jones lang lasalle ltd head of strategic growth central

Jones Lang LaSalle Limited

Registered in England & Wales Number 1188567

Registered Office 30 Warwick Street London W1B 5NH

FAO: Caroline Danby Head of Strategic Growth Central Bedfordshire Council Priory House Monks Walk Chicksands Shefford SG17 5TQ

Jones Lang LaSalle Ltd

30 Warwick Street London W1B 5NH +44 (0)20 7493 4933

jll.co.uk

Our ref 1000448759

Via Email: [email protected]

5th May 2021 Dear Ms Danby

Central Bedfordshire Local Plan 2015 – 2035 Proposed Main Modifications (March 2021)

Representations on Behalf of Defence Infrastructure Organisation and Homes England We are writing behalf of the Defence Infrastructure Organisation (“DIO”) and Homes England with

Representations in respect of the Council’s Proposed Main Modifications to the emerging Central

Bedfordshire Local Plan. In Section 1 below we provide Representations on the Counc il’s Schedule of Main

Modifications, in Section 2 we provide Representations on the Proposed Modifications to the Proposals

Maps and, in Section 3, we set out Representations on the modified Sustainability Appraisal. All of the

Council’s documents are dated March 2021.

The Council will be familiar with the Representations that DIO and Homes England have made previously

and the comprehensive and cogent manner in which it has argued against the deletion from the Plan of

Policy SE4. It should be noted at the outset that we remain firmly of the view that it is not necessary to

delete Policy SE4 in order to make the Local Plan sound and that the Inspectors have sufficient evidence to

agree necessary modifications to it. Such modifications would, as DIO and Homes England have submitted

previously, allow for RAF Henlow to simply be re-developed with a different balance of uses.

In EXAM 131, the Inspectors reiterated their concerns about removing RAF Henlow completely from the

Plan and referred to a possible alternative; that is identifying the site as a significant facility in the

countryside under Policy EMP5. We had exchanges of correspondence with the Council on this matter in

the early part of January 2021 and, on 15 January 2021, agreed a Statement of Common Ground (“SoCG”)

with the Council which set out the parties’ respective positions on how Policy EMP5 would need to change

in the event that Policy SE4 is deleted. On the same day, DIO wrote to the Inspectors with an explanation

of the position that it had taken in the SoGC, and additional submissions in respect of the A600 and MBDA.

The Inspectors were unable to take account of those submissions but noted that there would be an

opportunity to raise the points that DIO had made at this present stage of consultation. Accordingly, we

2

include below, under the relevant Main Modification references, the submissions that we originally made

in January and, for completeness, a copy of our January letter is attached (see Appendix 1).

1. Schedule of Main Modifications

MM7 and MM8 – New Policy SP1a and Associated Supporting Text

We note that MM7 and MM8 focus almost exclusively on the Oxford – Cambridge Arc and planned

infrastructure improvements as reasons why the Local Plan will need to be subject to a partial review

commencing within 6 months of its adoption. The text ignores the fact that there is another important

reason why the Plan will need to be the subject of a Review. This is housing need and the fact that the

Standard Method for assessing local housing needs indicates that there is a need in Central Bedfordshire

for some 2,3841 new homes per annum over the next 10 years, not 1,600 per annum as provided for in the

Local Plan. This will be a key driver in the Review process and should be acknowledged in both Policy SP1a

and the supporting text to it.

MM22 – New Paragraph 7.1.1

MM22 states that:

The Housing Trajectory (as 01/04/2020) demonstrates that there is a total supply of 44,756 homes which will be delivered throughout the lifetime of the plan. This represents a surplus of 5,406 homes and is 14% above the Plan requirement. While there is confidence that the allocation sites will deliver, the 14% surplus in the supply will provide sufficient flexibility in the event of any delay or non-delivery.

This is misleading. The 14% flexibility referred to in MM22 is derived from both commitments and windfalls.

The Local Plan actually only provides for the delivery of 41,883 new homes in the Plan period, just 6.4% over

the base requirement. MM22 should be amended to reflect precisely what the Plan itself is providing for in

terms of housing delivery and flexibility to deal with changes in circumstances.

MM26 – Changes to the Key Diagram

We noted in our December 2020 Matter 1 Hearing Statement that the Council is proposing to modify the

Key Diagram in several respects but, importantly, it is proposing to amend the boundaries of the Growth

Areas. Such amendments may only be made if they are necessary to make the Plan sound. The Council has

presented no evidence to suggest that the Plan would not be sound if the boundaries of the Growth Areas

remain as defined in the Submitted Plan. We note in particular that the Council’s proposed changes to the

boundary between the Central Area and the A1 Corridor are completely without explanation or evidence.

There is no need for this proposed Modification and this part of the Key Diagram should remain as

Submitted.

MM42 – Deletion of Policy SE4

1 Excluding any unmet needs that might be declared in Luton and may need to be provided for within Central Bedfordshire in due course.

3

As noted above we remain firmly of the view that it is not necessary to delete Policy SE4 in order to render

the Local Plan sound and that, instead, Policy SE4 should be modified as proposed by DIO and Homes

England.

