Power Court West End and East End Luton Town Football Club Luton

Heritage Desk-Based Assessment

for 2020 Developments (Luton) Ltd

on behalf of Luton Town Football Club

CA Project: 660708 CA Report: 16279

February 2021 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Power Court West End and East End Luton Town Football Club Luton

Heritage Desk-Based Assessment

CA Project: 660708 CA Report: 16279

Elizabeth Pratt, Assistant Heritage Consultant, and Sophie Martin, Assistant prepared by Heritage Consultant

date June 2016 (updated February 2021)

checked by Rob Sutton, Head of Heritage Consultancy

date June 2016 (updated February 2021)

approved by Nathan Blick, Principal Heritage Consultant

signed

date June 2016 (updated February 2021)

issue 01

This report is confidential to the client. Cotswold Archaeology accepts no responsibility or liability to any third party to whom this report, or any part of it, is made known. Any such party relies upon this report entirely at their own risk. No part of this report may be reproduced by any means without permission.

Cirencester Milton Keynes Andover Exeter Suffolk Building 11 Unit 8 – The IO Centre Stanley House Unit 1 – Clyst Units Unit 5, Plot 11 Kemble Enterprise Park Fingle Drive Walworth Road Cofton Road Maitland Road Cirencester Stonebridge Andover Marsh Barton Lion Barn Industrial Gloucestershire Milton Keynes Hampshire Exeter Estate GL7 6BQ Buckinghamshire SP10 5LH EX2 8QW Needham Market MK13 0AT Suffolk IP6 8NZ

t. 01285 771022 t. 01908 564660 t. 01264 347630 t. 01392 573970 t. 01449 900120 f. 01285 771033 e. [email protected]

CONTENTS

1. INTRODUCTION ...... 6

Location and landscape context ...... 6 Scope ...... 6

2. METHODOLOGY ...... 8

Data sources ...... 8 Recorded heritage assets ...... 9 Assessing significance ...... 10 Assessing harm (impact or effect) ...... 11

3. PLANNING POLICY CONTEXT ...... 13

Legislative framework, national planning policy and relevant sector guidance .... 13 Planning (Listed Buildings and Conservation Areas) Act (1990) ...... 13 Local planning policy ...... 14 National Planning Policy Framework (NPPF; 2012) ...... 16

4. HISTORICAL DEVELOPMENT OF THE SITE AND STUDY AREA ...... 18

Topography, geology and the palaeoenvironment ...... 18 Pre-Holocene activity (c.500,000 – 10,000BC) ...... 18 Fulk de Breaute’s castle ...... 21 Post-Medieval (1540 – 1800) and Modern (1800 – present) Luton ...... 27

5. SUMMARY OF ARCHAEOLOGICAL POTENTIAL AND SIGNIFICANCE ...... 39

Potential for archaeological remains ...... 39 Previous Impacts ...... 41

6. SETTING OF HERITAGE ASSETS ...... 43

Plaiters Lea Conservation Area ...... 43 Grade I Listed Church of St. Mary ...... 45

7. IMPACT ASSESSMENT ...... 51

Summary of Proposals ...... 51 Impacts upon buried archaeology ...... 51 Impacts upon designated heritage assets ...... 52

8. CONCLUSIONS ...... 53

9. REFERENCES ...... 55

1 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

APPENDIX A: GAZETTEER OF RECORDED HERITAGE ASSETS AND OTHER ELEMENTS OF THE HISTORIC ENVIRONMENT ...... 62

LIST OF ILLUSTRATIONS (interleafed between pages of report)

Fig. 1 Site location plan showing nearby designated heritage assets Fig. 2 Prehistoric and Roman landscape Fig. 3 Medieval Luton Fig. 4a Previous archaeological investigations of Fulk de Breaute’s castle complex Fig. 4b North-west facing section through the southern arm of the castle moat Fig. 5 Post-Medieval and Industrial Luton Fig. 6 Model of archaeological potential

LIST OF ILLUSTRATIONS (within text)

Fig. A Extract from Plan of Luton (1855), showing the supposed earthwork of Fulk de Breaute’s castle (labelled ‘6’). Red lines show the Site. Fig. B Projected line of the moat surrounding Fulk de Breaute’s castle complex derived from Woodley and Abrams 2012, superimposed on the Luton Tithe Map, 1842. Redlines show the Site. Fig. C Plan of St. Mary’s Vicarage (1845) Fig. D Todd’s Pictorial Map (1865), showing St. Mary’s Church and Vicarage Fig. E Photograph of St. Mary’s Church, St. Mary’s Vicarage and Girls’ School (1895) Fig. F Postcard of St. Mary’s Vicarage (1900) Fig. G First Edition Ordnance Survey Map (1880) Fig. H Second Edition Ordnance Survey Map (1901) Fig. I Ordnance Survey Map (1924) Fig. J View of the Power Court cooling towers from the north-west facing elevation of St. Mary’s Church (1938) Fig. K Current view towards Power Court from the north-west facing elevation of St. Mary’s Church (2016) Fig. L Aerial photograph of Power Court, taken on 27th September 1947 Fig. M The Power Court cooling towers are a prominent feature on the Luton skyline in this photograph taken from the railway station in 1962

2 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. N View of the cooling towers from Church Street, taken in 1966 Fig. O Aerial photograph of Power Court, taken on 14th April 1969 Fig. P Ordnance Survey Plan (1968 – 1978) Fig. Q Google Earth satellite imagery of Power Court (2010) Fig. R Looking north towards the Site from Church Street (2016)

Photo 1 Primary façade (north-west facing elevation) of St. Mary’s Church Photo 2 View of the tower of St. Mary’s Church from the churchyard path Photo 3 Looking south-west towards St. Mary’s Church from St. Mary’s Road Photo 4 Glimpse of St. Mary’s Church tower from the junction of Power Court, St. Mary’s Road and Church Street Photo 5 Pedestrian thoroughfare beneath the tower of St. Mary’s Church Photo 6 Glimpsed view of St. Mary’s Church from St. Mary’s Road

3 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

SUMMARY Project Name: Power Court Site, Luton Town Football Club Location: Power Court, St. Mary’s Road, Luton NGR: TL 0966 2131

Cotswold Archaeology was commissioned by 2020 Developments (Luton) Ltd, on behalf of Luton Town Football Club, to update a Heritage Desk-Based Assessment for a revised development proposal for a residential and retail development site with associated access routes and parking at Power Court in the centre of Luton. The revised development site is located to the east and west of the approved stadium location, which does not form part of the application. The objective of the assessment was to identify the nature, extent, character and condition of the heritage resource both within the Site and its immediate environs, in advance of the construction of multi-storey residential and retail units, and associated infrastructure.

Sources consulted for this assessment indicate a complex sequence of historical development within the Site. Programmes of archaeological work at Park Square, c.150– 250m to the south of the Site, have identified buried remains of the castle that was established by Fulk de Breaute in AD1221. Woodley and Abrams (2012) have proposed that the north-eastern part of the castle complex (including the arm of its moat) extended across what is now St. Mary’s Road and into the southern corner of the Site. Their projected line of the moat is not well-supported by documentary and archaeological evidence; but there is nevertheless potential for buried remains of Fulk de Breaute’s castle to occur within the Site. Feeder channels from the River Lea and/or sections of the moat could survive at more than 1m below current ground level, and be relatively undisturbed by 19th and 20th century development.

A medieval mill and a river crossing may have been located in the north-western corner of the Site, but any structural evidence of these features is likely to be fragmentary. Along the now culverted corridor of the River Lea, there could be waterlogged palaeoenvironmental and archaeological evidence of medieval activity. The Site was probably under pasture for much of the post-medieval period, prior to the construction of St. Mary’s Vicarage in the early 18th century, located between the Site locations. Multiple phases of residential and industrial development then occurred within and in the immediate vicinity of the Site from the late 19th century onwards, as shown by historic mapping. There will likely be truncated buried remains of Victorian and Edwardian terraced housing and 20th century industrial buildings; but such remains would be of little archaeological interest.

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A detailed settings assessment was undertaken for the Grade I Listed St. Mary’s Church. The Site does not form part of the setting of the church that contributes to its heritage significance. The primary elevation of St. Mary’s Church is its north-west facing elevation, which presents a number of features of architectural interest that are best appreciated from Church Street and the paths through the churchyard. Historical associations between St. Mary’s Church and Fulk de Breaute’s castle and St. Mary’s Vicarage, which formerly stood c.60m to the east of the western extent of the Site, are no longer recognisable within the present-day townscape; and views from the churchyard towards Hart Hill, and from the church tower towards Luton Cemetery, are incidental, and largely screened by the approved stadium building. The proposed development of residential and commercial units will introduce additional, substantial built form c.20m to the north of St. Mary’s Church, but this change to setting is not considered to be harmful to heritage significance. Indeed, the application for the stadium has already been approved, which lies within proximity to the Church, and the nearest proposed building (Block E) is also unchanged in terms of height and mass from the extant consent. The settings assessment concluded that the proposed residential and commercial development has the potential to foster greater public appreciation of the Church.

Step 1 of Historic England’s settings guidance was undertaken for other designated heritage assets in the surrounding townscape. Particular attention was given to the Plaiters Lea Conservation Area, on account of its proximity to the Site, and its extension in 2020. However, the Site is not an element of the setting that contributes to its heritage significance. Thus, whilst the proposed development will be visible from within the Conservation Area (in views towards Hart Hill), the character and appearance of the Conservation Area will not be harmed.

In summary, no overriding heritage constraints to the proposed development have been identified. However, there is potential for archaeological remains to occur within the Site; a scope of further archaeological works in advance of and during construction will need to be agreed with relevant heritage consultees at the Local Planning Authority.

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O N 0 READING © Crown copyright and database rights copyright 2020© Crown 010003167 Ordnance Survey PROJECT TITLE Power Court, Luton, Bedfordshire FIGURE TITLE Site location plan showing nearby designated heritage assets WEST DRAWN BY DRAWN CHECKED BY APPROVED BY RDSHIRE ERKSHIRE RE O I B

510000

Windmill Road A505

Park Town Park ParkTown

Crescent Road Road Road A6 A6 Crescent Crescent

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Hitchin Road Road Hitchin Hitchin St Mary’s Church St Mary’s St Mary’s Church St Mary’s

St Mary’s Road

High Town Conservation Area Town High High Town Conservation Area Town High

A505 A505

University of Bedfordshire Bedfordshire of of University University

Park Square Square Park Park

Railway station station Railway Railway

509000 Town Centre Conservation Area Area Town New Bedford Road Centre Conservation Area Town

Stuart’s Street A505

New Bedford Road A6 Plaiters Lea Conservation Area Area

Telford Way A6 A6 Way Way Telford Telford 222000 221000 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

1. INTRODUCTION

1.1 Cotswold Archaeology was commissioned by 2020 Developments (Luton) Ltd, on behalf of Luton Town Football Club, to update a Heritage Desk-Based Assessment of a proposed development site at Power Court in the centre of Luton. The objective of the assessment was to identify the nature, extent, character and condition of the heritage resource both within the Site and its immediate environs, in advance of the construction of multi-storey residential and retail units, and associated infrastructure.

Location and landscape context 1.2 The Site is located in the centre of Luton, immediately to the south-east of the railway station. The Site comprises two parcels, separated by the location of the approved stadium proposal, that forms part of the extant consent and the assessment baseline. The ‘West End’ comprises a 2ha portion of land bordering Church Street in the north. The ‘East End’ comprises a 1.2ha portion of land bordering Crawley Green Road in the south. The East and West Ends are the subject of the current outline application. The proposed development comprises a residential-led, mixed use development, in line with the extant consent. The residential blocks will be supported by ground floor town centre uses such as retail, food and beverage outlets and including a health centre in the East End.

1.3 The Site is bounded to the north by the Luton–Dunstable Busway, which traces the railway line; and the routes and interchange of Church Street/St Mary’s Road (to the south-west) and Crawley Green Road (to the south-east). The Mall (a large shopping centre) and the Grade I Listed St Mary’s Church are located on the opposite side of St Mary’s Road, c.20m to the south-west and c.20m to the south respectively. The Site was formerly the location of an electricity power station that was in operation from 1901–1969; its two large cooling towers and other structures were demolished in 1972, which were situated between the two Site locations. The Site was subsequently used as an industrial estate; but most of the late 20th century warehouses and units have now been demolished.

