to the Heritage Action Zone. Finally we welcome the reference to heritage in relation to Stewartby brickworks.

I agree with this plan period

No comment.

Nothing chosen

Historic England has no particular preference on the specific geographical spilt however we recommend that the density, scale, character and detailed designed of new housing be appropriate for its context. The capacity for an area to accommodate Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. new housing development whilst maintaining its historic environment should be a key consideration, so that the quality and character of neighbourhoods, towns and villages is conserved. Integrating consideration of the historic environment into plan making alongside other considerations is a key principle of sustainable development. Allocation of new housing sites should be considered in the most sustainable locations and densities and character should reflect that of the surrounding area. This approach will require a careful and detailed analysis of locations to ensure that distribution of housing is appropriate. The historic environment is a critical factor in this analysis in terms of considering the ability of sites and locations to accommodate new housing without undue harm to heritage assets and their settings. Any proposals for growth should consider the potential impact on the historic environment. Our advice note (HEAN) 3 on Site Allocations in Local Plans offers information on a methodology for site selection assessment: https://historicengland.org.uk/images-books/publications/historic-environment-andsite- allocations-in-local-plans/ Further detail is given on this aspect later in the letter and in our response to your Call for Sites consultation in August. We have included a few brief comments below on some of the potential locations for housing and employment growth and identified some of the key historic environment considerations for particular areas. This is by no means an exhaustive list but offers a starting point for the consideration of heritage in relation to these different options. Potential locations for housing and employment growth 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. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. 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 72) 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 3 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 a number of historic villages and conservations areas around the exiting 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) expansion within the borough boundary, of neighbouring urban areas, such as Rushden and St. Neots; Immediately to the south of Rushden lies the grade I listed parish church of St Lawrence at Wymington. To the south of St Neots lie a cluster of listed buildings centred on Little Barford and Wyboston. To the west of the town, across the A1 there are a number of listed buildings and scheduled monuments including Bassmead Manor Farm moated enclosure, Bushmead Priory and The Camps moated site and fishponds. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. d) development along the A421 corridor; There are a number of Conservation Areas and clusters of listed buildings along the A421 corridor including at Wootton, north of Shortstown, Elstow, Cardington, Willington, Great Barford and Roxton. There are also a number of scheduled monuments along the route with a particular cluster to the east of Bedford. e) development around an East West Rail northern station; There are a number of grade II listed buildings and structures in this area. Yarl’s Wood hermitage and moated site lies to the west of this area. f) new settlements in locations with good accessibility; The NPPF (paragraph 72) states that the supply of large numbers of new homes often can be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns. Criterion 3 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). Whilst Historic England broadly welcomes the idea of new settlements in locations with good accessibility, it is important that these are carefully located and planned with respect to all three strands of sustainable development. One of the strands of sustainable development includes the protecting and enhancing the historic environment. Landscape and heritage assets should be considered from the outset when determining the location of a new settlement in order to ensure that development can be delivered whilst having regard to the these assets. It is expected that strategic new settlement policies makes reference to the historic environment and the need for its conservation or enhancement. In considering potential locations for new settlements, it is important to consider the potential impact of new development on character and vitality of existing historic places. Consideration should also be given to the landscape character/context and how any new development would relate to it. Any new place has a past. Attention should be given as to how heritage can shape our future places and how new development might respond to our heritage to enhance the place and those assets. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. Whilst we recognise that it is hard to avoid all heritage assets for new settlement proposals given the scale of the proposed development, never-theless sites where should be chosen where there are likely to be fewer heritage assets and where harm to heritage can be avoided or at least minimised. The key to the development of large strategic sites, be they new settlements or urban extensions, is early Heritage Impact Assessment prior to allocation and before the site is included in a Local Plan, to determine suitability of site per se and, if so, which parts of site developable and to recommend appropriate mitigation. We would also emphasise the importance of clear policy wording and ideally a concept diagram to show key principles for the new settlement including heritage mitigation. Many Local Plans state that new settlements should come forward as a new ‘Garden Village’ based on the Town and Country Planning Association’s principles for Garden Cities. It is important at this stage to highlight that whilst these principles are useful and do embody a number of modern town planning concepts, they do not address the historic environment. It is therefore unclear how the TCPA principles can be reconciled with the NPPF’s definition of sustainable development in terms of its environmental strand which requires the conservation and enhancement of the historic environment. Whilst the TCPA Garden Cities Principles are silent on the historic environment, their 2017 publication “The Art of Building a Garden City” does provide a