Bedford Borough Local Plan 2040 Plan for Submission

Comment

Representation ID: 9702

Received: 26/07/2022

Respondent: Historic England

See comments above on Opportunity Sites

Comment

Representation ID: 9703

Received: 26/07/2022

Respondent: Historic England

We welcome this Appendix. It helpfully sets out the criteria for identifying non-designated heritage assets in the borough.

Comment

Representation ID: 9704

Received: 26/07/2022

Respondent: Historic England

Add Registered Park and Garden, Significance and Setting

Comment

Representation ID: 9711

Received: 26/07/2022

Respondent: Historic England

Thank you for consulting Historic England on the Bedford Borough Local Plan 2040:
Plan for Submission. As the Government’s adviser on the historic environment, Historic England is keen to ensure that the protection of the historic environment is
fully considered at all stages and levels of the local
planning process.
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.
It is for this reason that Historic England is keen to ensure that the emerging plan gives full consideration to the historic environment, both in the choice of site allocations and policy criteria for sites, as well as through a robust and clear suite of historic environment and other policies that seek to both protect but also enhance the historic environment.
We have reviewed the Regulation 19 Plan and
consultation material with a view to providing advice on heritage matters. As a general comment, Historic England welcomes emerging plan and work undertaken to date.
Whilst we consider many aspects of the plan to be sound, we have identified issues with some of the policies and site allocations which do compromise the overall soundness of the plan.
Under paragraph 35 of the National Planning Policy Framework, some aspects of this Plan are unsound as they have not been positively prepared, are not justified,
effective, or consistent with national policy.
We have summarised below in this letter some of the key issues to be addressed. We have also identified in detail where we find the Plan unsound and what
measures are needed to make the Plan sound. These detailed comments are in the Table at Appendix A which provides more detailed comments on these and other
more minor issues.
In summary we highlight the following 2 key issues: sites and heritage impact assessments.

In preparation of the Bedford Local Plan, we encourage you to draw on the knowledge of local conservation officers, archaeologists and local heritage groups.
Please note that absence of a comment on an allocation or document in this letter does not mean that Historic England is content that the allocation or document forms
part of a positive strategy for the conservation and enjoyment of the historic environment or is devoid of historic environment issues.
Finally, we should like to stress that this opinion is based on the information provided by the Council in its consultation. To avoid any doubt, this does not affect our
obligation to provide further advice and, potentially, object to specific proposals, which may subsequently arise where we consider that these would have an adverse effect upon the historic environment.

Comment

Representation ID: 9713

Received: 26/07/2022

Respondent: Historic England

We have considerable concerns about the suitability of this site for residential development, and therefore recommend that the site is deleted.
However, if you are minded to proceed with this allocation, then further landscape work specifically considering the wider setting of Elstow Abbey and the rural approach into Bedford, 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.

Comment

Representation ID: 9714

Received: 26/07/2022

Respondent: Historic England

We have raised some concerns about the suitability of this site for employment development.
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.

Comment

Representation ID: 9715

Received: 26/07/2022

Respondent: Historic England

We have considerable concerns about the suitability of parts of this site for development.
Further assessment of this area is required prior to EiP to better understand the significance of this landscape.
We will also be 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.
If, following further assessment, the site is found to be broadly suitable, the policy should be amended to incorporate reference to specific heritage assets. The
various heritage mitigation and enhancement recommendations for the site (identified in the HIA and further assessment) should also be included in the
policy wording. (see table for details). The diagram should also be amended to incorporate these recommendations.
Without this further evidence these allocations are not justified and so are not sound.

Comment

Representation ID: 9716

Received: 26/07/2022

Respondent: Historic England

We welcome the preparation of heritage impact assessments for many of the sites.
This is an important part of the evidence base and helps to justify the allocation and policy requirements for sites.
However, there are a number of issues in relation to the sites and HIAs.
For some sites, there does not appear to be an HIA and yet there are heritage issues
that need to be addressed.
These include sites HOU2, HOU8 and parts of HOU14.
In these cases, please prepare a proportionate HIA prior to EiP and use the recommendations to inform policy wording.

Comment

Representation ID: 9717

Received: 26/07/2022

Respondent: Historic England

For some sites, there does not appear to be an HIA and yet there are heritage issues that need to be addressed.
These include sites HOU2, HOU8 and parts of HOU14.
In these cases, please prepare a proportionate HIA prior to EiP and use the recommendations to inform policy wording.

Comment

Representation ID: 9718

Received: 26/07/2022

Respondent: Historic England

For some sites, there does not appear to be an HIA and yet there are heritage issues that need to be addressed.
These include sites HOU2, HOU8 and parts of HOU14.
In these cases, please prepare a proportionate HIA prior to EiP and use the recommendations to inform policy wording.