Scope 1.4 This assessment focuses upon the heritage resource of the Site itself, as well as a minimum 500m ‘buffer’ around its redline boundary (referred to hereafter as ‘the study area’). In addition, selected designated heritage assets lying within the wider townscape have undergone a settings assessment.

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1.5 The main objectives of the Heritage Desk-Based Assessment are:

• to identify and gather information on designated and non-designated heritage assets within the proposed Site and surrounding townscape, and the settings of those assets that may change as a result of the proposed development;

• to assess the effect of the proposed development on the significance of designated and non-designated heritage assets within the Site and the surrounding townscape arising from potential changes to their setting;

• to identify recorded heritage assets of archaeological interest (designated and non-designated) within the proposed Site and, where sufficient information allows, to assess their significance;

• where possible, to assess the resultant baseline information, and to offer an analysis of the potential for the presence of currently unrecorded heritage assets of archaeological interest within the proposed Site, and of their likely significance; and

• to assess as far as possible, the potential effect of the proposed development on the significance of known and potential buried archaeological remains within the proposed Site.

7 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

2. METHODOLOGY

2.1 The methodology used within this assessment is informed principally by the guidance provided in the Chartered Institute for Archaeologists’ Standard and Guidance for Historic Environment Desk-Based Assessment (2020).

2.2 The defined study area for the assessment of the heritage resource has been measured from the boundaries of the Site, and encompasses a buffer area of a minimum of 500m from the Site boundary. The Site is split into two parcels, however the 500m buffer area encompasses the land between the two areas of the Site also. The size of the study area ensured that data sources provided sufficient information about the Site and its surrounding landscape from which to assess known and potential impacts on the heritage resource.

Data sources 2.3 The assessment required consultation of readily available archaeological and historical information from documentary and cartographic sources. The major repositories of information consulted comprised:

Historic England National Heritage List for England • World Heritage Sites • Scheduled Monuments • Listed Buildings • Registered Parks and Gardens • Registered Battlefields

Central Bedfordshire and Luton Historic Environment Record • Database of known archaeological sites, findspots, historic buildings and previous archaeological works; and • Published and unpublished documentary sources.

Central Bedfordshire and Luton Archives • Historic maps and documentary sources to demonstrate previous land use.

Historic England Archives • AMIE (Archives and Monuments Information, England) data including known archaeological sites, findspots and previous archaeological works; and • Aerial photography collections.

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Online sources • The British Geological Survey (BGS) Geology of Britain Viewer and the Cranfield University Soilscapes Viewer; • The Luton Borough Council (LBC) website for Local Plan information and the Appraisal for Plaiter’s Lea Conservation Area (LBC 2020); and • The Archaeological Data Service (ADS) for ‘grey literature’ reports of previous archaeological investigations (see below).

2.4 Several programmes of archaeological work have occurred within the study area, but none within the Site. Ten archaeological evaluations and excavations have been conducted near the University of Bedfordshire, on St. Ann’s Road, Vicarage Street and Park Street. These investigations recorded evidence for the medieval castle complex that existed here from the 13th–14th centuries, as well as post-medieval buildings and deposits (see Section 4).

2.5 Complementing the synthesis of these data sources, a site visit and a study area walkover were conducted on 2nd and 10th June 2016 to more fully understand the potential constraints, if any, to the proposed development.

Recorded heritage assets 2.6 These data repositories allowed for a gazetteer to be compiled of known heritage assets within the study area (Appendix A). These assets are discussed in Section 4, where they are referred to by a unique reference number (1), etc... Their locations are marked on Figs. 3 and 5.

2.7 The National Heritage List for England provided information regarding designated heritage assets within the study area. There are no World Heritage Sites (or sites included on the Tentative List of Future Nominations for World Heritage Sites), Scheduled Monuments, Registered Parks and Gardens, or Registered Battlefields located within a 500m radius of the Site.

2.8 However, numerous Listed Buildings are located within the study area. The majority of these are Grade II Listed and are concentrated within three Conservation Areas: High Town, which is focussed around the street of that name, c.260m north-west of the Site; Plaiters Lea, which includes a section of Guildford Street and Bute Street, Cheapside, Silver Street and John Street, c.30m west of the Site; and Town Centre, which encompasses George Street, Upper George Street and their side streets, c.270m south-west of the Site. Nine other Listed Buildings are located elsewhere in

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the study area; and the Grade I Listed St. Mary’s Church occupies an ‘island’ of green space between the University of Bedfordshire (to the south-west) and St. Mary’s Road (to the north-east), c.20m to the south of the Site.

2.9 The Grade I Listed St. Mary’s Church and the Plaiters Lea Conservation Area were considered potentially to be most sensitive to the proposed development, and have undergone settings assessments in accordance with Historic England’s guidance (see Section 2.11). Other designated heritage assets were found to require no further assessment beyond Step 1. Their wider setting made little to no contribution to heritage significance (see below); and there was no direct relationship to or intervisibility with the Site (see Section 6).

Assessing significance 2.10 The significance of known and potential heritage assets within the Site, and any beyond the Site which may be affected by the proposed development, has been assessed and described, in accordance with paragraph 189 of the NPPF (2019), the guidance issued by CifA (2017), Historic Environment Good Practice Advice in Planning Note 2 (HE 2015) and Advice Note 12: Statements of Heritage Significance: Analysing Significance in Heritage Assets (Historic England 2019).

2.11 Determination of significance has been undertaken according to the industry- standard guidance on assessing heritage value provided within Conservation Principles (English Heritage 2008). This approach considers heritage significance to derive from a combination of discrete heritage values, principal amongst which are: i) evidential (archaeological) value, ii) historic (illustrative and associative) value, iii) aesthetic value, iv) communal value, amongst others. Further detail of this approach, including the detailed definition of those aforementioned values, as set out, and advocated, by Historic England, is provided in Appendix 1 of this report.

2.12 The way in which heritage significance is expressed within this document has been specifically developed to ensure that it is fully aligned with the Planning (Listed Buildings and Conservation Areas) Act 1990 (‘the Act’) and the NPPF (see Section 3). The statements of significance developed for each of the heritage assets reflect the language of the Act making use of the terms such as ‘character and appearance’ (of Conservation Areas) and ‘architectural and historic interest’ (of Listed Buildings).

2.13 Although the statements of significance will rightly acknowledge the fabric of the assets as being the embodiment and physical manifestation of heritage significance,

10 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

the surroundings of the assets often contribute to the overall significance. The other attribute of setting that is of key relevance is the way in which the significance of the heritage asset is ‘experienced’. As with its physical surroundings, the intelligibility of the heritage asset (and thus the way in which it is or can be appreciated) can only be articulated from an informed position on the heritage significance of the fabric of the asset. These statements of significance describe ‘what matters and why’.

2.14 Although terms such as High, Medium or Low value, and National, Regional or Local importance are often adopted by the industry to express a summary description of the ‘relative significance’ of heritage assets, they are not universally recognised or accepted terms. These multifarious concepts require complex definitions to properly allow for their application and don’t directly relate to the language or key tests required in determining planning applications or heritage consents.

2.15 Therefore, a simple three-tiered structure (derived directly from the NPPF) to differentiate the relative significance of heritage assets is adopted. In descending order of relative heritage significance:

• Designated heritage assets of the highest significance; • Designated heritage assets of less than the highest significance; and • Non-designated heritage assets;

2.16 The language used is entirely consistent with the NPPF and the Act and provides the decision-maker with sufficient (and no more) information than is necessary to understand how change (see below) could bring about harm to the heritage significance of an asset(s). Each of these ‘ranks’ of heritage asset have their own bespoke and relevant policy within the NPPF. Thus the adopted approach simplifies the process of reaching an informed judgement, a necessary element of the planning- balance exercise.

Assessing harm (impact or effect) 2.17 Any quantitative description of change (or harm) is also avoided. Much like the scalar approaches to defining relative significance, those that adopt complex quantifying criteria are often weakened by circular definitions (i.e. ‘a moderate impact equates to significant changes to many of the attributes of the asset’).

2.18 The clear statements of significance (the ‘what matters and why’) and a sound understanding of the character of the change brought about by the Project, as

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presented in this assessment methodology, allow for a transparent articulation of the nature of the harm. 2.19 In terms of harm through changes to setting, as clearly illustrated within the NPPF, any attempt to convey the impact or harm of a project has to be framed within the tightly defined parameters of the harm to the significance of the heritage asset itself. This is a fundamental principle. In summary, a project could bring about change within a heritage assets setting, causing harm to the significance of the heritage asset or the way in which the significance is experienced. References such as ‘harm to the setting’ are avoided.

2.20 To further assist in the decision-making process, much like the approach taken for relative significance, a three-tiered approach is adopted to summarise the ‘scale of the harm’. It is not used as the sole descriptive frame of reference, but just a simplistic summary. Again, the language used is entirely consistent with the NPPF and the Act and provides sufficient information to reach an informed judgement.

• Substantial harm: defined with specific regard to change to a heritage asset that ‘…would have such a serious impact on the significance of the asset that its significance was either vitiated altogether or very much reduced’; • Less than substantial harm; and • No harm (or preservation), such that the attributes identified within the statement of significance have not been adversely affected.

2.21 The NPPF does not employ the use of the terms ‘substantial (or less than substantial) harm’ with regard to non-designated heritage assets. However, in the absence of any other definition, for purposes of this assessment methodology it is deemed appropriate to apply the same terms for the ‘scale of harm’ to all types of heritage asset, whether designated or not.

2.22 To ensure that the language used within the Town and Country Planning (Environmental Impact Assessment) Regulations 2011 (‘the EIA Regulations’) is also incorporated within the assessment methodology, it is considered that ‘substantial harm’ to any heritage asset (designated or not) would equate to a ‘significant effect’. ‘Less than substantial harm’ to designated heritage assets of the highest significance could also trigger the same ‘significant effect’ but no prescriptive criteria is proposed to prejudge this threshold, leaving it to professional judgement.

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3. PLANNING POLICY CONTEXT

Legislative framework, national planning policy and relevant sector guidance 3.1 The assessment is written within the following legislative, planning policy and guidance context:

• National Heritage Act 1983 (amended 2002);

• Planning (Listed Buildings and Conservation Areas) Act (1990);

• Conservation Principles, Policies and Guidance for the Sustainable Management of the Historic Environment (2008);

• National Planning Policy Framework (2019);

• National Planning Practice Guidance: Conserving and enhancing the historic environment;

• Historic Environment Good Practice Advice in Planning Note 2: Managing Significance in Decision-Taking in the Historic Environment (2015);

• Historic Environment Good Practice Advice in Planning Note 3: The Setting of Heritage Assets (2017).

Planning (Listed Buildings and Conservation Areas) Act (1990) 3.2 In determining planning applications that might affect the settings of Listed Buildings, the 1990 Act states that:

‘In considering whether to grant planning permission for development which affects a listed building or its setting, the local planning authority or, as the case may be, the Secretary of State shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.’ (Section 66).

3.3 In determining planning applications that might affect the character and appearance (including their setting) of Conservation Areas, the 1990 Act states that:

‘[W]ith respect to any buildings or other land in a conservation area […], special attention shall be paid to the desirability of preserving or enhancing the character or appearance of that area.’ (Section 72).

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Local planning policy Luton Local Plan (2011-2031) 3.4 On 7 November 2017, Luton Borough Council met and resolved to adopt the Luton Local Plan (2011-2031). Policies relevant to the historic environment are as follows:

Policy LP30 – Historic Environment

‘A. To protect, conserve and enhance Luton’s unique and rich heritage, identity and sense of place, development proposals must take account of the character, setting, local distinctiveness (including materials and detailing) of local affected heritage assets and features of particular importance including: i. the manufacturing industry and the hat industry; ii. registered parks and gardens including Luton Hoo and Wardown Park; iii. historic landscape features such as the Chilterns and River Lea; iv. prominent listed buildings including within the town centre, the medieval street patterns, the Town Hall and the Parish Church of St. Mary.

