Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9656

Received: 26/07/2022

Respondent: Historic England

We welcome the reference to the consideration of heritage in relation to retrofitting buildings at Avii.

Comment

Representation ID: 9657

Received: 26/07/2022

Respondent: Historic England

We welcome the reference to the revision of the Design Guide and references to design codes. This provides a helpful framework and context for Design policy and guidance going forward. It will be important to follow the emerging policy in relation to Design Codes under the Levelling Up and Regeneration Bill.

Comment

Representation ID: 9658

Received: 26/07/2022

Respondent: Historic England

We welcome the reference to the revision of the Design Guide and references to design codes. This provides a helpful framework and context for Design policy and guidance going forward. It will be important to follow the emerging policy in relation to Design Codes under the Levelling Up and Regeneration Bill.

Comment

Representation ID: 9659

Received: 26/07/2022

Respondent: Historic England

The site is located adjacent to the Bedford Conservation Area. Any development of this site has the potential to impact upon the Conservation Area and its setting.
We welcome criterion viii in relation to Bedford Conservation Area.

Comment

Representation ID: 9662

Received: 26/07/2022

Respondent: Historic England

We suggest it would be helpful to refer to the SPD.

Comment

Representation ID: 9663

Received: 26/07/2022

Respondent: Historic England

A small part of the Bedford Conservation Area lies within the site boundary, while other parts of the Conservation Area lie adjacent to the site. There are several grade II listed buildings nearby along Bromham Road. Any development of this site has the potential to impact upon these assets and their settings.
We note that a heritage appraisal has been prepared for the site. The appraisal raises some concerns about the capacity of the allocation and the likely density of any development having a negative impact on the heritage assets and their settings.
The appraisal discusses the need for careful siting, design and materials as well as the need for building heights to step down near the conservation area and heritage assets. These measures are currently not articulated in the policy. The policy should be amended to include these mitigation measures and further consideration should be given to the capacity of the site. We advise that the site capacity may need to be reduced.
We welcome the reference to heritage assets in criterion 1. However, we recommend changing the wording from ‘preserve…heritage assets’ to ‘Development should conserve or where appropriate enhance the significance of heritage assets (noting that significance may be harmed by development within the setting of an asset) including…’.

Comment

Representation ID: 9665

Received: 26/07/2022

Respondent: Historic England

We welcome the reference to the High Street HAZ

Comment

Representation ID: 9666

Received: 26/07/2022

Respondent: Historic England

The site is located within the Bedford Conservation area and includes the grade II* listed Harpur Suite, the Grade II listed Corn Exchange and the remains of the George Inn which is a scheduled monument. The Corn Exchange was recently listed. The area has been part of the Heritage Action Zone. There are a number of listed buildings nearby, most notably St Pauls Church and the Statue of John Howard, both listed at grade I and numerous grade II listed buildings.
Any development of this site has the potential to impact upon the heritage assets and their settings. Therefore, we recommend you prepare an HIA. The HIA should also draw on the new research and values from the Heritage Action Zone.
The recommendations of the HIA should then be used to inform the policy wording
We note the reference to an HIA as the first stage in the masterplanning process. It is indeed important for an HIA to inform the masterplanning.
However, ideally a brief HIA should be prepared now and the recommendations for the HIA should be used to inform the policy wording in the Plan.
vi. Whilst we broadly welcome this criterion, it may be better to use the following wording, given multiple asset types. ‘Development should conserve or where appropriate enhance the significance of heritage assets including the Conservation Area and listed buildings (noting that significance may be harmed by development within the setting of an asset)’.
vii We welcome criterion vii.
viii We welcome criterion viii

Comment

Representation ID: 9667

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets on the site or in the immediate surrounding area.
No comments

Comment

Representation ID: 9668

Received: 26/07/2022

Respondent: Historic England

The site is located within the Bedford Conservation Area and there are a number of grade II listed buildings nearby including 2-28 The Grove and 12-16 Newnham Street.
Any development of this site has the potential to impact upon the heritage assets and their settings.
We welcome the preparation of an HIA for the site which considers both built heritage and archaeology. The HIA noted the importance of sympathetic materials, design scale and massing and so we welcome the reference to the preparation of a design code for the site.
The HIA also identified harm to the heritage significance of the Conservation Area if high density residential development as presented by the LPA for the purposes of the HIA was pursued. It is unclear from the Plan what capacity and density the Council is seeking for this site. The capacity of the site should be reviewed in light of the HIA findings and the policy should be clearer in this regard.
We welcome the criterion iv and ix.