further level of detail, particularly with regards to the siting of new settlements. This publication states that, “locations for new garden cities should not only avoid damaging areas that are protected for their ecological, landscape, historic or climateresilience value but should actively be located in areas where there can be a positive impact on these assets. Underpinning the consideration of sites for new garden cities or towns should be the extent to which each one … will allow for positive impacts on assets of historic value”. (Emphasis added, pg. 100) In drafting any principles for the development of new garden communities, we would suggest that you ensure that reference is made to the need to conserve and enhance the historic environment. You will recall that we made a number of comments of proposed new settlements during the last Local Plan Review. Given that these sites are now being reconsidered as part of this Local Plan Review exercise we include our Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. comments on these new settlements for your ease of reference. WE have not taken a view at this stage as to which if any of these sites might be suitable but advise that further detailed assessment in relation to heritage will be required to inform any decision. 1. Lee Farm / 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. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. 2. Thurleigh This proposed new settlement site was a World War Two Royal Air Force and United States Army Air Force bomber airfield. The airfield was constructed in the early 1940s. In 1942-3 the runways were extended. Technical facilities were located on the east side of the airfield but have now been demolished. The airfield was designated as USAAF Station 111 by the Americans. In 1946 a temporary wind tunnel (the largest in the United Kingdom at that time) was erected on the airfield in one of the hangars but was subsequently dismantled. The airfield was rebuilt between 1951-1954 in parallel with the development of the Royal Aircraft Establishment Wind Tunnel site south from the airfield. Surrounding the airfield are a number of other designated heritage assets including grade II Blackburn Hall Farmhouse and scheduled Blackburn Hall medieval moated site which is an above average example of a Bedfordshire moat with well-preserved archaeological structures. Although partially excavated, the monument displays a wide diversity of surviving features including fishponds and a rare association with quarry pits. 3. 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. 4.Wyboston The proposed new settlement site to the east of Wyboston includes two grade II listed buildings. It is adjacent to or includes the medieval moated site of Chawston Manor. 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 Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. western enclosure is undisturbed and will also retain buried archaeological features. 5. Tempsford (mentioned in the rail growth option) We have previously provided advice to Central Beds in relation to a possible new settlement site at Tempsford. Given the proposals for a station in this broad area as part of the EWR proposals, we understand that you are exploring the potential for a new settlement in this broad location, on the boundary with Central Bedfordshire. There are a number of designated and non-designated assets in the area. These include Roxton, Tempsford – Langford End and Church End Conservation Areas, a number of listed buildings including the Church of St Peter, Church of Saint Mary Magdalen and Congregational Chapel, all listed at grade II* and numerous grade II listed buildings. There are also several scheduled monuments in the area; the Gannocks Castle moated site, Biggen Wood moated enclosure and Story Moats moated enclosure at Everton. The Hazell’s Registered Park and Garden is located to the south east in an elevated position and offers commanding views over the Tempsford area. Tempsford Airfield is a non-designated heritage asset. We would refer you to two publications which may be of use in assessing this site. The first, https://www.historicengland.org.uk/images-books/publications/nine-thousandmiles- of-concrete/ is essentially an audit of airfields. Tempsford is mentioned and is rated 1-2 (low grade) and to that end we would recommend that standard investigation would be needed to establish in any earlier airfield remains lie beneath the surface. We would also highlight the following publication: https://content.historicengland.org.uk/imagesbooks/ publications/historic-military-aviation-sites/heag048-historic-militaryaviation- sites.pdf/ In order for any of these new settlement sites to be brought forward we would expect detailed site specific evidence prepared, for example through a proportionate Heritage Impact Assessment, which could assess the impact of development on heritage assets and their settings has to the assets’ significance and what, if any, mitigation or enhancement opportunities there are within the proposal. We also would expect to see a clear justification why such sites are being preferred over alternatives where there is considerable impact on the historic environment. Without this level of detail it is difficult to advise where such large allocations are proposed. Historic England, Brooklands, 24 Brooklands Avenue, Cambridge CB2 8BU Telephone 01223 58 2749 HistoricEngland.org.uk Please note that Historic England operates an access to information policy. Correspondence or information which you send us may therefore become publicly available. Further assessment of potential impacts is necessary and any site allocation will need to be justified in terms of its heritage impacts. If taken forward for allocation, appropriate development criteria would need to be set. It may not be possible to allocate based on these impacts. g) more dispersed development throughout the borough including the expansion of villages. Any proposed growth of villages should give consideration to settlement character and identity. Development of jobs and homes should seek to conserve and enhance the historic environment through appropriate development that minimises harm to the historic environment through careful siting and appropriate design. There may be some villages that are more or less suited to absorbing additional growth, in part dependent upon their historic character and settlement morphology. Consideration will need to be given to the capacity of individual villages and their sensitivity to change. Where there is a Conservation Area Appraisal in place, this may help to inform decisions regarding potential locations for growth within villages.