Any degree of harm and benefit arising from development proposals will be assessed against the significance of any affected heritage assets including:

Designated heritage assets: • Listed Buildings • Conservation Areas • Scheduled Monuments

Non-designated heritage assets: • Locally listed buildings • Archaeology

B. There will be a presumption in favour of the retention of heritage assets. Development proposals will be supported where they conserve heritage assets, bringing them back into appropriate use for the benefit of future generations.

C. Complete or partial loss through demolition will amount to substantial harm to a designated heritage asset and may amount to substantial harm to a non-designated heritage asset, depending on the significance of the heritage asset including its positive contribution within a Conservation Area, and will only be permitted where it

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can be justified that there is a net public benefit. Proposals must also accord with the following criteria: i. wholly exceptional circumstances for demolition or part demolition must be justified in the case of listed buildings and designated heritage assets of the highest significance; ii. the nature of the heritage asset is such that no reasonable alternative use including conversion can be found, and that appropriate marketing or options for grant-funding or charitable/public ownership have been exhausted; iii. within a conservation area any complete or part demolition of a building whether designated or not, must protect and conserve the setting and character of the conservation area.

D. Proposals affecting designated and non-designated heritage assets require a Heritage Statement for validation (which may be included within a Design and Access Statement), setting out the significance of the asset, the resulting impact and mitigation, addressing the setting of the asset.

E. Where evidence points to potential presence of remains, mitigation will be required (e.g. investigative trenching, watching brief, recovery and interpretation of remains).

F. Proposals will be subject to appropriate recording of the significance of the building or asset and regulated by legal agreements on the phasing of demolition and development with planning permission and a contract for redevelopment.

The Council will seek to:- • maintain a regularly updated schedule of Luton’s Designated Heritage Assets and locally listed heritage.

• ensure that heritage assets considered to be at risk of neglect or decay included on the English Heritage at Risk Register, are effectively managed and protected; and • work with stakeholders and the community to establish Conservation Area Appraisals and Management Plans for its Conservation Areas.’

3.5 The Plan is also supported by a suite of documentation that includes a Historic Area Assessment of Plaiters Lea Conservation Area (Carmichael et al. 2011), a

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synthesis of The Hat Industry of Luton and its Buildings (Carmichael et al. 2013), and an external link to the Central Bedfordshire and Luton Historic Environment Record. These resources have been consulted for this assessment (see Sections 2.4 and 8). This assessment fulfils clause D from Policy LP30.

National Planning Policy Framework 3.6 The NPPF sets out national planning policy relating to the conservation and enhancement of the historic environment. It defines the historic environment as ‘all aspects of the environment resulting from the interaction between people and places through time, including all surviving physical remains of past human activity, whether visible, buried or submerged, and landscaped and planted or managed flora.’

3.7 Individual aspects of the historic environment are considered heritage assets: ‘buildings, monuments, sites, places, areas or landscapes identified as having a degree of significance meriting consideration in planning decisions, because of their heritage interest.’ Heritage assets include designated sites and non-designated sites, and policies within the Framework relate to both the treatment of assets themselves and of their settings, both of which are a material consideration in development decision making.

3.8 Key tenets of the NPPF are that:

• when considering the impact of a proposed development on the significance of a designated heritage asset, great weight should be given to the asset’s conservation. The more important the asset, the greater the weight should be; • significance can be harmed or lost through alteration or destruction of the heritage asset or development within its setting. As heritage assets are irreplaceable, any harm or loss should require clear and convincing justification. Substantial harm to or loss of a Grade II listed building, park or garden should be exceptional. Substantial harm to or loss of designated heritage assets of the highest significance, notably Scheduled Monuments, Protected Wreck Sites, Battlefields, Grade I and II* Listed Buildings, Grade I and II* Registered Parks and Gardens, and World Heritage Sites, should be wholly exceptional;

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• where a proposed development will lead to less than substantial harm to the significance of a designated heritage asset, this harm should be weighed against the public benefits of the proposal; and • with regard to non-designated heritage assets a balanced judgement will be required having due regard to the scale of any harm or loss and to the significance of the heritage asset affected.

3.9 Local planning authorities are required to request that applicants describe the significance of any heritage assets affected by a proposed development, including any contribution made by their setting. The level of detail required in the assessment should be ‘proportionate to the assets’ importance and no more than is sufficient to understand the potential impact of the proposal on their significance.’ As per clause [D] of the Luton Local Plan (2011–2031), this report represents the proportionate level of assessment.

17 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

4. HISTORICAL DEVELOPMENT OF THE SITE AND STUDY AREA

4.1 This Section provides an overview of the geographical, historical and archaeological background of the Site, the study area and the region surrounding it, to provide a better understanding of the context and significance of the heritage resource that may be affected by development. The synthesis is a necessary prelude to Section 5, which considers the potential for encountering buried archaeological remains within the Site – and predicts their likely nature, date, extent, character, condition and significance. Section 7 then considers the impact of the proposed development upon the significance of any such buried archaeological remains.

Topography, geology and the palaeoenvironment 4.2 The modern town of Luton is located across the valley slopes of the River Lea, which has its source at Leagrave Common, c. 4.5km to the north-west of the Site (see Fig. 2). Urban sections of the Lea have been diverted and culverted, not least, where it bisects the Site on a north-west/south-east orientation. Contour data indicates that the Site lies at 108–112m aOD (see Fig. 2), but the ground level has been altered through modern development. Before the modern period, the Site was probably always peripheral to settlement due to the risk of flooding from the River Lea.

4.3 The solid geology of the Site comprises chalk of the Holywell Nodular and New Pit Chalk Formations, which was created approximately 89–100 million years ago during the Cretaceous Period. This bedrock is overlain by alluvium associated with the River Lea; and glaciofluvial sands and gravels that formed up to 2 million years ago during the Quaternary Period. Many boreholes have been taken across the Site, but the results of only four are publically available. Two recorded chalk at c.1.3–1.6m below drift deposits (BGS online viewer, accessed 25.05.16).

4.4 The Site is said to be characterised by freely-draining, slightly acid, base-rich soils (Soilscapes viewer, accessed 25.05.16); but it is likely that the uppermost horizons consist of ‘made ground’ associated with 20th and 21st century residential and industrial land use and activity.

Pre-Holocene activity (c.500,000 – 10,000BC) 4.5 The earliest evidence for hominin presence in the Luton area comprises flint implements discovered within brick-earth deposits of clay extraction pits during the 19th and early 20th century (Albion Archaeology 2005, 12). Lower and Middle

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Andover 01264 347630 N Cirencester 01285 771022 Site boundary Cotswold Exeter 01392 826185 Archaeology Milton Keynes 01908 564660 w www.cotswoldarchaeology.co.uk Roman e [email protected] Prehistoric PROJECT TITLE Power Court, Luton, Bedfordshire course of the River Lea

FIGURE TITLE m AOD Prehistoric and Roman landscape 98 110 125 140 155 170 185 205 1:35,000 0 1km DRAWN BY AO, AW PROJECT NO. 660708 FIGURE NO. CHECKED BY RP DATE 19/01/21 © Crown copyright and database rights 2021 Ordnance Survey 010003167 APPROVED BY RS SCALE@A4 1:35,000 2 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Palaeolithic handaxes, borers, disc scrapers, fabricators, trimmed flakes and cores have been found at Caddington (c.3.5km to the south-west of the Site), Ramridge End (c.2km to the north-east of the Site) and Leagrave (c.4km to the north-west of the Site). These assemblages were recovered, identified and studied by local antiquary Worthington G. Smith. Whilst his proposed palaeoenvironment sequences have been challenged by recent syntheses, it has been noted that the valley of the River Lea holds potential for the survival of such artefacts (Albion Archaeology 2005, 12). No brick-earth deposits are recorded within the Site; but there is a limited likelihood that the alluvium associated with the (now-culverted) River Lea might contain flint tools redistributed by fluvial activity during the Holocene (see below).

Later Prehistoric landscape (10,000BC – AD43) 4.6 With the onset of the Holocene (c.9600BC), the River Lea played a pivotal role in the development of the Luton area (Carmichael et al. 2011, 27). Whilst evidence for Mesolithic activity is scant, Neolithic occupation is well-attested (Albion Archaeology 2005, 12). A large curvilinear ditched enclosure known as Waulud’s Bank was built adjacent to the source springs of the Lea, c.4.5km to the north-west of the Site; and other Neolithic and Bronze Age ceremonial monuments are distributed across the high ground above the river valley, c.5.5km to the north of the Site at Warden Hill and Galley Hill (see Fig. 2).

4.7 The first settlement was probably established to the north of Waulud’s Bank at Sundon Park, c.3000BC (Albion Archaeology 2005, 12); with subsequent foci of occupation clustered on the alluvial terraces and chalk ridges overlooking the River Lea, c.1–4km to the north-west of the Site (Carmichael et al. 2011, 27). The remains of a ‘log causeway’ associated with 2nd–1st century BC pottery have been discovered at Leagrave, c.4km to the north-west of the Site (BBC/CBC 2016a; not illustrated). It is likely that the Luton area was ‘an extensive agricultural landscape’ during the Iron Age (Albion Archaeology 2005, 13). Given that the Site is crossed by the River Lea, it would not have been a favourable location for settlement but may have been used as seasonal grazing for livestock.

Roman landscape (AD43 – 410) 4.8 More substantial evidence of later occupation is recorded within (what is now) the modern town of Luton. At Limbury, slightly to the south of Leagrave and c.3.7km north-west of the Site, excavations uncovered a timber-built settlement of 2nd–4th century date (Albion Archaeology 2005, 15). A section of a ‘service road’, which would have connected settlements to key routes such as Watling Street, has been

19 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

identified at Leagrave Marsh, c.3.3km to the north-west of the Site (BBC/CBC 2016b; HER Ref. 167). Another dense concentration of Roman period features and material has been recorded beneath the former Waller Street and at Vicarage Street, c.50–250m from the Site (Fig. 2, 1; Carmichael et al. 2011, 27). At Waller Street, c.265m to the south-west of the north-western corner of the Site, a probable kiln built of Roman tile was found in 1908; but it is now supposed to be of medieval date, since later tile was also present. In 1975/1976, groundworks at Vicarage Street, c.130m to the south of the Site, recovered Roman building debris that included box and flue tile and pottery sherds.

4.9 Although many findspots of Roman date are recorded throughout Luton (BBC/CBC 2016b; not illustrated), none occur within the Site. The River Lea (which is now culverted) would have flowed in a south-easterly direction through the Site (BGS viewer, accessed 25.05.16; see Fig. 2) – thus rendering it unlikely that settlement was located here. It is probable, however, that the river and its floodplains were exploited for aquatic, floral and faunal resources during the prehistoric and Roman periods; but unstratified artefacts such as worked flints and/or pottery sherds, of limited heritage significance, would be the only material signatures of such activity.

Early Medieval origins of Luton (AD410 – 1066) 4.10 The establishment of a town at Luton is thought to have occurred in the 6th century, since the Anglo-Saxon Chronicle records an attack by a Saxon army on a place known as Lygeanberg (meaning a defended enclosure on the River Lea) in AD571 (Carmichael et al. 2011, 28). Archaeological evidence for activity during the first half of the first millennium is scarce, but suggests ongoing occupation at Leagrave, c.4– 4.5km to the north-west of the Site, from the Roman period (see Section 4.8; BBC/CBC 2016c; Albion Archaeology 2005, 16). An extensive cemetery of 5th–6th century date has been excavated at Biscott, c.2km to the north-west of the Site (not illustrated); but no traces of Saxon buildings have yet been found in Luton. The extent and form of settlement at this time is unclear, but likely consisted of dispersed hamlets (Albion Archaeology 2005, 16). Documentary sources do reveal that the River Lea formed part of the boundary of the Kingdom of Wessex, and thus, various territorial disputes were centred on Lygetune (as it was later re-named) and its hinterland during the later first millennium AD (BBC/CBBC 2016d). The Anglo- Saxon Chronicle documents an attack on Lygetune by the Danes in AD913, which was successfully thwarted and commemorated by constructing a church. It was probably timber-built but its location is unknown (Carmichael et al. 2011, 28).