Through the Examination into the Local Plan the Council has ventured several reasons as to why Policy SE4

should be deleted, one of which concerns the lack of demand for employment development of the type and

scale proposed in the Plan as submitted, and several have related to technical matters such as heritage and

traffic. We dealt comprehensively with all of these matters in our December 2020 Hearing Statements (and

earlier Hearing Statements) and, during the December 2020 Hearing Sessions, made it absolutely clear that

there are in fact no technical reasons why RAF Henlow should not be allocated for a housing-led mixed-use

development now.

Notwithstanding our December 2020 submissions, there are two interrelated highway matters that require

further comment. These both concern the A600 as it passes MBDA to the immediate west of RAF Henlow.

First, the Council referred during the December 2020 Hearing Sessions to EXAM 20 and went on to rely on

this (and its link to impacts forecast in respect of MBDA) to justify its proposed deletion of Policy SE4. We

would make the following brief points in respect of EXAM 20:

a) there is a technical transport evidence base that has informed the preparation of the Local Plan.

This is underpinned by outputs from the CBLTM; the Council’s strategic transport model. The CBLTM

has been used to test the likely effects of all development proposed in the Submission version of

the Local Plan. The CBLTM makes assumptions about the number of trips that are likely to be

generated by committed and proposed developments across Central Bedfordshire and how these

trips are likely to be distributed across the highway network. There is no suggestion in the evidence

base that the redevelopment of RAF Henlow (in line with Policy SE4) would give rise to unacceptable

adverse traffic impacts. Moreover, DIO and Homes England has demonstrated that a housing-led

mixed-use development would generate significantly less traffic than the employment-led mixed-

use development described within Policy SE4 (see Appendix 2 – Technical Note produced by

Stantec); and

b) EXAM 20 is wholly inadequate as a standalone piece of evidence. It is not a Transport Assessment

and has not been produced in a manner that is consistent with the methodology employed when

undertaking transport assessments. Critically, it focusses on what it describes as a ‘worst case

scenario’ – a scenario in which all traffic generated by committed development routes via the A600

past MBDA. Yet it contains no assessment of trip distribution / assignment from either committed

developments or RAF Henlow. The so called ‘worst case scenario’ is not a worst case at all, it is a

scenario that will never be encountered. It is simply not tenable to suggest that all traffic from all

committed developments in Shefford, Clifton, Lower Stondon and Henlow Camp, or indeed any

other location, will travel along the A600 past MBDA. In addition, it does not explain or evidence

the trip rates that it has applied and it refers only to 4 ‘committed’ developments. It doesn’t

consider at all the effect that housing and other allocations proposed elsewhere in Central

Bedfordshire might have on the A600. If the Council is right about the criticality of the A600 issue,

this begs the question whether it has ramifications for other major developments proposed in the

4

Local Plan and whether the transport evidence which the Council is relying on to justify other

proposals is fit for purpose. Ultimately, the approach taken in EXAM 20 is misleading and the

document is not one that can be relied upon to justify Main Modifications.

Secondly, during the December 2020 Hearing Sessions the Council invited the Inspectors to approach the

A600 issue on the basis that, if the 10,000 vehicle trip threshold were to be exceeded, this would mean that

MBDA would have to cease to operate. This also is grossly misleading. The 10,000 vehicle trip issue could

be addressed by MBDA relocating its processing facility to a position further away from the A600. This is a

project which MBDA has already commenced with full permission secured. DIO and Homes England will

continue to work with the Council and MBDA on the masterplanning of RAF Henlow, and the A600 issue,

but the A600 issue is not one that can be used to justify the deletion Policy SE4.

Ultimately, having reflected on the evidence that has been presented in respect of RAF Henlow during the

Examination, we remain firmly of the view that there are no grounds on which to justify the deletion of

Policy SE4. The redevelopment of RAF Henlow remains as sound a proposition today as it was when the

Local Plan was submitted. All that needs to change is the way in which the Local Plan describes the uses that

will be appropriate, shifting the balance from employment to housing.

MM111 – Changes to Policy SP7

Policy SP7 should recognise the potential for sites covered by Policy EMP5 to contribute ‘windfall’

development. Policy EMP5 should be included in the list of policies referenced within paragraph 5 of Policy

SP7 as follows:

MM118 – Changes to Policy H3

MM118 proposes that Policy H3 be re-written and that it includes the following words:

On larger sites of 300 units or more, the provision of an Extra Care Facility will be required, unless an alternative approach can be demonstrated to be more suitable having regard to site suitability or viability constraints. Extra care schemes will be restricted by S106 to ensure that the occupants are those in need of care and support in perpetuity.

So far as we can tell, no evidence has been presented by the Council, or anyone else, which demonstrates

that this modification must be made in order to render the Local Plan sound. It is simply not necessary for

developments of 300 dwellings or more to include an element of extra care accommodation to make them

acceptable in planning terms. This part of Policy H3 should remain as submitted.

Outside Settlement Envelopes, the Council will recognise the intrinsic character and beauty of the countryside and only particular types of development will be permitted. This includes the development of those sites allocated by this development plan, the redevelopment of significant facilities in the countryside and Green Belt in accordance with Policy EMP5, rural exception schemes, dwellings for the essential needs of rural workers and the re-use and replacement of existing buildings in accordance with Policies H5, DC1, DC2 or DC3

5

MM134 and MM135

CBC and DIO agree that RAF Henlow should be referenced within Policy EMP5 in the event that Policy SE4

is deleted from the Local Plan. As instructed by the Inspectors during the EiP Hearing Session on 11

December 2020, DIO and CBC have considered how Policy EMP5 and its supporting text would need to be

modified in this event and have reached a degree of agreement. However, the Parties disagree on whether

the Policy itself would need to be modified and are also not entirely in agreement on how the supporting

text should be drafted.

