Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9682

Received: 26/07/2022

Respondent: Historic England

The grade II listed Octogan Farmhouse lies within the site boundary. There are multiple other listed buildings in the surrounding area including the highly graded Stables and Dovecote (both listed at grade I and also scheduled) as many grade II listed buildings. There are also numerous scheduled monuments (the Stables and Dovecote as well as a number of barrows, mortuary complex and settlement site) along the river valley. Any development of this site has the potential to impact upon these heritage assets and their settings.
This is a large strategic proposal for between 700 and 850 dwellings and other mixed uses.
A heritage assessment has been prepared for this site. Recommendations include the retention and appropriate reuse of the Octagon Farmhouse, buffer to scheduled monument, and careful masterplanning for preservation and enhancement of other assets. These recommendations have been included in the policy which is welcomed.
We broadly welcome criteria xi, xii, xiii and xiv. The policy seems well defined and the policy criteria seem appropriate. However, we suggest that other scheduled monuments are added to the list at criterion xi.

Comment

Representation ID: 9683

Received: 26/07/2022

Respondent: Historic England

We welcome the Councils intention to prepare a strategic place making framework for the major growth proposed in the area to the south of Bedford. We suggest an additional bullet point in the section to read:
• Protection and enhancement of the historic environment

Comment

Representation ID: 9684

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site, there are a number of grade II listed buildings nearby including The Cottage, Kempston House, Ramsay Cottage, Tithe Farmhouse, Wood End Farmhouse, 157 Bedford Road and a cluster of buildings at Keeley Green. Any development of this site has the potential to impact upon these heritage assets and their settings.
We note that a Heritage Appraisal has been prepared by the site promoters for the northern portions of the site. The assessment recommends set back and open space to protect the Cottage and Kempston House. These spaces are shown in Figure 6 on page 58 and will help to protect the setting of these assets.
We also welcome criterion ix which lists and number f heritage assets. We suggest adding Wood End Farmhouse and Tithe Farmhouse to the list.
We welcome criterion x but suggest that the specific mitigation measures being proposed are listed here by adding the following words: ‘including open space and landscaping to the south of Kempston House and The Cottage and north west of 157 Bedford Road as shown on figure 6’.
We welcome criterion xi and xii.

Comment

Representation ID: 9685

Received: 26/07/2022

Respondent: Historic England

This new settlement proposal is a large strategic allocation for at least 4000 homes and employment development.
The site contains a scheduled monument, The Kempston Hardwick Moated Site. Kempston Hardwick is a fine example of a Bedfordshire moated site, the interior of which is substantially undisturbed and the waterlogged moat of which provides conditions suitable for the survival of organic remains.
Manor Road is the site of the linear medieval manorial deserted village, and part of the setting of the monument is this linear settlement.
Stewartby Conservation Area and its associated listed buildings lies to the south of the site whilst Wootton Conservation Area and listed buildings lie to the west of the site.
Any development of this site has the potential to impact upon these heritage assets and their settings.
An HIA has been prepared for the western portion of the site. However, this assessment does not follow the full 5 step methodology for HIAs. It identifies assets and considers impact but does not make any recommendations regarding potential mitigation and enhancements. This should be undertaken to inform the policy.
There does not appear to be an HIA for the rest of the site. An HIA should be prepared to cover the whole site.
However, we note that the promoters supporting statement does refer to an agreed stand-off distance for the scheduled monument. However, this was negotiated in relation to a specific application for employment development rather than a larger new settlement proposal.
An HIA should also be prepared for the rest of the site that considers the context of the new settlement.
We welcome criterion vi. However, the policy needs to be more specific in relation to mitigation and enhancement measures for the scheduled monument (see requirement above for completion of HIA).
Figure 7 page 64 shows a concept diagram for the site. Our initial view, though subject to the findings and recommendations of the HIAs, is that there should be more open space to the west of the monument (removing some of the land for employment in this area) and greater set back along the line of Manor Road, leaving a wider green corridor in this area.

Comment

Representation ID: 9686

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are a number of listed buildings nearby at Duck End and Wilstead. These include All Saints Church, listed at grade II* and a variety of grade II listed buildings. Any development of this site has the potential to impact upon these heritage assets and their settings.
A historic environment desk-based assessment has been prepared for land to the south of Wixams (although the report on the website is entitled Land to the east of Wixams). The report states that there will be no impact on designated assets and does not recommend any mitigation or enhancements.
However, we consider that some planting along the eastern site boundary would help to soften and impact of the development in the landscape including any (winter) views from heritage assets in the villages to the east. Figure 8 shows green space along this eastern edge which is welcomed. This should also be referred to in the policy wording.
We welcome criterion x. It would be helpful if specific mitigation measures were included in this criterion to read ‘with appropriate landscaping along the southern and eastern boundaries of the site.’
We welcome criterion xiii.

Comment

Representation ID: 9687

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are a number of listed buildings nearby at Duck End and Wilstead. These include All Saints Church, listed at grade II* and a variety of grade II listed buildings. Any development of this site has the potential to impact upon these heritage assets and their settings.
A Heritage Impact Assessment has been prepared for the site which focuses on built heritage. This provides a useful analysis. The HIA makes a number of helpful recommendations. These include:
• Retention and incorporation of existing historic landscape features
• Careful consideration of layout scale and massing to reduce impact on heritage assets
• Landscape buffer and set back around John Bunyan Trail
• Create viewing corridors to grade II*Cardington Hangers as prominent landmark on the skyline
• Lower density and scale of development around Duck End to sustain the existing character of the lane
• Incorporate elements of the local vernacular to retain the local distinctiveness of the area
We recommend that these measures should be included in the policy wording.
Whilst we broadly welcome criterion xii it should be expanded to include the specific mitigation recommended in the HIA.
We welcome criterion xiii.