20 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Medieval development of Luton (AD1066 – 1539) 4.11 By the time of the Domesday Survey (AD1086), Luton goes by the name of Loitoine and is described as a very large settlement with land for 82 ploughlands, woodland for 2000 pigs, six mills and a market (Open Domesday, accessed 01.06.16). The Central Bedfordshire and Luton Historic Environment Record locate one of these mills within the Site (Fig. 3, 2); although on what basis it is not clear. In the early 12th century, Henry I granted the Manor of Luton to Robert Earl of Gloucester, who in c.1137 built a new church dedicated to St. Mary (Fig. 3, 7; Albion Archaeology 2005, 19). Following Robert’s death in 1147, the lordship of St. Mary’s Church and its estate (which formed part of the Manor of Luton) passed to St. Alban’s Abbey; although the location and extent of this sub-manor’s landholdings are not known (BBC/CBC 2016e). The Abbots built a tower and chapel dedicated to St. Ann on the north side of the River Lea, c.250m to the east of the Site (not illustrated); the tower is said to have been extant until the early 18th century.

4.12 Following the ascension of King Stephen, the Manor of Luton was granted to Robert de Waudari, a foreign mercenary who built a substantial motte-and-bailey castle on high ground to the south of (but overlooking) the medieval town, c.690m south-west of the Site (Fig. 3, 3). This castle was demolished in AD1154 under the terms of a truce (Carmichael et al. 2011, 29); but archaeological investigations have located its 3–4m wide bailey ditch and it is thought that Castle Street follows the alignment of the inner ditch (Albion Archaeology 2005, 23). A new castle was established by Fulk de Breaute when he acquired the Manor of Luton in AD1221, on a site adjacent to St. Mary’s Church and overlooking the River Lea (Fig. 3, 4). The castle appears to have been moated. It was partially destroyed in 1224–1225 following de Breaute’s exile, but the site was re-used in the later 13th and 14th centuries (Carmichael et al. 2011, 29). Archaeological excavations at Park Square (see Fig. 4a) have unearthed buried remains of medieval structures, deposits and debris relating to the use, demolition and re-use of the castle complex (see below).

Fulk de Breaute’s castle Known documentary evidence 4.13 The general location of Fulk de Breaute’s castle has been identified from both documentary sources and archaeological evidence. An account written by Matthew Paris in the early 13th century notes that de Breaute dammed the River Lea and created a pond to fill and aid the retention of water within a moat; this caused flooding across church lands (see Section 4.11), destroying a corn crop and

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3 Andover 01264 347630 Cirencester 01285 771022 Robert de Waudari’s Cotswold Exeter 01392 826185 Castle Archaeology Milton Keynes 01908 564660 w www.cotswoldarchaeology.co.uk e [email protected]

PROJECT TITLE Power Court, Luton, Bedfordshire

FIGURE TITLE Medieval Luton

DRAWN BY AO, AW PROJECT NO. 660708 FIGURE NO. CHECKED BY RP DATE 06/06/2016 APPROVED BY RS SCALE@A3 1:7500 3 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

damaging a barn (Keir 2011, 20). There do not appear to be any known records of the castle from the later medieval or early post-medieval period. However, a glebe terrier of 1707 describes the churchyard of St. Mary’s (Fig. 3, 7) as ‘fended by water in part’ and the vicarage orchard as ‘funded by mote of water’ – which the Central Bedfordshire and Luton Historic Environment Record has presumed to refer to a medieval moat.

4.14 The next known mention of the castle comprises a map of Luton, produced in 1855, which depicts a small sub-rectangular earthwork at the corner of Park Street and Lea Road (Fig. A). This feature is labelled as ‘Site of Fulk de Brent’s [sic] Castle’ and the accompanying text notes: ‘This castle probably stood in the meadow at the east corner of the churchyard, where the site of a large square moated mansion is still very plainly to be seen; the meadow adjoining it is surrounded by a very high bank of earth, and a deep ditch’ (Davis 1855, 8, 144). Another history of Luton, published in 1928, states: ‘many recollect a raised mound of considerable extent, surrounded by a good-sized ditch’ (Austin 1928). These anecdotes are repeated in syntheses of recent archaeological investigations at Park Square, c.100–250m to the south of the Site (see Sections 4.16–4.21), which have recorded sections of (what appear to be) the north-western and southern arms of the moat.

NORTH

Fig. A Extract from Plan of Luton (1855), showing the supposed earthwork of Fulk de Breaute’s castle (labelled ‘6’). Red lines show the Site.

22 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Recorded archaeological evidence (see Fig. 4a) 4.15 The first excavation on the site of de Breaute’s castle took place in 1976, following the demolition of Victorian housing on the south-eastern side of Vicarage Street, c.120m to the south of the Site. Beneath strata containing post-medieval pottery were revealed partial sections of ditches. One measured more than 20m in width and more than 2.5m in depth; the fill indicated that it had once been water-filled and thus could have been part of a moat surrounding the castle (Luton Museum 1976, 3–4). Further archaeological investigations took place in the same locality in 2008 and 2010. Trial trenches identified linear features of 13th–14th century date, overlain by late post-medieval deposits and structures; the recovered fragments of burnt daub were thought to derive from timber-framed buildings that had stood within the castle bailey (Archaeology South-East 2008; 2010).

4.16 Multiple programmes of archaeological work have taken place in and around the University of Bedfordshire at Park Square. In April 2009, trial trenching on the north side of St Ann’s Road revealed part of a large ditch measuring up to 12m in width and 3m in depth, which was thought to represent the north-western arm of the moat of de Breaute’s castle (Albion Archaeology 2009). Subsequent excavations in May and June 2009 found that the ditch had been re-cut twice during the post-medieval period – probably representing deliberate quarrying of the nutrient-rich fill (Keir 2011, 8). The moat had subsequently infilled over a relatively long period; distinctive waterlogged deposits consisted of dark brown clay silts up to 1.6m thick (Keir 2011, 8). A smaller ditch, measuring 1m in width and 0.45m in depth, was also found to join the north-western arm of the moat. Its primary fill was mostly comprised of large compacted flints presumably placed to consolidate the base of the ditch, which was interpreted as a feeder channel for the moat (Keir 2011, 4).

4.17 During Albion Archaeology’s 2009 investigations of the north-western arm of the moat, the partial footprint of a large timber-framed building was also identified within the moated enclosure. Associated with assemblages of 12th and late 13th century pottery, it was suggested that this building might be the ‘court house’ described in documentary sources (Keir 2011, 5, 21). Three refuse pits located outside the moated enclosure were dated to the mid-13th to 14th century, relating to the re-use of the castle site in the later medieval period (Keir 2011, 6). In a small area outlying the moat (i.e. to the west), twelve graves containing the remains of 8 children under the age of 4 years were also found; the burials were dated to the 17th, 18th and early 19th century (Keir 2011, 9, 22–23). It is possible that these graves were dug in

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01:2500 100m FIGURE TITLE Previous archaeological investigations of Fulk de Breaute’s castle complex

DRAWN BY AO PROJECT NO. 660708 FIGURE NO. CHECKED BY RP DATE 17/06/2016 © Crown copyright and database rights 2020 Ordnance Survey 0100031673 APPROVED BY RS SCALE@A4 1:2500 4a NE SW 103.33m AOD

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Andover 01264 347630 Cirencester 01285 771022 Cotswold Exeter 01392 826185 Archaeology Milton Keynes 01908 564660 w www.cotswoldarchaeology.co.uk overburden (19th - 20th century) e [email protected] silty infill (15th - 18th century) PROJECT TITLE Power Court, Luton, Bedfordshire re-cut and re-use (14th century) organic material and stone fragments (13th century) FIGURE TITLE North-west facing section through the southern arm of the castle moat (after Headland Archaeology 2015)

DRAWN BY AO PROJECT NO. 660708 FIGURE NO. CHECKED BY RP DATE 17/06/2016 APPROVED BY RS SCALE@A4 1:50 4b © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

unconsecrated ground outside the churchyard of St. Mary’s, due to the children not having been baptised.

4.18 Further archaeological investigations of Fulk de Breaute’s castle were conducted by Albion Archaeology in 2011 and Headland Archaeology in 2011 and 2013–2014, in advance of redevelopment of the University of Bedfordshire’s Park Square campus. These excavations were located on the north-western side of Vicarage Street, i.e. inside the moated enclosure, and provided clues as to its built layout and use. In a synthesis of the 2009 and 2011 fieldwork, it was estimated that the moat had enclosed a total area of c.2.5ha; this was derived by combining ‘the results of these investigations with knowledge from similar castles’ (Woodley and Abrams 2012, 12). The south-western quarter of the castle complex contained a large rectangular building (see Section 4.17) and structures associated with crop processing; whilst the central area, delimited by a series of fences and parallel ditches, was a focus for zoned industrial activity. The authors proposed that the north-eastern quarter (which has not been subject to archaeological investigation) was occupied by domestic buildings (Woodley and Abrams 2012, 13; see Section 4.21).

4.19 The excavations conducted by Headland Archaeology in 2013–2014 recorded evidence for the demolition of Fulk de Breaute’s castle and the subsequent re-use of the site. One trench presented a detailed section of the southern arm of the moat (see Fig. 4b). It was of similar dimensions to the north-western arm (see Section 4.17), indicating that the moat was a uniform construction all along its circuit (Headland Archaeology 2015, 18). In the lower fill were fragments of dressed stone blocks and rubble, likely representing the demolition of a substantial structure, possibly a gatehouse or part of the curtain wall (Headland Archaeology 2015, 19). Above this were recorded timber fragments of a trestle bridge, attesting to the new phase of use in the 14th century (Headland Archaeology 2015, 20). Recovered assemblages of local and imported ceramic wares, decorative metalwork and imported coinage demonstrated that this remained a high-status site, perhaps even a political centre, before being abandoned in the mid-14th century (Headland Archaeology 2015, 60).

4.20 Unlike the north-western arm of the moat (see Section 4.17), the excavated section of the southern arm preserved a stratigraphic sequence from the medieval period to the present (Fig. 4b). The upper fill, characterised by a 0.9m thick layer of silt indicative of a gradual infilling of the moat, was overlain and truncated by c.0.7– 0.9m of ‘made ground’ relating to 19th–20th century built development. Beneath this

24 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

was material relating to the re-use of the castle complex in the 13th and 14th centuries (including the remains of the timber trestle bridge) – overlying c.0.7m of organic material and stone fragments from the use and abandonment of the castle in AD1224/1225 (Headland Archaeology 2015, 58–59). Within the moated enclosure, medieval features were sealed by a 0.25m-deep ‘abandonment layer’ of buried soil thought to derive from the reversion of the castle site to pasture from the late 14th century (Woodley and Abrams 2012, 13). Across the area of the 2013– 2014 excavations, modern ground reduction and levelling had penetrated no deeper than c.0.3m above the medieval horizon (Headland Archaeology 2015, 28); thus, construction activity had only caused localised disturbance to medieval deposits.

Potential for the survival of remains within the Site 4.21 The north-eastern part of Fulk de Breaute’s castle complex has not been subject to archaeological investigation. However, in their synthesis of Headland Archaeology’s 2011 excavations, Woodley and Abrams suggested that the moated enclosure had continued beneath (what is now) St. Mary’s Road and towards the southern corner of the Site (Woodley and Abrams 2012, 12). Their accompanying drawing aligns the north-eastern arm of the moat with a field boundary shown on the 1842 Tithe Map, c.50m to the south of the (now culverted) River Lea (see Fig. B). This is based on detail provided by Davis (which is missing from his 1855 account; see Section 4.14), of the ‘mound remaining on the north and south-east sides’ of an enclosed field (Davis 1874, 30–31).

4.22 This reconstruction is not well-supported by recorded archaeological evidence from the locality. Rather, it combines the results of the fieldwork at Park Square, c.50m to the south of the Site, with ‘knowledge from similar castles’ (Woodley and Abrams 2012, 12). The few documentary sources referring to Fulk de Breaute’s castle (see Sections 4.13–4.14) are too vague to identify its plan. There is currently insufficient evidence to state with any confidence whether or not the castle complex extended into the Site.

25 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Projected line of moat

Fig. B Projected line of the moat surrounding Fulk de Breaute’s castle complex derived from Woodley and Abrams 2012, superimposed on the Luton Tithe Map, 1842. Redlines show the Site.