The Modifications that CBC and DIO each propose are set out in a SoCG dated 15 January 2021. CBC

preferred not to include within the SoCG, DIO’s explanation for the Modifications proposed by DIO.

However, DIO considers it important that an explanation is provided and so this is set out below.

The Supporting Text

DIO considers that RAF Henlow should not be referenced in paragraph 12.10.1 because:

a) this paragraph states that: “Central Bedfordshire is notable for the presence of a number of significant

employment facilities…”. RAF Henlow is not an employment facility; it is a military facility, a Sui Generis

use;

b) the paragraph states that: “These sites have the potential to provide additional jobs, which would help

to meet the employment objectives and aspirations of the Plan”. There is no prospect of a

redevelopment of RAF Henlow providing ‘additional’ jobs over and above the number maintained by

the MoD and CBC has stated to the Inspectors that the redevelopment of RAF Henlow, with either

housing or employment development, is not needed to help meet the objectives of the Plan; and

c) paragraphs 12.10.2 and 12.10.3 (which reference CBC expectations for the sites listed in paragraph

12.10.1) are all about economic or employment related development. Whilst DIO expects there to be

some employment development at RAF Henlow, the market will not support a major employment

development here (hence CBC’s proposed deletion of policy SE4) and, in any event, the greater need is

for housing and so RAF Henlow will be redeveloped primarily with new homes.

Accordingly, it is necessary for RAF Henlow to be addressed in a standalone paragraph in the supporting

text which appears immediately after paragraph 12.10.3. DIO has agreed with CBC that this will be done by

the new paragraph 12.10.4, and it is agreed that this will refer to the site being developed for non-military

uses. That paragraph, as agreed, is not prescriptive of the nature of the future uses of the site. Reference

to RAF Henlow in paragraph 12.10.1 would therefore create confusion, and even contradiction, about how

the site is to be treated and what is its future use may be.

The reference in the new paragraph to the airfield must reflect the up to date position and provide the

necessary clarity. The airfield is no longer used for either military or civilian flying. All flying ceased in March

2020 and flying cannot and will not resume. It is important that this is reflected in the Local Plan for the

benefit of all interested parties, including the local community.

6

The Policy

DIO and Homes England are firmly of the view that additional words need to be inserted into the Policy

which make it clear that it allows for the redevelopment of RAF Henlow with alternative (non-military) uses.

As currently drafted, the Policy only provides for the expansion, infilling or redevelopment of significant

facilities in the countryside or Green Belt in circumstances where the proposed development relates to the

existing use. This may be a perfectly acceptable requirement for the other sites listed in the Policy but it is

not an acceptable requirement for RAF Henlow. The closure of RAF Henlow was announced in 2016 and the

Base will be vacated by MoD by 2023. The phased relocation of military personnel has already commenced.

There is no prospect of a military use being re-instigated, or a use that is ‘related to’ the current military use

being introduced post-2023. Accordingly, unless the words ‘relates to that use’ are caveated for RAF

Henlow, the Policy will not allow for its redevelopment with non-military uses as required, irrespective of

what the supporting text says. And if the Policy does not explicitly provide for non-military development,

there is a prospect that it will not be re-used at all; an outcome that would be completely at odds with

national planning policy and Government objectives in respect of the re-use of redundant public sector

assets.

CBC asserted on 11 December 2020 that RAF Henlow currently contains residential and employment uses

and so its future redevelopment with housing and employment uses would be ‘related to the existing use’

and allowed by EMP5 as Submitted. It went on to indicate that it wants future uses to relate to ‘existing

uses’. This is incoherent, because the current use of the military base is sui generis. It is not at all like a site

containing traditional housing and employment uses. It is therefore unclear what limitation this would

impose. It also makes no sense in planning terms because, despite being unclear, it could be used to argue

for constraints on the future development of particular parts of the site on the basis simply of how the MoD

has used it, without regard to whether development of that kind or in that particular location is viable or

beneficial. Without absolute clarity on what Policy EMP5 does and does not allow for as regards RAF

Henlow, there is an unacceptable risk of the Policy being misinterpreted or misapplied in the future and a

Policy that is not clear and effective is unsound.

DIO and Homes England have given very careful consideration to how the Policy should be amended and it

is satisfied that its proposed Modification:

a) is the minimum required to render the Policy justified and effective (and, therefore, sound); and

b) would have no impact on the way in which the Policy applies to the other sites that are to be listed in

the opening paragraph of the Policy.

DIO and Homes England consider it important to note that the principle here has been agreed, because CBC

has agreed to supporting text (paragraph 12.10.4) which explicitly states that RAF Henlow will be developed

with alternative, non-military uses. Accordingly, our proposed addition to policy EMP5 does not reflect any

difference of substance. However, it is not appropriate for such a fundamentally important clarification to

be addressed only in the supporting text. It is the Policy against which future planning applications will be

considered and therefore the Policy must provide clarity and be consistent with the supporting text. A

7

mismatch between the supporting text and the policy will only create uncertainty and reduce the Policy’s

effectiveness in achieving the agreed intent that RAF Henlow should be developed for non-military uses.