Transport, IT, education, retail, community facilities re all needed to be brought forward to support new development in sustainable communities. The opportunities for achieving this may be increased by having fewer, larger developments rather than multiple small scale sites.

It will be important to capture the benefits of increased connectivity through enhanced internal linkages in the town, by ensuring that routes to the historic core of Bedford and riverside are made as accessible and permeable as possible for people connecting to East West Rail, and that this should favour less intrusive modes of transport encouraging the signposting of Bedford’s High Street and the Castle Park/Riverside Area.

The town centre of Bedford is within the Bedford Conservation Area and is packed full of beautiful listed buildings. Bedford Town Centre has been chosen as a High Street Heritage Action Zone by Historic England. This, together with the Town Centre Plan, will help to achieve physical improvements both to the buildings and streets in the town centre. Covid-19 has had a serious impact on our high streets. We therefore suggest that the Local Plan makes reference to the Heritage Action Zone and includes policies to support the regeneration of this part of the town. Policies should encourage a diverse mix of uses to encourage vitality in historic areas, and that historic and traditional details in the conservation area should be protected where possible by Article 4s.

I agree

We suggest that a policy approach to climate change, sustainable design and energy efficiency should take into account the historic environment. We invite a specific policy relating to the inclusion of renewable technologies within Conservation Areas and with regard to historic buildings and the wider historic landscape. A sustainable approach should secure a balance between the benefits that such development delivers and the environmental costs it incurs. The policy should seek to limit and mitigate any such cost to the historic environment. Listed buildings, buildings in conservation areas and scheduled monuments are exempted from the need to comply with energy efficiency requirements of the Building Regulations where compliance would unacceptably alter their character and appearance. Special considerations under Part L are also given to locally listed buildings, buildings of architectural and historic interest within registered parks and gardens and the curtilages of scheduled monuments, and buildings of traditional construction with permeable fabric that both absorbs and readily allows the evaporation of moisture. In developing policy covering this area you may find the Historic England guidance Energy Efficiency and Historic Buildings – Application of Part L of the Building Regulations to historically and traditionally constructed buildings https://content.historicengland.org.uk/images-books/publications/energy-efficiencyhistoric- buildings-ptl/heag014-energy-efficiency-partlL.pdf/ to be helpful in understanding these special considerations.

We note that you are planning to update the Landscape Character Assessment as part of the evidence base which is welcomed. Please ensure that your Historic Landscape Characterisation is up-to-date.