4.23 However, re-considering Matthew Paris’ account (see Section 4.13), it is possible that feeder channels were created between the River Lea and the moat, i.e. within the southern part of the Site. In 2009, Albion Archaeology recorded a small ditch that appeared to have served this function for the north-western arm (see Section 4.16). Alternatively, Paris’ description could suggest that the River Lea itself formed a natural defence to the north side of Fulk de Breaute’s castle. If a buried section of the north-eastern arm of the moat survives within the Site, its stratigraphy could be similar to that of the southern arm (see Section 4.20; Fig. 4b). The post-medieval quarrying of the north-western arm (see Section 4.16) was probably a localised activity, undertaken by the owner of the plot extending back from Park Street (see Fig. B).

4.24 Woodley and Abrams also proposed that a motte surmounted by domestic buildings occupied the north-eastern part of the castle complex (see Section 4.21). If this was indeed the case, it is unlikely that there are surviving archaeological remains since the earthwork (and thus, any trace of structures upon it) is no longer extant. Even if

26 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

the castle complex did extend into the Site, in situ evidence of domestic buildings that once stood atop of a motte is unlikely.

Medieval settlement 4.25 The medieval settlement of Luton was established on the first terrace above the River Lea (Carmichael et al. 2011, 29); but, as noted elsewhere, ‘By the end of the 11th century, Luton could perhaps be characterised as a small town of timber and wattle and daub houses, congregating around the stone church [the precursor to St. Mary’s; see Section 4.10] and centred on what is now the Park Square area, with roads going down to the fording points or bridges over the River Lea’ (Albion Archaeology 2005, 16). Three crossings have been identified: North Bridge, Church Street and Blackwater Bridge; and according to the illustration produced by Albion Archaeology, one was located within the Site (see Fig. 3). It is not clear how the locations of these crossings have been derived; the Central Bedfordshire and Luton Historic Environment Record does not make any reference to them. If these were simply fording points, rather than being structures such as bridges, there would be little to no trace in the archaeological record.

4.26 It seems that medieval Luton was a linear settlement comprising George Street and Park Street (on the same orientation as the River Lea), Bridge Street, Castle Street and Church Street (Albion Archaeology 2005, 51–52). Archaeological investigations have unearthed evidence of medieval occupation in these localities (Fig. 3, 5). Luton’s medieval market and fairs may originally have been held near St. Mary’s Church, but later moved to Market Hill at the junction of George Street and Castle Street (Albion Archaeology 2005, 51). Another medieval settlement was located on rising ground on the north side of the River Lea, c.400m to the north-east of the Site at Crawley Green (Fig. 3, 6). Land here (and probably elsewhere in Luton) was owned by St. Albans Abbey prior to the Dissolution (see Section 4.11).

Post-Medieval (1540 – 1800) and Modern (1800 – present) Luton Urban and industrial growth 4.27 During the post-medieval period, it is likely that the majority of Luton’s population was engaged in some form of agricultural activity. Francis Blomfield, writing of Luton between 1724 and 1734, noted: ‘It hath a market house and large Monday market for corn, with which this part much abounds, there being but little pasture’ (cited in Page 1908). Brick-making was also an important industry; but the brewing and sale of beer and spirits was the principal and continuous trade, with documentary and

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PROJECT TITLE Power Court, Luton, Bedfordshire

FIGURE TITLE Post-Medieval and Industrial Luton

DRAWN BY AO, AW PROJECT NO. 660708 FIGURE NO. CHECKED BY RP DATE 19.01.21 APPROVED BY RS SCALE@A3 1:7000 5 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

cartographic records of numerous inns and taverns (Albion Archaeology 2005, 24, 28, 34) (see Fig. 5). Luton’s main growth did not occur until the 19th century. The medieval town layout can still be discerned on Higgins’ Plan of 1815 (not illustrated), with fields around St. Mary’s Church and towards the River Lea (i.e. encompassing the Site); however, Brown’s Map of 1839 (not illustrated) ‘depicts the centre of Luton on the eve of substantial change’ (Carmichael et al. 2011, 30).

4.28 From the 1840s onwards, many new streets were laid out across former farmland and common along the river valley (Carmichael et al. 2011, 32). The building of new housing was concentrated in the ‘New Town’ and ‘High Town’ areas, to the south- east and north of the historic town core respectively (Albion Archaeology 2005, 42, 47; see Fig. 5). New town houses were also built along Upper George Street and George Street West (Fig. 5, 8). Development was fuelled by the resurgence of the straw plaiting and hatting industry (Albion Archaeology 2005, 41; English Heritage 2013). Factories, workshops and warehouses were built along Guildford Street (Fig. 5, 10); and several such buildings survive in the Plaiters Lea area (see Section 6). Nearly every building around Bute Street was involved in the hatting (or ancillary) trades (Albion Archaeology 2005, 46–47).

4.29 Luton’s population nearly doubled between 1841 and 1851 (Albion Archaeology 2005, 28). Map regression permits a detailed understanding of town growth and expansion from the mid- to late 19th century (see Carmichael et al. 2011, 29–38); a narrative for the Site is presented in Sections 4.30–4.36 and on Fig. 6. The Hatfield, Luton and Dunstable Branch Railway (Fig. 5, 12a) and the Midland Railway (Fig. 5, 12b) opened in 1858 and 1868 respectively; and further expansion of Luton occurred in the later 19th century (Albion Archaeology 2005, 47). In the early 20th century, surrounding hamlets became absorbed into the town; but many parts of Luton were bombed during the Second World War (Albion Archaeology 200, 48). From the 1940s through to the 1970s, several areas were redeveloped for housing and retail – with The Mall, a large shopping centre, built from 1974 onwards (Fig. L). Recently, new high-rise buildings have been constructed on the University of Bedfordshire’s Park Square campus, adjacent to St. Mary’s Church.

Historical land use and development within the Site 4.30 The Tithe Map of 1842 (Fig. B) shows the River Lea bisecting the Site, with two short lanes branching off from Crawley Green Road on the south-eastern side and a building set within a spacious plot mid-way along the south-western boundary. The building is St. Mary’s Vicarage (Fig. 5, 9), which is first documented in a glebe

28 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

terrier of 1707; in a later terrier of 1825, it is described as a brick and tiled dwelling with a small courtyard and a range of outbuildings on its north-western side (BBC/CBC 2016f). A Plan of St. Mary’s Vicarage from 1845 (Fig. C) shows formal gardens extending north towards the Lea, with St. Mary’s churchyard to the south. Todd’s Pictorial Map of 1865 (Fig. D) shows possible allotment gardens between the River Lea and the railway line; and proffers a detailed representation of the primary (south-facing) elevation of the vicarage. But by the late 19th century, it had fallen into disrepair and was sold to Luton Borough Council who built an electricity power station in the former gardens: demolishing the building itself in 1907 (Stubbs 1997, 58; Fig. F). A new vicarage was built at 72 Crawley Green Road, near Luton Cemetery (BBC/CBC 2016f).

Fig. C Plan of St. Mary’s Vicarage (1845)

29 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. D Todd’s Pictorial Map (1865), showing St. Mary’s Church and Vicarage

St. Mary’s Church Vicarage Girls’ School

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Fig. E Photograph (1895), looking south-west towards St. Mary’s Church, St. Mary’s Vicarage and Girls’ School from the eastern portion of the Site

30 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. F Postcard (c.1901), looking north-east towards St. Mary’s Vicarage from the western boundary of the Site with St. Mary’s Road

4.31 The First Edition Ordnance Survey Map of 1880 shows considerably more built development along the northern section of Church Street. A row of terraces in the north-western corner of the Site is named ‘Church Crescent’ and a building close to St. Mary’s Vicarage is identified as ‘School (Girls)’ (Fig. G). The school (Fig. 5, 11; Fig. E) closed in 1940, and the building was re-used as St. Mary’s Church Hall before being demolished c.1968 (Stubbs 1997, 58). Its survival until this point is remarkable given the scale and extent of (re)development here throughout the 20th century. The First Edition Ordnance Survey also shows small buildings (probably sheds) in the allotment gardens in the northern part of the Site (Fig. G).

4.32 By the time of the Second Edition Ordnance Survey of 1901 (Fig. H), a Methodist chapel is marked in the north-western corner of the Site. There is nothing to indicate that this chapel had an adjacent burial ground; given that St. Mary’s churchyard is marked as ‘disused’, it is likely that Luton Cemetery, c.60m east of the Site, was used by various Christian denominations. By 1901, Pondwicks Road, Henry Street, Alfred Street and Peach Street are shown in the southern part of the Site; and the ‘River Lea Boiler Works’ has been built in the centre of the Site.

31 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. G First Edition Ordnance Survey Map (1880)

Fig. H Second Edition Ordnance Survey Map (1901)

32 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

4.33 Ordnance Survey mapping indicates that St. Mary’s Road was built sometime between 1901 and 1924, replacing a pedestrian thoroughfare that is marked on the Second (but not the First) Edition. The Ordnance Survey Map of 1924 (Fig. I) illustrate expansion of the ‘Boiler and Engineering Works’. A corporation yard and fire station abut the boundary with St. Mary’s Road, whilst a coal depot and railway sidings occupy much of the northern part of the Site. The River Lea seems to have been culverted by this time. Two large cooling towers were built sometime between 1924 and 1938 (Figs. J and L–O).

Fig. I Ordnance Survey Map (1924)

33 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. J Looking north towards the Power Court cooling towers from outside the west door of St. Mary’s Church (1938)

Fig. K Looking north towards Power Court from outside the west door of St. Mary’s Church (2016)

34 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

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Vicarage Street

Fig. L Aerial photograph of Power Court, taken on 27th September 1947

Fig. M The Power Court cooling towers are a prominent feature on the Luton skyline in this photograph taken from the railway station in 1962

35 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. N View of the cooling towers from Church Street, taken in 1966

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Fig. O Aerial photograph of Power Court, taken on 14th April 1969

36 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

4.35 With the exception of a few buildings to the rear of St. Mary’s Hall, the houses along Church Crescent had been demolished by 1955 (not illustrated). The terraces of Alfred Street and Peach Street were cleared in the 1960s and the area does not appear to have been redeveloped (Fig. P). The cooling towers were demolished in 1972.

4.36 Pondwicks Road and Henry Street had disappeared entirely by the 1990s, although clearance of selected properties seems to have been underway from the late 1970s and early 1980s. The Ordnance Survey Plan of 1981–1986 (not illustrated) shows the transformation of the former power station into a light industrial estate of warehouses and car parks. These units were demolished very recently (Figs. Q and R).

Fig. P Ordnance Survey Plan (1968 – 1978)

37 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

Fig. Q Satellite imagery of Power Court (© Getmapping plc 2010)

Fig. R Looking north towards the Site from the University of Bedfordshire at Park Square (2016)

38 © Cotswold Archaeology Power Court, Luton Town Football Club, Luton: Heritage Desk-Based Assessment

5. SUMMARY OF ARCHAEOLOGICAL POTENTIAL AND SIGNIFICANCE

Potential for archaeological remains Prehistoric and Roman 5.1 Later prehistoric occupation of the Luton area appears to have been focussed on the alluvial river terraces at Sundon Park c.4km upstream of the Site. By the Roman period, however, settlement is recorded slightly further downstream. Sections of service roads and timber buildings have been excavated at Limbury and Biscot, c.2–4km north-west of the Site; and structural debris and artefactual material have been discovered at Waller Street and Vicarage Street, within 50–250m of the Site. However, given that the original course of the River Lea flowed through the Site, it is unlikely that settlement was located here due to the risk of flooding. The natural resources of the floodplain may have been exploited by later prehistoric and Roman communities, but any archaeological signatures of such activity would likely comprise only unstratified artefacts (such as worked flints and/or pottery sherds) of limited heritage significance.

Early Medieval and Medieval 5.2 The early medieval period seems to have seen continuation of occupation at Limbury, since no traces of activity have been recorded within Luton’s town core. By the 10th century, however, settlement was apparently well-established on a piece of low-lying land beside the River Lea – serviced by several crossing points, watermills and a church. The location of this first church is unknown; it may or may not have occupied a site close to St. Mary’s, which was built in the 12th century to replace it. Given the Site’s proximity to the historic town core, it is likely that the land here was used in some way, perhaps as grazing for livestock.