For the avoidance of doubt, DIO and Homes England consider that Policy EMP5 and the supporting text to

it should read as follows:

12.10.1 Central Bedfordshire is notable for the presence of a number of significant employment facilities in the countryside and Green Belt. These sites have the potential to provide additional jobs, which would help to meet the employment objectives and aspirations of the Plan. These facilities have been identified as Cranfield University, its airport and Technology Park, Rookery South Resource Recovery Facility (RSRRF), Shuttleworth College, Millbrook Proving Ground, RSPB, DISC Chicksands, ZSL Whipsnade, Woburn Safari Park, Center Parcs, Toddington Motorway Services Area, Faldo Road Industrial Estate in Barton-le-Clay, Kier at Tempsford and Lockheed Martin, Ampthill.

12.10.2 It is clear that these major sites can make a significant contribution to the local economy and that a number of these also have the potential to attract high technology orientated businesses, creating specialist markets and a cluster effect. 12.10.3 The NPPF is clear about the need to secure economic growth. It recognises that the challenges presented by a low carbon future can still be met while also delivering this core objective. In order to proactively plan for businesses in within the key growth sectors emerging sectors like the green economy, the Council supports the development of innovation, research and development industries, particularly around the existing cluster of high technology centres of excellence of Cranfield University (including the area formerly known as Cranfield Technology Park), Cranfield Airfield and Millbrook Proving Ground. 12.10.4 RAF Henlow has been declared surplus to MoD requirements and is due to be vacated by 2023. At that point it, will be available for redevelopment to help meet future growth requirements. It is expected that the site will be redeveloped with alternative, non-military uses. The suitability of future uses and the redevelopment of the site will need to be carefully considered in the context of the existing and neighbouring uses, local infrastructure provision, community uses and landscape character, as well as the historic nature of the site, including on-site heritage assets such as the now disused airfield and associated buildings. Policy EMP5: Significant Facilities in the Countryside and Green Belt The significant facilities in the countryside and Green Belt, as identified on the policies maps, are: • Cranfield University (including the area formerly known as Cranfield University Technology Park and

Cranfield Airport (excluding the Airpark)),

• Rookery South Resource Recovery Facility (RSRRF)

• Shuttleworth College,

• Millbrook Proving Ground,

• RSPB, Sandy,

• DISC Chicksands,

• RAF Henlow,

• ZSL Whipsnade,

• Woburn Safari Park,

• Center Parcs,

• Toddington Motorway Services Area,

• Faldo Road Industrial Estate in Barton-le-Clay,

• Kier at Tempsford and

• Lockheed Martin, Ampthill

8

2. Policy Maps

PM34: EMP5 RAF Henlow

We note that the proposed Policy EMP5 designation does not include the RAF Henlow sewage treatment

works that lies to the east of Hitchin Road. This forms part of the Base and should be shown on the Proposals

Map as being covered by Policy EMP5. A location plan for the treatment works is attached (see Appendix

3).

3. Sustainability Appraisal Main Modifications

We have made numerous representations in respect of the Council’s Sustainability Appraisal (“SA”),

highlighting issues and errors that should by now have been corrected. Yet, in spite of us having made such

representations, the SA continues to make inappropriate, inaccurate and unsubstantiated assertions in

respect of RAF Henlow. We note, in particular, the following:

a) at paragraph 5.24 the SA states that: At Henlow Airfield and Camp the nearby service provision is

relatively limited and the development of the site may result in the loss of the existing onsite services.

There are no services currently on site that are available to the general public and would therefore be

lost as a consequence of development;

b) at paragraph 5.36 the SA states that: A significant negative effect has also been identified for Henlow

Airfield and Camp considering the constraints on the number of vehicle movements on the A600 which

would be one of the main points of access to this site. As noted above, there is no evidence, other than

the wholly unreliable evidence contained within EXAM 20, to suggest that the redevelopment of RAF

Planning permission will be granted for expansion, infilling or redevelopment of, significant facilities provided that the expansion, infilling or redevelopment is within the boundaries of the existing use, relates to that use (or in the case of RAF Henlow delivers suitable alternative uses) and enhances the contribution to the local or national economy. Significant expansion of existing facilities will be subject to the production of a development brief or masterplan prior to any application which will ultimately need to be endorsed by the Council. Within the Green Belt, the expansion of existing facilities will only be considered where proposals are consistent with National Policy. All proposals for significant development at these facilities will be assessed on an individual basis and in accordance with other relevant policies within the plan, including, but not limited to: 1. impact on the open countryside and any heritage assets; 2. provision of sustainable transport; 3. justification; 4. scale, layout and design – which must be appropriate to the establishment and its setting. Planning applications that are considered acceptable against these criteria and all other relevant plan policies will be considered favourably. In the future, major new sites may emerge in Central Bedfordshire. Any new major facilities with a similar level of importance in terms of employment or research once built, including Cranfield Airpark, will be considered under this policy as well as other relevant policies within the plan. Where a development brief or masterplan for a facility identified above has already been produced and endorsed by the Council, this should be a material consideration for future planning decisions.

