Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9692

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site boundary there are a number of assets nearby. These include a number of grade II listed buildings, in particular 52 Green End immediately to the north of the site and other listed buildings in Workhouse End and a cluster of listed buildings associated with Howbury Hall to the west of the site. To the south of the A421 lie a number of other grade II listed buildings as well as a series of scheduled monuments including Howbury Ringwork and medieval trackway, several barrows, a henge and Hengi form monument. Any development of this site has the potential to impact upon these heritage assets and their settings.
A heritage appraisal has been prepared for the site. However, the appraisal doesn’t make any recommendations for the site in terms of mitigation and enhancement measures. The heritage appraisal should be reviewed to include recommendations for the site.
We broadly welcome criteria v, vi and vii. However, vii should be amended to include specific mitigation measures and enhancements informed by the revised heritage appraisal.

Comment

Representation ID: 9693

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site, there is a grade II listed building, Brook Cottages, to the north of the site. To the south of the site lies to scheduled monument, Tempsford Bridge which is also grade II listed. Any development of this site has the potential to impact upon these heritage assets and their settings.
A heritage appraisal has been prepared for the site. However, the appraisal only considers the bridge and not the cottage to the north. The appraisal doesn’t make any recommendations for the site in terms of mitigation and enhancement measures. The heritage appraisal should be reviewed to include recommendations for the site.
Given the scale of the proposed employment development including warehousing and distribution, it is our view that development is likely to have an impact on the setting of the bridge.
The appraisal should make recommendations in relation to heights, mass, colours, materials and landscaping to help mitigate the impact of the development upon heritage.
We broadly welcome criterion v. There should be an additional criterion to refer to nearby heritage assets and including specific mitigation measures and enhancements informed by the revised heritage appraisal.

Comment

Representation ID: 9694

Received: 26/07/2022

Respondent: Historic England

Whilst there are no designated heritage assets within the site, the Roxton Conservation Area and associated listed buildings including the grade II* Church of St Mary Magdalen lies to the south west of the site. Tempsford Bridge scheduled monument and listed structure lies to the south east of the site. Any development of this site has the potential to impact upon these heritage assets and their settings.
An initial heritage assessment has been prepared for the site. The assessment identifies some harm, albeit less than substantial harm by the proposed development. The assessment makes some broad recommendations about open space buffers and landscaping but is not specific about where these should be. We suggest that the heritage assessment is revisited to confirm the mitigation needed, including considering the issue of heights etc and the impact on the nearby heritage assets and their settings.
These recommendations should then be incorporated into the policy wording of the Plan.
The site appears to come very close to the listed farm at the northern end of the Conservation Area which would presumably include land that was historically associated with the farm. Therefore we suggest some public open space here would help retain the setting’s essential character.
There is also intervisibility between the site and the Church and therefore careful considerations with regard to layout, siting, heights etc will be crucial in mitigating the visual impacts. We suggest that these requirements are included in the policy wording.
Criterion vii should be made more specific about mitigation (including recommendations from the revised HIA, as well as the suggested open space, and careful consideration of layout, siting and heights) and presumably it is cross referencing criteria vi rather than iv as currently worded.

Comment

Representation ID: 9695

Received: 26/07/2022

Respondent: Historic England

We welcome reference to the High Street Heritage Action Zone

Comment

Representation ID: 9696

Received: 26/07/2022

Respondent: Historic England

We suggest that criterion ix specifically mentions the historic environment (we appreciate that policy 41S is the historic environment policy).

Comment

Representation ID: 9697

Received: 26/07/2022

Respondent: Historic England

We note that this policy refers to policy 42S. Should it also refer to 41S? Do the policies need to cross refer to other policies? If so, important to be consistent for natural and historic environment, but if not, then may not be needed.

Comment

Representation ID: 9698

Received: 26/07/2022

Respondent: Historic England

Add the following text at the end of the paragraph: ‘Not everything within the HER is a non-designated heritage asset.’

Comment

Representation ID: 9699

Received: 26/07/2022

Respondent: Historic England

We welcome this new policy. It provides a helpful framework for the identification of non-designated heritage assets.
The main framework for decision making in relation to NDHA is still to be found in Policy 41S.

Comment

Representation ID: 9700

Received: 26/07/2022

Respondent: Historic England

We broadly welcome the new tall buildings policy. It is helpful to have an overarching policy framework for tall buildings going forward, particularly given the growth pressures that Bedford is likely to experience in the future. We very much welcome the commitment to prepare and SPD to assist with the application of this policy. There are still a number of questions that will need to be explored and addressed through the SPD including as assessment of the current skyline, methodology for assessment of proposals (LVIA, photomontages, VuCity, wireframes etc.), identification of key views and finally assessment of, and designation of, areas considered inappropriate for tall buildings.
We look forward to reviewing the SPD.

Comment

Representation ID: 9701

Received: 26/07/2022

Respondent: Historic England

We welcome the commitment to monitoring and review of the policies in the Local Plan. We recommend indicators to measure how successful historic environment policies are. These can include preparation of a local list, completion of conservation area action plans and management plans, reduction in the number of assets that are classified as heritage at risk.