5.3 A watermill and a river crossing may have been located in the north-western corner of the Site (Albion Archaeology 2005, 27). Any buried remains of the mill are likely to be fragmentary, comprising only rubble or waterlogged timber footings. The river crossing might simply have been a ford, rather than a bridge, and would leave little trace in the archaeological record. Surviving evidence of the mill or river crossing could be of some archaeological interest. Alongside the River Lea, and in the small areas that escaped late 19th and 20th century development (see Sections 5.10– 5.11 and Fig. 6), there might also be some potential for waterlogged deposits and/or unstratified finds of medieval date. The Archaeological Assessment of Luton undertaken for the Extensive Urban Survey of Bedfordshire notes:

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‘[…] the small number of [previous] archaeological investigations does not provide a sufficient basis for assessing the archaeological potential of the historic core. Almost certainly there will be pockets of undisturbed archaeological stratigraphy which could shed great light on the town’s medieval development and answer many questions about its Anglo-Saxon origins’ (Albion Archaeology 2005, 50).

5.4 Two castles were constructed in the 11th and 12th centuries by Robert de Waudari and Fulk de Breaute, who respectively held the Manor of Luton at these times. Buried remains of the moat and internal features of Fulk de Breaute’s castle have been revealed through extensive archaeological works undertaken at Park Square (see Sections 4.15–4.20). Historic maps had shown a complex sequence of post- medieval and modern development here (much like the Site, see Sections 4.30– 4.33); but the excavations conducted by Headland Archaeology in 2013/2014 found most areas to be ‘relatively well protected beneath a series of buried soils and more recent dumping layers, the latter generated by the earlier demolition of 19th century buildings’ (Woodley and Abrams 2012, 1).

5.5 Woodley and Abrams have proposed that the north-eastern arm of the moat and domestic quarter of the castle complex might have extended into the southernmost corner of the Site, on the south side of the River Lea (Woodley and Abrams 2012, 12). However, as previously discussed (see Sections 4.21–4.24), this suggestion is not robustly supported by archaeological or documentary evidence. Any surviving archaeological remains related to Fulk de Breaute’s castle might comprise buried sections of feeder channels from the River Lea to the moat and/or the moat itself; but the remains of buildings are unlikely if they stood upon a mound that is no longer extant.

5.6 Following the 2011 excavations at Park Square, it was emphasised that: ‘Despite widespread disturbance due to development from the 18th century onwards, significant remains of Fulk de Breaute’s castle were still discovered’ (Woodley and Abrams 2012, 14). Modern construction activity within the Site cannot be presumed to have removed all buried traces of water management features. The fills of buried ditch features could contain palaeoenvironmental and artefactual material relating to the use of the castle complex in the 13th–14th centuries. Such evidence could be of archaeological significance.

Post-medieval and Modern 5.7 The Site likely remained under pasture from the later medieval period into the post- medieval period, before, in the early 18th century, St. Mary’s Vicarage was built close to the western portion of the Site. Historic maps and images from the early to mid-19th century show the vicarage and its outbuildings and gardens. Except for a building on the corner of Church Street, the rest of the Site is devoid of any other substantial structures prior to c.1880.

5.8 The Girls’ School/St. Mary’s Hall and adjacent housing of c.1901 were demolished only in c.1968; and new buildings were subsequently erected in their place for the power station between the western and eastern portions of the Site. The former terraced streets of Pondwicks Road, Henry Street, Alfred Street, Peach Street, were cleared and the area redeveloped for light industry only in the late 20th century. It is very likely that structural remains of these buildings survive – even beneath the now-demolished industrial units if they were constructed atop of a levelled demolition layer and did not have deep foundations. Wall footings and cellars of 19th century properties may not have been disturbed. Elsewhere in the Site, groundworks for the creation of car parks and new roads may also have been of shallow depth. However, any structural remains of Edwardian terraced housing are considered to be of limited heritage significance only.

5.9 It is likely that building foundations and debris from the former power station are buried within the Site: not least, of the coal depot and sidings, the large works complex on the north side of the River Lea, and activity associated with the cooling towers and electricity generating station on the south side of the River Lea (Figs. L and M). However, such remains are considered to be of little to no heritage significance.

Previous Impacts 5.10 Depths of the foundations of historic buildings are unknown, but it is worth noting that the terraced houses of Pondwicks Road, Henry Street, Albert Street and Peach Street probably had cellars. The construction of buildings for the power station and the culverting of the River Lea probably required groundworks to some depth. However, the late 20th century industrial units were probably built on a demolition layer from the former power station and may have had minimal impact upon earlier structural remains.

5.11 Areas of medieval archaeological potential comprise the north-western corner of the Site (assuming that ground disturbance for the construction of the coal depot and sidings was fairly minimal); and the south-eastern corner of the Site, either side of the River Lea (which was formerly occupied by gardens along Pondwicks Road and Henry Street). There may also be undisturbed ground in the very centre of the Site, alongside the culvert of the River Lea, and in the vicinity of what was once Albert Street.

6. SETTING OF HERITAGE ASSETS

6.1 An appraisal was undertaken at an early stage to identify whether the proposed development would have any impact upon the significance of nearby designated heritage assets through alteration of their setting. The proposed development comprises two parcels of residential and commercial development. The stadium plot (situated between the two Site locations) has already been granted planning permission as part of the extant consent and is not part of this planning application. In the context of the setting assessment, the stadium therefore forms part of the baseline.

6.2 Step 1 of Historic England’s guidance (2017; see Section 3) was conducted through a map-based search of the National Heritage List for England. Numerous Listed Buildings were identified in the surrounding townscape, mostly concentrated in the Conservation Areas of Town Centre, Plaiters Lea and High Town (see Fig. 1). After reviewing List Entry descriptions, using Google Earth imagery to ascertain their locations in relation to the Site, and visiting selected assets during the study area walkover, it was judged that the Grade I Listed St. Mary’s Church was potentially sensitive to the proposed development and thus required further settings assessment – on account of being a notable historic landmark located in proximity to the Site. Almost all of the other Listed Buildings are 19th and 20th century townhouses, public houses or former factories of the hatting industry. Only the immediate physical surroundings (such as street frontages) and associations with other nearby built assets contribute to their heritage significance. There is no direct relationship with the Site.

6.3 The Step 1 exercise indicated that the Site was not a key element of setting of any of the Conservation Areas. However, a rigorous explanation of the Step 1 exercise undertaken for the Plaiters Lea Conservation Area is provided below, since it is located c.10m to the west of the Site and has been identified as a potential concern in consultation with Historic England. A detailed settings assessment is then provided for the Grade I Listed St. Mary’s Church – supported by photographs taken during the site visit.

Plaiters Lea Conservation Area Character and appearance 6.4 Plaiters Lea Conservation Area encompasses a 250m section of Guildford Street as well as Bute Street, Cheapside, John Street, Silver Street and Melson Street; its

eastern boundary (revised in 2020; LBC 2020) is located is c.10m to the west of the Site (see Fig. 1). Nine buildings are Listed at Grade II. A detailed Historic Area Assessment of Plaiter’s Lea was undertaken by English Heritage (now Historic England) in 2011; and provides a detailed synthesis of the development and built character of this historic straw-plaiting and hat-making district. English Heritage has also produced a more general synthesis, ‘The Hat Industry of Luton and its Buildings’ (2013), whilst an Appraisal was produced in support of the boundary change in 2020 (LBC 2020). Within Plaiter’s Lea, there are many surviving mid- to late 19th and early 20th century buildings of various scales and styles that were formerly used for hat production, storage, sale and distribution (Carmichael et al. 2011, 44). Despite conversion into residential units and business premises, deterioration of historic fabric, and the incursion of modern development (especially at Silver Street, ‘which lies in the shadow of the Arndale’ (ibid, 82–83)), English Heritage considered that: ‘The area retains the character of an artisanal quarter in much the same way as the Birmingham Jewellery Quarter or the Northampton Boot and Shoe Quarter’ (ibid, 1).

6.5 The Historic Area Assessment describes the Great Northern Steam Mills at Bute Street as ‘a prominent building’, and identifies Nos. 40, 50 and 68 Guildford Street as ‘very distinctive buildings notable for their sheer scale and the complexity of architectural motifs and styles that were incorporated’ (Carmichael et al. 2011, 69– 70). Other buildings such as 30 Guildford Street and 35 John Street, are highlighted as exemplars of interwar development (ibid, 82). Although the buildings in Plaiters Lea exhibit a diverse mixture of architectural styles, there is ‘a particular cohesion of design resulting from the rapid development of this small area’ (ibid, 69). However, equally: ‘The process of constant re-working and redefinition of existing buildings is a recurring theme’, with the street frontages ‘frequently interrupted by vacant plots and large open areas, now generally used as temporary car parks’ (ibid, 42–44).

6.6 Key characteristics of Plaiters Lea Conservation Area are summarised as follows:

1. Commercial/industrial frontages • Combined doorway, passageway and display window at ground-floor level found on buildings of every period and style. • Raised ground-floor over basement, with lights to basement. • Use of banded rustication on buildings of all periods. • Gables resulting from development at right angles to the street, with long rear ranges occupying the whole of the plot.

2. Variety in scale, materials and architectural styles • Prevalence, from the 1880s onwards, of four storey factory/showroom blocks, often forming a contrast with smaller buildings to either side. • Adoption, from the 1880s onwards, of pier and panel design reflecting the use of modern cast-iron construction, creating a more industrial aesthetic which contrasts with buildings of conventional construction such as the public houses.

3. Increasing and often eclectic use of fashionable styles and materials • Use of Victorian polychromy, Queen Anne Revival, Neo-Jacobean, Edwardian Baroque, Neo-Georgian and Neo-Classicism.

Setting 6.7 The historic street pattern of Guildford Street, Bute Street, Cheapside, John Street, Silver Street and Melson Street is the only element of setting that contributes to the character and appearance of Plaiter’s Lea Conservation Area. These streets provide context for the historic buildings and channel movement – with Bute Street being a key pedestrianised thoroughfare connecting Luton railway station and The Mall, and John Street providing access to the University (Carmichael et al. 2011, 41). English Heritage considered that: ‘The levels of public perception of the historic significance and value of the Plaiters Lea Conservation Area are almost certainly conditioned by the transitory nature of experience here’ (ibid). The wider physical surroundings – i.e. Luton railway station (to the north), St. Mary’s Road and beyond it, the Site (to the east), 1960s council offices (to the west), and The Mall (to the south) – do not contribute to the character and appearance of Plaiter’s Lea Conservation Area. Further, glimpsed views of tree-covered slopes of the suburb of Hart Hill are incidental, and will be viewed in the context of the approved stadium, and do not contribute to the significance of the Conservation Area. Furthermore, the proposed development does not include the previously approved podium element of the scheme, and as a consequence engages with Guildford Street more strongly. The proposed development does not pose a threat to the significance of the Conservation Area and no further assessment is required.

Grade I Listed Church of St. Mary Special architectural and historic interest 6.8 The List Entry for St. Mary’s Church describes the scale of the building, its distinctive flint and stone chequerwork, three-stage tower and embattled parapets (Photo 1); and acknowledges earlier origins than the 14th–15th century architecture otherwise suggests (NHLE Ref. 1114615; see Section 4.11). Attention is given to

detailing distinctive features such as the ‘octagonal angle turrets’, ‘moulded cornice with gargoyles at corners’, ‘cinquefoil lights in belfry windows’ and ‘canopied statue niches’. The principal façade is the north-west facing elevation (Photo 2). Despite restoration (1865–1885), St. Mary’s Church has retained much of its medieval fabric and is recognisable from engravings and etchings produced at the turn of the 19th century (see Section 8). The heritage significance of the Church is considered to be principally derived from a combination of illustrative historical value, aesthetic value and communal value – as embodied by its physical fabric.