Comment

Representation ID: 9688

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, there are a number of listed buildings nearby including Cardington number 1 and number 2 sheds, both listed at grade II* and several grade II listed buildings at Harrowden. The impact on the historic airfield setting is also important. Any development of this site has the potential to impact upon these heritage assets and their settings.
The open space around the sheds was of critical functional importance and contributes to their significance as heritage assets. The massive scale of the sheds within the open space of the flying field and the surviving landscape beyond speaks to the function of the buildings and combine to make the sheds extraordinary structures that dominate the landscape to the south of Bedford acting as local landmarks.
The Masterplan drawing shows that a large proportion (roughly half) of the development would be sited to the west of the existing settlement, where there is no discernible spatial relationship with, or uninterrupted views of the hangars.
However there would also be a significant amount of development to the south of Shortstown and directly opposite the west doors of the hangars, which would is likely to have some effect on some medium and longer distance of the hangars, affecting, to some extent, the way in which these heritage assets are experienced and appreciated. Very careful attention to layout and siting of development will be critical here, as well as massing and building heights, in order to minimise impact.
A Heritage Appraisal has been prepared for the site. It focuses on built heritage, in particular the Cardington sheds. It does not consider the listed buildings in Harrowden.
The Heritage Appraisal considers the issue of views to the sheds and suggests that that southern portion of the site is left open to retain these views. This is reflected in the concept plan at Figure 9 which is welcomed However, it should also be referred to in the policy, perhaps at criterion viii. Additional wording could read ‘open space in southern portion of the site to retain important views to Cardington sheds’.
We broadly welcome criteria xii and xiii but again suggest that reference is made to the need to maintain open space and key views to the sheds. We also suggest that the design of the development as well as the open space and landscaping will also be important and should draw on its historical aviation context for inspiration. This should be included in the policy wording.

Comment

Representation ID: 9689

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary, the site lies immediately adjacent to the grade II listed Cardington Railway Station. It is also close to the grade II* listed Cardington sheds whilst to the east lies Cardington Conservation Area with its associated listed buildings (including the grade II* Howards House and grade II Registered Park and Garden to Howards House). Any development of this site has the potential to impact upon these heritage assets and their settings.
This site not quite as sensitive as HOU17 given that it is in an area where lots of other residential development has been approved in recent years. However, it is important that to ensure that development is grounded in a thorough understanding of the context and in particular the setting ,and ensuring that layout, siting, massing etc is appropriate so that development is in deference to the hangars.
A Heritage Appraisal has been prepared for this site. The appraisal makes a number of recommendations for the site including:
• Maintain channelled views between the station and hangers
• Retain vegetation and eastern and south eastern boundary of the site
• Sensitively placed built form with massing that does not compete with the hangers
These recommendations should be included in the policy wording.
We broadly welcome criteria vi and vii. We suggest adding the following after Conservation Area ‘and associated listed buildings and Registered Park and Garden’

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.

Comment

Representation ID: 9691

Received: 26/07/2022

Respondent: Historic England

There are a number of designated heritage assets within the site boundary including St Denys Church (grade II*), Lower Farmhouse, a barn north of Lower Farm Farmhouse, and 1-4 – a row of cottages, all listed at grade II. There are also a number of other grade II buildings nearby, notably across the River Great Ouse. Any development of this site has the potential to impact upon these heritage assets and their settings.
New Manor House lies within the site boundary. Although not currently listed, this is an interesting building, dating from the 19th century.
There are extensive earthworks across the central part of the site comprising a complex, intact, good quality medieval landscape, largely untouched, including a Deserted Medieval Village and Ridge and Furrow.
A heritage impact assessment has been prepared for this site. An Archaeology DBA has also undertaken which are welcome.
The HIA and DBA reveal that there are extensive earthworks, a rich palimpsest and good quality medieval landscape in the central portion of the site. There is also an unlisted Manor House and associated buildings within the site boundary.
We do therefore have concerns about the potential impact of development on the historic environment in this area. We need a better understanding of its significance in order to make the judgement.
We note that the Historic Environment Topic Paper concurs that there is insufficient information, particularly in relation to archaeology and therefore suggests a detailed HIA to inform the masterplan. But in Historic England’s view, that would be too late. The principle of development would already have been established.
Historic England therefore strongly advise that further assessment of this area is required now to better understand the significance of this landscape.
We will also asking Historic England’s designation team to investigate whether parts of the site should be scheduled and whether the Manor House and associated buildings should be listed.
Depending on the findings of these assessments, this may affect the developable area and thus capacity of the site.
Significant further work is necessary now before progressing the site to EiP. Without the further evidence to support the allocation, the allocation is not justified and fails the test of soundness.
We strongly suggest an early meeting between BBC and Historic England to explore this issue in more detail. Notwithstanding this need for additional evidence, if upon further assessment, the site is found to be broadly suitable for development as a new settlement, the HIA makes a number of recommendations in relation to mitigation for heritage assets (broadly based on an illustrative masterplan) including:
• Retention of existing woodland and planting
• Retain open and green setting by Church of St Denys and the New Manor House
• Retain open area to the west of Lower Farm
• View corridors adjacent to heritage assets on east of Barford Road with open space to the south east
• Use local materials to create attractive and distinctive places where views of the surrounding rural context area maintained
• Careful masterplanning, and consideration of design, scale and built form
• Open space and woodland retained around former Council school
These measures are a helpful starting point in setting some of the important heritage parameters for the site but will need to be further refined in light of the findings of the additional assessment.
However, these recommendations are not currently set out in the policy or on the concept diagram. Also, the main heritage assets on site are not listed in the policy. The policy and diagram should be amended to incorporate these recommendations (and any others identified) and reference to the designated heritage assets.