9

Henlow would give rise to significant negative effect in highway terms and the matter of potential

impact on the MBDA business is, as we have said, capable of being address through the relocation of

its processing facility. Also, we can assure the Council and the Inspectors that the A600 will not be one

of the main points of access into the RAF Henlow site. The main accesses will be off Hitchin Road;

c) at paragraph 5.44 the SA states that: all 19 residential site options contain large areas of greenfield

land including sizeable areas of Grade 1, Grade 2 or Grade 3 agricultural soils. Therefore, potential

significant negative effects are identified in relation to the first part of this SA objective. This is not

correct, the land that is proposed to be redeveloped at RAF Henlow is entirely brownfield. It contains

no agricultural land;

d) paragraph 5.44 goes on to say: Henlow Airfield and Camp; Marston Moretaine South (Marston Vale);

and Tempsford South and Tempsford Airfield are the only sites that are expected to have a minor

positive effect in relation to the second element of SA objective 11. While these sites contain mostly

greenfield land, all have a history of uses which could result in land contamination. Development at

these locations could therefore help promote the remediation of contaminated land in Central

Bedfordshire. Development at the Henlow Airfield and Camp site would also likely result in the reuse of

some previously developed land. This again is not correct. The entirety of the 81ha that is proposed to

be redeveloped at RAF Henlow if previously developed and the redevelopment of 81ha of previously

developed land must, on any sensible analysis, give rise to a significant positive effect under SA

objective 11;

e) at paragraph 5.48 the SA states that: Henlow Airfield and Camp; Luton North Options 1-3; Marston

Moretaine North (Marston Thrift); Marston Moretaine South (Marston Vale); Tempsford South and

Tempsford Airfield; Wixams South; Houghton Regis North; and North and North East Sandy are also

expected to have mixed effects in relation to this SA objective [biodiversity and geodiversity]. We have

found no evidence to suggest that the redevelopment of RAF Henlow will have anything other than

positive effects in terms of biodiversity and geodiversity and have supplied ecological assessments of

the site with previous representations;

f) at paragraph 5.57, the SA states: Only three sites (Biggleswade East Phase 2; Henlow Airfield and Camp;

and Tempsford South and Tempsford Airfield) contain designated heritage assets. Development at

these site options is considered to have potential for particular harm on these heritage assets or their

respective settings. Therefore, a significant negative effect on this objective is expected. There is again

no evidence to support this conclusion. RAF Henlow does indeed contain designated heritage assets

but they occupy a small part of a large site and it is perfectly possibly to redevelop the site in a manner

that does not cause harm either to the buildings themselves, or their settings. Moreover, the

redevelopment of RAF Henlow is the primary, if not the only means, by which these important assets

are likely to be brought back into use. As a consequence, rather than expect a significant negative effect

in respect of SA objective 14, the Council should be assuming a positive or significant positive effect in

accordance with our previous submissions;

10

g) at paragraph 5.63 of the SA it states: Henlow Airfield and Camp and Houghton Regis North also have

three significant effects, but these each have three significant positive effects. As a result these two

options perform in the middle of all the options, along with Marston Moretaine North (Marston Thrift)

and Biggleswade East Phase 2. Scored correctly, RAF Henlow would be amongst the top performing

sites in the SA.

We consider it important that the above errors are corrected before the SA is finalised.

We trust that you will find this additional information helpful but if you need anything further from us,

please do not hesitate to ask.

Yours sincerely,

Tim Byrne Director – Planning, Development and Heritage For and on Behalf of JLL Cc: Planning Inspectors: Matthew Birkinshaw and Helen Hockenhull

Appendix One



www.jll.co.uk

1

Louise St John Howe

Programme Officer

PO Services

PO Box 10965

Sudbury

Suffolk CO10 3BF

Direct line

Email

Via Email

15th January 2021

Dear Ms St John Howe,

Examination of the Central Bedfordshire Local Plan 2015 – 2035

RAF Henlow

JLL acts for Defence Infrastructure Organisation (“DIO”) in respect of RAF Henlow and we are writing to draw

the Inspectors’ attention to two important evidential matters. The first concerns Policy EMP5 of the Local

Plan and the debate that was had about the possibility of RAF Henlow being covered by this Policy in the

event that Policy SE4 is deleted from the Local Plan. The second, concerns the implications for the MBDA

facility of traffic movements on the A600.

Policy EMP5

CBC and DIO agree that RAF Henlow should be referenced within Policy EMP5 in the event that the Inspectors

agree with the Council that Policy SE4 should be deleted from the Local Plan. As instructed by the Inspectors

during the EiP Hearing Session on 11th December 2020, DIO and CBC have considered how Policy EMP5 and

its supporting text would need to be modified in this event and have reached a degree of agreement.

However, the Parties disagree on whether the Policy itself would need to be modified and are also not

entirely in agreement on how the supporting text should be drafted.