Photo 1 View of the tower of St. Mary’s Church from the churchyard path

Physical surroundings – ‘what matters and why’ 6.9 St. Mary’s Church was established by Robert Earl of Gloucester when he acquired the Manor of Luton in the 12th century (see Section 4.11). It is not clear whether St. Mary’s Church was built on an entirely different site to its Saxon precursor (Albion Archaeology 2005, 19); but it nonetheless occupied a well-chosen location to the east to the settlement core and upon the north-facing slopes of high ground above the River Lea. This would have ensured visual prominence as well as safeguarding against floodwaters. The construction of St. Mary’s Church continued during the lordship of Robert de Waudari, who built a castle a short distance to the south (Fig. 3, 3); whilst Fulk de Breaute favoured a site adjacent to St. Mary’s for his own fortified castle complex (Fig. 3, 4). De Breaute’s castle and St. Mary’s Church were located on the eastern edge of the medieval town and market, overlooking the River

Lea and its crossing points (see Fig. 3). Historical associations between St. Mary’s and these other elements of the medieval landscape contribute to its heritage significance; but these associations are no longer recognisable within the present- day townscape.

Photo 2 Primary façade (north-west facing elevation) of St. Mary’s Church

6.10 During the post-medieval period, there would have been a functional association between St. Mary’s Church and St. Mary’s Vicarage (Fig. 3, 9); but this building was demolished in 1907 and modern urban development has completely eroded any sense of the once semi-rural setting (see Fig. E). There are surviving components of the post-medieval street pattern, but the use and character of these streets have changed. Whilst St. Mary’s Road was built in the early 20th century (see Section 4.33), Church Street follows the same alignment along the north-western boundary of the churchyard as shown on the 1842 Tithe Map (see Fig. B) and it remains an important feature of the physical surroundings of St. Mary’s Church. In addition, the churchyard, which has survived amidst the construction of high-rise buildings such as the Arndale Centre and the University of Bedfordshire, is considered to be a key element of the setting of the Church (see below). However, the built form that currently surrounds St. Mary’s is of variable architectural quality and does not contribute to the heritage significance of the Church.

Photo 3 Looking south-west towards St. Mary’s Church from St. Mary’s Road

Photo 4 Glimpse of St. Mary’s Church tower from the junction of Power Court, St. Mary’s Road and Church Street

Experience – ‘what matters and why’ 6.11 The principal façade of the Church is the north-west facing elevation. Key views are afforded from Church Street where it traces the north-western boundary of the churchyard (Photo 2). However, St. Mary’s Church is not an especially prominent or dominant building within the townscape. Only glimpsed views are possible on the approach from the west along St. Mary’s Road/Church Street (Photos 3 and 4); whilst on the approach from the east along St. Mary’s Road, views are screened by vegetation and a 20th-century single-storey church hall (Photo 5). The church hall does not contribute to the aesthetic value of the Church. From near the junction of Church Street with Park Street, views of St. Mary’s Church are currently obscured by the large multi-storey building of the University of Bedfordshire.

6.12 St. Mary’s Road is the thoroughfare for vehicular traffic whilst Church Street is a bus and pedestrian route connecting The Mall, the University of Bedfordshire and the town centre. The proximity of the University of Bedfordshire buildings to St. Mary’s Church has meant that the churchyard paths see regular pedestrian use – especially the cut-through from Church Street to Vicarage Street, which passes beneath the church tower (Photo 6). There are also glimpsed, funnelled views of the tower from the alleyway of St. Ann’s Lane and the recently-redeveloped Vicarage Street (not illustrated). The architectural features of the Church – such as the embattled parapets and moulded cornice with gargoyles (see Section 6.8) – are best appreciated at close range, from the churchyard paths. The churchyard is an area of green space in which to experience St. Mary’s Church.

6.13 Long-ranging views from the churchyard are limited to glimpses of the tree-covered slopes of the suburbs of Hart Hill (to the north); whilst from the church tower, it is possible to see Luton Cemetery (to the east). Although land at Hart Hill may have formed part of the historic estate of St. Albans Abbey (of which St. Mary’s would also have been part), it is no longer an element of setting that contributes to the heritage significance of the Church. Meanwhile, despite a functional association between St. Mary’s Church and Luton Cemetery, except from the tower, there is no recognisable or meaningful intervisibility between the two locations. From Luton Cemetery, only glimpses of the tower are possible between tree cover and from the cemetery lodge.

Luton railway station

St. Mary’s Church

Church Hall

Photo 5 Glimpsed view of St. Mary’s Church from St. Mary’s Road

Photo 6 Pedestrian thoroughfare beneath the tower of St. Mary’s Church

7. IMPACT ASSESSMENT

Summary of Proposals 7.1 The Site is proposed for redevelopment by Luton Town Football Club. The proposed development comprises an outline application, with all matters reserved except for access, for a mixed-use development comprising: residential floorspace; appropriate town centre uses including a foodstore, health care centre, retail, food and drinking establishments; car and cycle parking; and associated access, highways, utilities, public realm, landscaping, riverworks and associated ancillary works and structures.

7.2 Visualisations of the proposed development (see the Townscape and Visual Impact Assessment) illustrate its form from key viewpoints, as well as the elements of the development that have an extant consent. The stadium element of the approved planning permission does not form part of this planning application, and instead forms part of the baseline conditions.

Impacts upon buried archaeology 7.3 There is potential for archaeological remains to survive within the Site, since 19th and 20th century groundworks cannot be presumed to have removed all buried traces of features and deposits. This assessment has critically considered the reconstruction of Fulk de Breaute’s castle complex that was proposed by Woodley and Abrams in 2012; and found there to be insufficient conclusive evidence supporting the projected continuation and return of the moat into the East End of the Site.

7.4 However, this is not to say that archaeological remains associated with the castle complex are wholly absent. Most likely to occur are buried sections of feeder channels from the River Lea to the moat and/or the moat itself. The fills of such ditches which could contain palaeoenvironmental and artefactual evidence of archaeological interest. Construction of the proposed development could disturb, truncate or remove such features and deposits, resulting in a degree of less than substantial harm to their heritage significance. Meanwhile, the presence of structural remains of medieval buildings that once stood upon a motte is unlikely; but elsewhere within the Site, particularly along the corridor of the River Lea, there is potential for unstratified finds relating to medieval-period activity.

Impacts upon designated heritage assets 7.5 Elements of the setting of the Grade I Listed Church of St. Mary that contribute to its significance are as follows: • Historic geographical and topographical context (i.e. established on the edge of the medieval settlement, overlooking the River Lea); • Associative relationships with other known (non-extant) heritage assets (i.e. Fulk de Breaute’s castle); • Approaches from the north-west, north and south (along St. Mary’s Road, Church Street and from the University of Bedfordshire buildings); • Experiences afforded at close range, from the paths that skirt and run through the churchyard – which itself comprises a green oasis.

7.6 The Site is not an element of the setting of St. Mary’s Church that contributes positively to its heritage significance. The proposed development will introduce additional built form to the north of St. Mary’s Church (see Townscape and Visual Impact Assessment Viewpoint A), visible in the context of the extant consent, comprising the stadium building (Ref: 16/01400/OUTEIA) and non-material amendments (Ref: 20/01497/AMEND). The visibility of the proposed development is not considered to be harmful to the significance of the Church. Despite the proximity, scale and massing of the proposed high-rise buildings, the development will not impact upon the historic fabric of the Church and will not constrain opportunities for its appreciation. Key approaches along Church Street and from the University of Bedfordshire will not be altered; and the north-west facing elevation will remain the primary façade of the Church.

7.7 From the churchyard, views of Hart Hill are incidental and viewed in the context of the approved stadium, thus, the visibility of the proposed development will not result in harm to the heritage significance of St Mary’s Church. From the tower, although the proposed development will be visible as part of the existing urban form in the middle and foreground, it will not prevent or obscure the view of Luton Cemetery. Furthermore, the proposed development might encourage public use and experience of St. Mary’s, if the churchyard sees more frequent use by people walking to and from the town centre and the stadium complex.

8. CONCLUSIONS

8.1 Sources consulted for this assessment indicate a complex sequence of historical development within the Site. Programmes of archaeological work at Park Square, c.150–250m to the south of the Site, have identified buried remains of the castle that was established by Fulk de Breaute in AD1221. Woodley and Abrams (2012) have proposed that the north-eastern part of the castle complex (including the arm of its moat) extended across what is now St Mary’s Road and possibly into the East End of the Site. Their projected line of the moat is not well-supported by documentary and archaeological evidence; but there is nevertheless potential for buried remains of Fulk de Breaute’s castle to occur within the East End of the Site. Feeder channels from the River Lea and/or sections of the moat could survive at more than 1m below current ground level, relatively undisturbed by 19th and 20th century development, and could be of heritage significance. However, construction activities associated with the proposed development could truncate or remove buried remains, resulting in a degree of less than substantial harm to their heritage significance.

8.2 A medieval mill and a river crossing may have been located in the West End of the Site, but any surviving structural evidence of these features is likely to be fragmentary. Along the current, now culverted, corridor of the River Lea, there could be waterlogged palaeoenvironmental and archaeological evidence of medieval activity. The Site was probably under pasture for much of the post-medieval period, prior to the construction of St. Mary’s Vicarage in the early 18th century, which was located between the East End and West End of the Site. Multiple phases of residential and industrial development then occurred within and in the immediate vicinity of the Site from the late 19th century onwards, as shown by historic mapping. There will likely be truncated buried remains of the foundations of the Girls’ School (which later became St. Mary’s Hall), Victorian and Edwardian terraced housing and 20th century industrial buildings; but such remains would be of little archaeological interest. Their disturbance or loss during construction of the proposed development is not considered to result in harm to their limited heritage significance.

8.3 A detailed settings assessment was undertaken for the Grade I Listed St. Mary’s Church. The Site does not form part of the setting of the church that contributes positively to its heritage significance. The primary elevation of St. Mary’s Church is its north-west facing elevation, which presents a number of features of architectural interest that are best appreciated from Church Street and the paths through the churchyard. Historical associations between St. Mary’s Church and Fulk de

Breaute’s castle and St. Mary’s Vicarage, which formerly stood between the western and eastern portions of the Site, are no longer recognisable within the present-day townscape; and views from the churchyard towards Hart Hill, and from the Church tower towards Luton Cemetery, are incidental. The proposed development will introduce additional, substantial built form c.20m to the north of St. Mary’s Church, immediately to the north of approved stadium building. This change to setting is not considered to be harmful to the Church’s heritage significance. The settings assessment concluded that the development has the potential to foster greater public appreciation of the Church.

8.4 Step 1 of Historic England’s settings guidance was undertaken for other designated heritage assets in the surrounding townscape. Particular attention was given to the Plaiters Lea Conservation Area, on account of its proximity to the Site. However, the Site is not an element of setting that contributes to its heritage significance. Thus, whilst the proposed development will be visible from within the Conservation Area (in views towards Hart Hill), the character and appearance of the Conservation Area will not be harmed.

8.5 In summary, no overriding heritage constraints to the proposed development have been identified. However, there is potential for archaeological remains to occur within the Site; a scope of further archaeological works in advance of and during construction will need to be agreed with relevant heritage consultees at the Local Planning Authority.

9. REFERENCES

Albion Archaeology 2005 Extensive Urban Survey for Bedfordshire: Luton Archaeological Assessment. Available online: http://archaeologydataservice.ac.uk/archiveDS/archiveDownload?t=arch- 674-1/dissemination/pdf/Luton/fulltext/Luton_Assessment.pdf, accessed 25th May 2016.

Albion Archaeology 2009 Land at the University of Bedfordshire, Park Square, Luton: Archaeological Trial Trenching. Report No. 2009/55.

Archaeology South-East 2008 Archaeological Evaluation on Land at Vicarage Street, Luton, Bedfordshire (Site A). Report No. 2008/200.

Archaeology South-East 2010 Land at Vicarage Street, Luton, Bedfordshire: Post- Excavation Assessment and Updated Project Design. Report No. 221053.

Bedford Borough Council and Central Bedfordshire Council (BBC/CBC) 2016a Luton in the Iron Age. Available online: http://www.bedfordshire.gov.uk/CommunityAndLiving/ArchivesAndRecordOf fice/CommunityArchives/Luton/LutonIntroduction/LutonInTheIronAge.aspx, accessed 1st June 2016.

