Bedford Borough Local Plan 2040 Plan for Submission

Object

Representation ID: 9671

Received: 26/07/2022

Respondent: Historic England

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Whilst there are no designated heritage assets within HOU5, the site lies to the south-west of a very high concentration of heritage assets in Elstow - one of the key jewels in Bedford’s heritage crown.
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.
The setting of the Elstow Abbey in particular (comprising the Manor House Scheduled Monument, Grade I listed Hillersdon House, Grade I listed Church of St Mary and St Helena, and Grade I listed Church Tower) within the meadows, and views of the Abbey from the approach into Bedford along the A6 are important.
We welcome the preparation of an HIA for the site which considers both built heritage and archaeology but consider that it downplays the contribution made by the wider setting of Elstow Abbey to its heritage significance.
Although the significance of the heritage assets comprising Elstow Abbey are drawn primarily from their immediate setting and architectural, archaeological, historic interests, nonetheless their importance is enhanced by their landscape context and wider rural setting.
Elstow Abbey sits in a typical location for a monastery/nunnery. Monasteries and other religious institutions were reliant upon their wider agricultural estate to support them and were often sited away from large conurbations to provide an area of peace and reflection away from the outside world. The wider rural setting is important to the experience of the Abbey as a place of worship, and local landmark, as well as illustrating its historic association with agriculture. It therefore makes an important contribution to its significance.
While we acknowledge that the land immediately to the south and west of the Abbey is to be retained as green open space, nonetheless any built development within HOU5 would divorce the Abbey from its wider rural context, altering its historic illustrative value as a rural monastic site, and thereby resulting in a loss of significance. We do not consider that there is any potential for further mitigation since any measures which retain the open character would render the developable area too small for a viable allocation. We therefore recommend that the site is deleted.
If you are minded to proceed with this allocation, then further landscape work specifically considering the wider setting of Elstow Abbey will need to be produced in advance of the EiP, setting out with appropriate justification where development could be sited. This further work should then inform revisions to policy wording to establish key design parameters for the site. We would be grateful to have a conversation with you to agree the scope of this further work with you.
While we note that there is reference to a Landscape and Visual Appraisal (LVA) in the Vision Strategy (Savills, August 2020), we have been unable to access it. Without having had the opportunity to review this technical work, we have been unable to determine whether it satisfies the concerns and next steps that we have outlined above.
Without this further evidence, the allocation is not justified and therefore is not sound.

Comment

Representation ID: 9672

Received: 26/07/2022

Respondent: Historic England

The site is located to the east of the grade II* St Mary’s Church. Any development of this site has the potential to impact upon the heritage asset and its setting.
We welcome the preparation of an HIA for the site which considers both built heritage and archaeology. The HIA does not give clear recommendations for the site, but it does hint at this in terms of maintaining scale and making reference to sensitive design. However, the criteria i, ii, iii in the policy represent a helpful response to the HIA.
The policy could be further improved with a diagram to show the proposed extent of the open space to protect the church.
We welcome criterion x.

Comment

Representation ID: 9673

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets within the site boundary or nearby.
No comments.

Comment

Representation ID: 9674

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the grade II listed Sailors Bridge Cottages lie to the south east of the site. Any development of this site has the potential to impact upon the heritage asset and its setting.
We understand that there is no heritage impact assessment for the site. Given the proximity of the grade II cottages we recommend you prepare a brief, proportionate HIA. The recommendations of the HIA should then be used to inform the policy wording.
We welcome criteria v and vi.

Comment

Representation ID: 9675

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets within the site boundary or nearby.
No comments.

Comment

Representation ID: 9676

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets within the site boundary. Bedford Cemetery, a grade II registered park and garden lies to the south of the site but due to the intervening development, the development of the proposed site is unlikely to have an impact on the significance of the park and garden.

Comment

Representation ID: 9678

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the grade II listed Woodlands Lodge, an early nineteenth century Picturesque lodge with whitewashed roughcast exterior and a thatched roof, lies to the north west of the site. Any development of this site has the potential to impact upon the heritage asset and its setting.
Given the distance, the impact is likely to be minimal. However, it would be helpful if the north west boundaries of the site could be carefully landscaped to minimise impact on the designated heritage asset. Therefore, we recommend that the first criterion is amended to read ‘landscape, visual and heritage impact issues’.
We welcome criterion v.

Comment

Representation ID: 9679

Received: 26/07/2022

Respondent: Historic England

There are no designated heritage assets within the site boundary or nearby.
No comments.
We welcome criterion v.

Comment

Representation ID: 9680

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are several scheduled monuments to the south of the river. These cropmark sites have been partly excavated. The Howbury Hall Estate, including several listed buildings, lies to the north of the site. The site lies adjacent to the non-designated earthwork of Risinghoe Castle. We have previously advised that this merits further assessment through a Heritage Impact Assessment (HIA). There is also high potential for other buried archaeological remains at the allocation site based on elsewhere along the valley floor. Any development of this site has the potential to impact upon these heritage assets and their settings.
A heritage assessment was prepared to accompany a planning application for this site in 2019.
The heritage impact assessment helps further our understanding of the Castle. Further to our site visit, and in light of the HIA, we understand that the archaeological advisers at BBC are satisfied that the castle is of regional importance and is not likely to meet the criteria for scheduling. To that end, Historic England is content to leave the decision to BBC in this regard.
We welcome criterion iv and v. However, no detail is given of the mitigation or enhancement required. These measures should be informed by the heritage assessment, and development management process and then the wording incorporated into the policy.
The heritage assessment recommends the following mitigation measures:
• Geo-physical survey followed by trail trench evaluation
• Careful design in particular in relation to height and density to minimise harm to the setting of the Castle • Sensitive landscaping along the southern boundary and careful landscaping to enhance the immediate setting of the Castle mound
We suggest that these measures are incorporated into the policy wording.

Comment

Representation ID: 9681

Received: 26/07/2022

Respondent: Historic England

a) Bedford Blues Rugby Club
Whilst there are no designated heritage assets within the site, the Bedford Conservation Area lies immediately to the south of the site and the grade II listed Shires House lies to the north west of the site. Any development of this site has the potential to impact upon these heritage assets and their settings. We therefore welcome the reference to the listed building and conservation area on page 129. Prior to allocation and/or determination a heritage impact assessment will be required. This requirement should be added on page 129.
b) Jowett Sidings and Royal Mail Depot, Midland Road, Bedford
Whilst there are no designated heritage assets within the site, the Bedford Conservation Area lies to the south east of the site, close to the river. The development at Crown Quay provides a buffer between the sidings site and the conservation area. It will be important for any new Development to preserve, or where opportunities arise, enhance the character or appearance of the Conservation Area and its setting.