The Modifications that CBC and DIO each propose are set out in a Statement of Common Ground (“SoCG”)

dated 15th January 2021 and is being issued by CBC. CBC have preferred not to include within the SoCG,

DIO’s explanation for the Modifications proposed by DIO. However, DIO considers it important that an

explanation is provided and so this is set out below.



www.jll.co.uk

2

The Supporting Text

DIO considers that RAF Henlow should not be referenced in paragraph 12.10.1 because:

a) this paragraph states that: “Central Bedfordshire is notable for the presence of a number of significant

employment facilities…”. RAF Henlow is not an employment facility; it is a military facility, a Sui Generis

use;

b) the paragraph states that: “These sites have the potential to provide additional jobs, which would help

to meet the employment objectives and aspirations of the Plan”. There is no prospect of a

redevelopment of RAF Henlow providing ‘additional’ jobs over and above the number maintained by the

MoD and CBC has stated to the Inspectors that the redevelopment of RAF Henlow, with either housing or

employment development, is not needed to help meet the objectives of the Plan; and

c) paragraphs 12.10.2 and 12.10.3 (which reference CBC expectations for the sites listed in paragraph

12.10.1) are all about economic or employment related development. Whilst DIO expects there to be

some employment development at RAF Henlow, the market will not support a major employment

development here (hence CBC’s proposed deletion of policy SE4) and, in any event, the greater need is

for housing and so RAF Henlow will be redeveloped primarily with new homes.

Accordingly, it is necessary for RAF Henlow to be addressed in a standalone paragraph in the supporting text

which appears immediately after paragraph 12.10.3. DIO has agreed with CBC that this will be done by the

new paragraph 12.10.4, and it is agreed that this will refer to the site being developed for non-military uses.

That paragraph, as agreed, is not prescriptive of the nature of the future uses of the site. Reference to RAF

Henlow in paragraph 12.10.1 would therefore create confusion, and even contradiction, about how the site is

to be treated and what is its future use may be.

The reference in the new paragraph to the airfield must reflect the up to date position and provide the

necessary clarity. The airfield is no longer used for either military or civilian flying (the operational and

occupational leases granted to Henlow Flying Club have been terminated) and flying will not resume. It is

important that this is reflected in the Local Plan for the benefit of all interested parties.

The Policy

DIO is firmly of the view that additional words need to be inserted into the Policy which make it clear that it

allows for the redevelopment of RAF Henlow with alternative (non-military) uses. As currently drafted, the

Policy only provides for the expansion, infilling or redevelopment of significant facilities in the countryside or

Green Belt in circumstances where the proposed development relates to the existing use. The existing,



www.jll.co.uk

3

military use of RAF Henlow is being wound down and will cease completely by 2023. There is no prospect of a

military use being re-instigated, or a use that is ‘related to’ the current military use being introduced post-

2023. Accordingly, unless the words ‘relates to that use’ are caveated for RAF Henlow, the Policy will not

allow for its redevelopment with non-military uses as required.

CBC asserted on 11th December that RAF Henlow currently contains residential and employment uses and

so its future redevelopment with housing and employment uses would be ‘related to the existing use’ and

allowed by EMP5 as submitted. It has since indicated that it wants future uses to relate to ‘existing uses’. This

is incoherent, because the current use of the military base is sui generis. It is not at all like a site containing

market and affordable housing and traditional employment uses falling within Use Classes E, B2 and B8. It is

therefore unclear what limitation this would impose. It also makes no sense in planning terms because,

despite being unclear, it could be used to argue for constraints on the future development of particular parts

of the site on the basis of the historical accident of how the MoD has used it, without regard to whether

development of that kind or in that particular location is viable or beneficial. Without absolute clarity on

what Policy EMP5 does and does not allow for as regards RAF Henlow, there is an unacceptable risk of the

Policy being misinterpreted or misapplied in the future.

DIO has given very careful consideration to how the Policy should be amended and it is satisfied that its

proposed Modification:

a) is the minimum required to render the Policy justified and effective (and, therefore, sound); and

b) would have no impact on the way in which the Policy applies to the other sites that are to be listed in the

opening paragraph of the Policy.

DIO consider it important to note that the principle here has been agreed, because CBC has agreed to

supporting text (paragraph 12.10.4) which explicitly states that RAF Henlow will be developed with

alternative, non-military uses. Accordingly, DIO’s proposed addition to policy EMP5 does not reflect any

difference of substance. However, it is not appropriate for such a fundamentally important clarification to be

addressed only in the supporting text. It is the Policy against which future planning applications will be

considered and therefore the Policy must provide clarity and be consistent with the supporting text. A

mismatch between the supporting text and the policy will only create uncertainty and reduce the Policy’s

effectiveness in achieving the agreed intent that RAF Henlow should be developed for non-military uses.

The A600 Issue

The Inspectors will recall that the Council has invited them to approach the A600 issue on the basis that, if

the 10,000 vehicle per day trip threshold were to be exceeded, this would mean that MBDA would have to

cease to operate. However, this is not correct. The 10,000 vehicle issue could be addressed by relocating



www.jll.co.uk

4

MBDA’s processing facility to a position further away from the A600. The Council will be aware that it has

already granted planning permission for this development.

DIO and Homes England will continue to work with the Council and MBDA on the masterplanning of RAF

Henlow, and the A600 issue, but the A600 issue is not one that can be used to justify the deletion Policy SE4.

We trust that you will find this additional information helpful but if you need anything further from us, please

do not hesitate to ask.