Bedford Borough Council and Central Bedfordshire Council (BBC/CBC) 2016b Luton in the Romano-British Period. Available online: http://www.bedfordshire.gov.uk/CommunityAndLiving/ArchivesAndRecordOf fice/CommunityArchives/Luton/LutonIntroduction/LutonInTheRomanoBritish Period.aspx, accessed 1st June 2016.

Bedford Borough Council and Central Bedfordshire Council (BBC/CBC) 2016c Luton in the Dark Ages. Available online: http://www.bedfordshire.gov.uk/CommunityAndLiving/ArchivesAndRecordOf fice/CommunityArchives/Luton/LutonIntroduction/LutonInTheDarkAges.aspx accessed 1st June 2016.

Bedford Borough Council and Central Bedfordshire Council (BBC/CBC) 2016d Luton in the Anglo-Saxon Chronicle. Available online: http://www.bedfordshire.gov.uk/CommunityAndLiving/ArchivesAndRecordOf

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Bedford Borough Council and Central Bedfordshire Council (BBC/CBC) 2016e Dallow Manor of Luton. Available online: http://www.bedfordshire.gov.uk/CommunityAndLiving/ArchivesAndRecordOf fice/CommunityArchives/Luton/DallowManorLuton.aspx, accessed 7th June 2016.

Bedford Borough Council and Central Bedfordshire Council (BBC/CBC) 2016f St. Mary’s Luton Vicarages. Available online: http://www.bedfordshire.gov.uk/CommunityAndLiving/ArchivesAndRecordOf fice/CommunityArchives/Luton/EstablishedChurchinLuton/SaintMarysLuton Vicarages.aspx, accessed 2nd June 2016.

British Geological Survey (BGS) 2011 Geology of Britain Viewer, 1:50,000 geological mapping, solid and superficial. Available online: http://mapapps.bgs.ac.uk/geologyofbritain/home.html, accessed 25th May 2016.

Carmichael, K., McOmish, D. and Grech, D. 2011 Plaiters’ Lea Conservation Area, Luton: Historic Area Assessment. English Heritage Research Department Report Series 069–2011.

Carmichael, K., McOmish, D. and Grech, D. 2013 The Hat Industry of Luton and its Buildings. Available online: http://www.luton.gov.uk/Environment/Lists/LutonDocuments/PDF/Local%20 Plan/Natural%20and%20historic%20environment/ENV%20002.pdf, accessed 7th June 2016.

Chartered Institute for Archaeologists 2020 Standard and Guidance for Historic Environment Desk-Based Assessment.

Cook, R. (ed.) 2001 Around Luton: Francis Frith’s Photographic Memories. Frith Book Co. Ltd.

Cranfield University. n.d. Soilscapes soil type viewer. Available online: http://www.landis.org.uk/soilscapes/, accessed 25th May 2016.

Davis, F. 1855 The History Of Luton, With Its Hamlets Etc. Luton: J. Wiseman.

Davison, W. (ed.) 1954 Saint Mary’s – Luton’s Parish Church. Luton: White Crescent Press.

Department for Communities and Local Government 2019 National Planning Policy Framework. Available online: http://planningguidance.planningportal.gov.uk/wp-content/themes/planningguidance/assets/NPPF.pdf, accessed 25th May 2016.

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Department for Culture, Media and Sport 2010 Principles of Selection for Listing Buildings. Available online: https://www.gov.uk/government/uploads/system/uploads/attachment_data/fil e/137695/Principles_Selection_Listing_1_.pdf, accessed 25th May 2016.

English Heritage 2008 Conservation Principles, Policies and Guidance. Available online: https://content.historicengland.org.uk/images- books/publications/conservation-principles-sustainable-management- historic-environment/conservationprinciplespoliciesguidanceapr08web.pdf/, accessed 25th May 2016.

Headland Archaeology 2011 Archaeological Investigation, Recording, Analysis & Publication at the University of Bedfordshire, Park Street, Luton (Phase2a): Updated Project Design and Assessment of Results. Report No. BULC11.

Headland Archaeology 2015 Archaeological Investigation, Recording, Analysis & Publication at the University of Bedfordshire, Park Street, Luton (Phase 3 – Library and Learning Resources Centre): Updated Project Design and Assessment of Results. Report No. UBED13.

Historic England 2015 Historic Environment Good Practice Advice in Planning Note 2: Managing Significance in Decision-Taking in the Historic Environment. Available online: https://content.historicengland.org.uk/images- books/publications/gpa2-managing-significance-in-decision- taking/gpa2.pdf/, accessed 25th May 2016.

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Historic England 2019 Advice Note 1: Conservation Area Designation, Appraisal and Management.

Historic England 2016 Advice Note 2: Making Changes to Heritage Assets. Available online: https://content.historicengland.org.uk/images- books/publications/making-changes-heritage-assets-advice-note- 2/heag023-making-changes-to-heritage-assets.pdf, accessed 25th May 2016.

Keir, W. 2011 Archaeological investigations on the western edge of the site of Fulk de Breaute’s castle, Park Square, Luton. Bedfordshire Archaeology.

Luton Borough Council (LBC) 1998 Luton Hat Trail - The Bute Street Area.

Luton Borough Council (LBC) 2003 Luton: Hat Industry 1750 to 2000. Luton Museum Service. Luton Borough Council (LBC) 2020 Plaiters’ Lea: The Hat District Conservation Area Appraisal July 2020

Luton Museum 1976 Vicarage Street Excavations, 28the June – 2nd July 1976. Unpublished report.

Oake, M. et al. 2007 Research and Archaeology: Resource Assessment, Research Agenda and Strategy. Bedfordshire Archaeology, Monograph 9.

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Stubbs, M. (ed.) 1997 Images of England – Luton. The History Press.

University of Hull n.d. Open Domesday – Luton. Available online: http://opendomesday.org/place/TL0821/luton/, accessed 1st June 2016.

White, H. (ed.) 1977 Luton Past and Present. Luton: White Crescent Press Ltd.

Woodley, N. and Abrams, J. 2012 Inside Fulk de Breaute’s 13th-Century Castle. Bedfordshire Archaeology, Vol. 26: 1–15.

Cartographic sources

1815 (1855) Higgins’ Map of Luton 1826 Bryant’s Map of Bedfordshire 1839 Brown’s Map of Luton 1842 Tithe Map and Award for Luton 1845 Plan of St. Mary’s Vicarage (Bedfordshire Archives, P85/2/12/3) 1855 (1862) Todd’s Pictorial Map of Luton: The Great Straw Bonnet Emporium, The Elevations of The Principal Buildings 1876 Map of the Borough of Luton 1880 Ordnance Survey County Series for Bedfordshire, 1:2,500 1880 Ordnance Survey Town Plan of Luton, 1:500 1895 Goad’s Fire Insurance Plan for Luton 1901 Ordnance Survey County Series for Bedfordshire, 1:2,500 1924 Ordnance Survey County Series for Bedfordshire, 1:2,500 1963 Ordnance Survey Plan of Luton, 1:1,250 1968–1979 Ordnance Survey Plan of Luton, 1:1,250 1981–1986 Ordnance Survey Plan of Luton, 1:1,250

Other archival material

1805 Engraving of St. Mary’s Church (Bedfordshire Archives, X254/88/170) 1806 Engraving of St. Mary’s Church (Bedfordshire Archives, X376/36) 1900 Postcard of St. Mary’s Vicarage (Bedfordshire Archives, Z580/10) unknown Photograph of Power Court Cooling Towers (image found online, http://hart- hill.co.uk/Maps_and_photos/Pages/Photos.html#17) 1930 Photograph of Church Street and Crescent Road (image found online, http://hart-hill.co.uk/Maps_and_photos/Pages/Photos.html#14) 1943 Photograph of Power Court Cooling Towers (image found online, http://hart- hill.co.uk/Maps_and_photos/Pages/Photos.html#16) 1955 Photograph from Queen Elizabeth’s visit to Luton (image found online, http://m.bedfordtoday.co.uk/webimage/1.3375204.1325238573!image/2736 446242.jpg_gen/derivatives/landscape_393/2736446242.jpg) 1966 Photograph of Power Court Cooling Towers (image found online, https://pbs.twimg.com/media/CeLA9vaWwAEw3Rl.jpg)

1969 Painting of St. Mary’s Hall and Cooling Towers, Luton by Edward Callam (image found online, http://artuk.org/discover/artworks/st-marys-hall-and- cooling-towers-luton-bedfordshire-48392 1969 Photograph of Power Court Cooling Towers (image found online, https://pbs.twimg.com/media/CC-3C3JWYAA6vrZ.jpg)

Aerial photographs

11th November 1943 US/7PH/GP/LOC75 10th April 1947 RAF/CPE/UK/1965 11th September 1947 RAF/CPE/UK/2306 27th September 1947 RAF 30005 18th January 1954 RAF/58/1342 2nd June 1955 RAF/82/1208 6th June 1955 RAF/58/1779 6th July 1955 RAF/82/1229 28th August 1961 RAF/543/1426 14th April 1969 OS/69110

APPENDIX A: GAZETTEER OF RECORDED HERITAGE ASSETS AND OTHER ELEMENTS OF THE HISTORIC ENVIRONMENT

No. Description Period Status NGR HE ref. Major Source (all TL) HER ref. AMIE ref. 1 Archaeological evidence of Roman 0958 10599 HER Roman occupation in the 2107; 205 vicinity of Vicarage Street, comprising building debris (tile 0923 and flue tile). A possible kiln 2125 was previously reported at Waller Street, based on the discovery of a large quantity of tile by workmen in 1908. 2 Possible site of a medieval Medieval 0952 10819 HER watermill, as recorded by the 2138 Domesday Survey. 3 Site of a castle built in the Medieval 0907 ---- Albion early- to mid-12th century by 2079 Archaeology Robert de Waudari, a foreign 2005 mercenary to whom the manor of Luton was granted by King Stephen. 4 Site of a castle built in 1221 by Medieval 0959 185 HER; Fulk de Breaute. May have 2109 extended from (what is now) Headland St. Mary’s Church (N), Lea Archaeology Road (S), St. Ann’s Road (W) 2011 and the River Lea (E). Medieval boundary ditches, pits, a section of the moat and the footprint of a large timber- framed building were revealed during excavations conducted in 2009. 5 A number of small-scale Medieval 0930 16993 HER excavations in the centre of 2116 11950 Luton have also unearthed deposits relating to the core of medieval settlement on the south side of the River Lea. 6 The probable site of another Medieval 1028 361 HER core of medieval settlement is 2111 17102 recorded on the north side of the River Lea. The remains of St. Anne’s Chapel and Tower are known to have survived nearby until the early 17th and early 18th century respectively. 7 Grade I Listed Building of St. Medieval Listed 0953 1114615 NHLE Mary’s Church. Of 12th 2120 8926 century origin, its fabric is predominantly of 14th–15th century date; with extensive restoration 1865–1885. 8 George Street was the main Post- 0911 19561 HER thoroughfare through Luton in medieval 2123

the post-medieval period. It was turnpiked in 1727. By the mid- to late-19th century it was the centre of trade and commerce. There are a number of Grade II Listed townhouses along Upper George Street and George Street West. 9 Site of the former vicarage of Post- 0961 12395 HER; St. Mary’s Church, referred to medieval to 2129 in documentary sources of Modern Bedford 1707 and 1825; and illustrated Borough in 1845 and 1900. Council 10 The Plaiters Lea area, centred Modern 0915 10528 HER; on Guildford Street, was the 2149; 18120 focus for hat and straw plaiting Carmichael in the mid- to late-19th century. 0937 et al. 2011 The area between Guildford 2146; Street and Bute Street was the focus of heavier industry – 0930 hosting the Great Northern and 2147 Bute Steam Mills from the late 19th to mid-20th century. 11 Site of a former school for Post- 0953 12393 HER girls, as shown on a map of medieval to 2131 1876. Modern 12a Hatfield, Luton and Dunstable Modern 0927 14086 HER Branch Railway, opened in 2158 1858 and closed in 1965. Now used for the Luton–Dunstable Busway. 12b Midland Railway line, opened 12933 in 1868. Originally built to run from Wigston to Hitchin; but the present route runs to St. Pancras International.