Yours sincerely

Tim Byrne

Director – Planning, Development and Heritage

For and on Behalf of JLL

Cc: Planning Inspectors: Matthew Birkinshaw and Helen Hockenhull

Appendix Two

TECHNICAL NOTE

J:\49390 - RAF Henlow Review\Reports\Examination Dec 2020\49390 RAF Henlow Review - Transport Note for EiP Final.docx Page 1 of 5

Job Name: RAF Henlow Review

Job No: 49390

Note No: TN001

Date: 13 November 2020

Prepared By: Marc Rennie

Subject: Potential vehicle trip generation

1. Introduction

On behalf of the Defence Infrastructure Organisation (DIO) and Homes England, Stantec UK Ltd has prepared this Technical Note as a supporting document to the EiP Hearing Statement pertaining to the allocation of the RAF Henlow site in the Central Bedfordshire Local Plan 2015-2035 for 7.5ha employment and 1,000 homes.

We prepared a report on transport and movement associated with the development proposals for the previous EiP session, entitled Transport & Movement Report – Rev B (March 2019), and this was appended to the previous Matter 6 Hearing Statement. This Technical Note adds to the previous evidence and should be read alongside it.

2. Vehicle trip generation

Methodology

Central Bedfordshire Council has suggested that the RAF Henlow allocation should be deleted from the draft Plan and, moreover, has stated that they are concerned about the possible highway impacts of development at the RAF Henlow site. In seeking to understand why the Council felt that this statement was justified, we have considered the relative impacts of the original allocation for high-tech employment development proposed at RAF Henlow by the Council themselves, and the predominantly residential-led development proposed by the DIO and Homes England.

We have undertaken a ‘first principles approach’ to forecasting the potential vehicle trip generation in the same way that would be undertaken for a Transport Assessment and based on data from the TRICS database system. The TRICS database system enables the user to establish multi-modal trip rates appropriate to the type, scale and location of a proposed development, from which the trip generation of a proposed development can then be established.

It is important to note that the approach taken is simply to compare the relative impacts of the Council’s original proposals for the RAF Henlow site and the DIO / Homes England proposals. Hence, it does not consider vehicle trips generated by committed developments in the vicinity of the site, i.e. developments that are consented or allocated where there is a reasonable degree of certainty that they will proceed within the next 3 years. Neither does it consider vehicle trips generated by sites in the Local Plan that will have been included in the CBLTM.

Furthermore, there are highway mitigation schemes associated with Local Plan proposals which will likely result in changes to traffic flows across the network, with some roads experiencing increased traffic flows and the traffic flows on other roads likely to reduce.

TECHNICAL NOTE


Given that a variety of housing types, and sizes, are necessary to meet the needs of the housing market, it is considered that the most appropriate category in TRICS from which to derive vehicle trip rates for a residential development, at this stage, is the Mixed Private/Affordable Housing sub land use category (use class C3). The Mixed Private/Affordable Housing sub land use category covers housing developments where fewer than 75% of units are privately owned and fewer than 75% of units are non-privately owned. Non-privately owned units may be council rented or housing association rented.

As the RAF Henlow site is expected to deliver an element of employment use, trip rates have also been extracted from TRICS for the 02/B land use category (Employment/Business Park).

DIO / Homes England proposals

The DIO and Homes England are seeking an allocation in the Central Bedfordshire Local Plan 2015-2035 for a development of 7.5ha employment and 1,000 homes at the RAF Henlow site.

It is estimated that 40% of the 7.5ha (or 75,000m²) of employment land will comprise actual trip generating development and, therefore, a quantum of 30,000m² has been assessed. The remaining 60% will likely comprise infrastructure, such as access roads, parking and open space.

Based on our methodology for forecasting trips, Table 2.1 summarises the forecast daily vehicle trip rates and trip generation for the quantum of residential and employment land uses proposed.

Table 2.1 – Forecast daily vehicle trip rates and trip generation: DIO / Homes England proposals

DIO / Homes England proposed land uses

Forecast daily vehicle trips rates and trip generation

Arrivals Departures Two-way

Trip Rate Vehicle Trips



Residential (1,000 homes)

1.757 1,757 1.808 1,808 3.565 3,565

Employment (30,000m2)

4.124 1,237 4.049 1,215 8.173 2,452

Residential + Employment

- 2,994 - 3,023 - 6,017

Table 2.1 shows that a development of 1,000 homes and 30,000m² employment can be forecast to generate 6,017 vehicle trips per day.

Table 2.2 summarises the forecast AM peak hour (8-9am) vehicle trip rates and trip generation for the quantum of residential and employment land uses proposed.

Table 2.2 – Forecast AM peak hour (8-9am) vehicle trip rates and trip generation: DIO / Homes England proposals


Forecast AM peak hour (8-9am) vehicle trips rates and trip generation






0.106 106 0.320 320 0.426 426


0.854 256 0.229 69 1.083 325


- 362 - 389 - 751

Table 2.2 shows that a development of 1,000 homes and 30,000m² employment can be forecast to generate 751 vehicle trips during the AM peak hour.

Table 2.3 summarises the forecast PM peak hour (5-6pm) vehicle trip rates and trip generation for the quantum of residential and employment land uses proposed.

TECHNICAL NOTE


Table 2.3 – Forecast PM peak hour (5-6pm) vehicle trip rates and trip generation: DIO / Homes England proposals


Forecast PM peak hour (5-6pm) vehicle trips rates and trip generation






0.287 287 0.124 124 0.411 411


0.115 35 0.677 203 0.792 238


- 322 - 327 - 649

Table 2.3 shows that a development of 1,000 homes and 30,000m² employment can be forecast to generate 649 vehicle trips during the PM peak hour.

Central Bedfordshire Council proposals

Policy SE4 of the submission draft of the Central Bedfordshire Local Plan 2015-2035 allocates RAF Henlow for a mixed-use development that will:

1. provide for up to 130 hectares of developable land comprising:

up to 85 hectares of specialist high-technology, science, research and development uses to the north of the A659 Hitchin Road; and

a mixed use visitor-economy and residential scheme of up to 45 hectares (approximately 500 dwellings in total) to the south of the A659 Hitchin Road.

2. deliver necessary improvements to the road network maintaining suitable access to the site; and

3. provide opportunities for sustainable transport links to be determined through a Transport Assessment.

Adopting the same approach to assessing the DIO / Homes England proposals, it is estimated that 40% of the 85ha (or 850,000m²) of employment land will comprise actual trip generating development and, therefore, a quantum of 340,000m² has been assessed. The remaining 60% will likely comprise infrastructure, such as access roads, parking and open space.

Based on our methodology for forecasting trips, Table 2.4 summarises the forecast daily vehicle trip rates and trip generation for the quantum of residential and employment land uses proposed.

Table 2.4 – Forecast daily vehicle trip rates and trip generation: Council proposals

Central Bedfordshire Council proposed land uses

Forecast daily vehicle trips rates and trip generation





Residential (500 dwellings)

1.757 879 1.808 904 3.565 1,783


4.124 14,022 4.049 13,767 8.173 27,788


- 14,900 - 14,671 - 29,571

Table 2.4 shows that a development of 500 residential dwellings and 340,000m² employment can be forecast to generate 29,571 vehicle trips per day.

TECHNICAL NOTE


Table 2.5 summarises the forecast AM peak hour (8-9am) vehicle trip rates and trip generation for the quantum of residential and employment land uses proposed.

Table 2.5 – Forecast AM peak hour (8-9am) vehicle trip rates and trip generation: Council proposals


Forecast AM peak hour (8-9am) vehicle trips rates and trip generation






0.106 53 0.320 160 0.426 213


0.854 2,904 0.229 779 1.083 3,682


- 2,957 - 939 - 3,895

Table 2.5 shows that a development of 500 residential dwellings and 340,000m² employment can be forecast to generate 3,895 vehicle trips during the AM peak hour.

Table 2.6 summarises the forecast PM peak hour (5-6pm) vehicle trip rates and trip generation for the quantum of residential and employment land uses proposed.

Table 2.6 – Forecast PM peak hour (5-6pm) vehicle trip rates and trip generation: Council proposals


Forecast PM peak hour (5-6pm) vehicle trips rates and trip generation






0.287 144 0.124 62 0.411 206


0.115 391 0.677 2,302 0.792 2,693


- 535 - 2,364 - 2,898

Table 2.6 shows that a development of 500 residential dwellings and 340,000m² employment can be forecast to generate 2,898 vehicle trips during the PM peak hour.

Comparison of vehicle trip generation

Comparison of the forecast vehicle trip generation of the DIO / Homes England proposals with those of Policy SE4 of the submission draft of the Central Bedfordshire Local Plan 2015-2035 are presented in Table 2.7.

Table 2.7 – Comparison of forecast vehicle trip generation

Proposals Forecast vehicle trip generation

Daily AM peak hour (8-9am) PM peak hour (5-6pm)

DIO / HE proposals (1,000 homes and 7.5ha employment)

6,017 751 649

CBC proposals (500 homes and 85ha employment)

29,571 3,895 2,898

Difference 23,554 3,144 2,249

It is clear from Table 2.7 that the DIO / Homes England proposals would generate a much lower volume of vehicle trips than that of Policy SE4 of the submission draft of the Central Bedfordshire Local Plan 2015-2035.

TECHNICAL NOTE


It should be noted that the forecast vehicle trip generation presented in Table 2.7 for both proposals do not consider three important factors which will likely reduce the overall number of vehicle trips generated, namely:

Netting off of trips – the potential vehicle trip generation of both proposals does not consider the 'netting off' of trips that are currently generated by the RAF Henlow site and, therefore, are currently on the local road network. This is a standard approach that would be adopted in a detailed assessment to determine the potential impact of development traffic on the local road network

Internalisation of trips – given the range of uses proposed, it can be expected that some trips will be made between uses (i.e. they will stay internal to the site) and will not access the external highway network, and

Successful travel planning measures – a Travel Plan will be required as part of a planning application for development at RAF Henlow and will help facilitate modal shift away from the private car to more sustainable modes of travel, such as walking, cycling and public transport. Incentives such as free bus passes and cycle vouchers could be offered, for example, and on-site infrastructure can be designed and located to enable residents to travel sustainably.

There are clearly factors that will affect the overall number of external trips to the RAF Henlow site, some of these will affect any type of proposal, whereas others will be beneficial in the context of mixed-use development.

3. Summary

This Technical Note has considered the potential vehicle trip generation of the proposed RAF Henlow site allocation and the land uses originally proposed by Central Bedfordshire Council in Policy SE4 of the submission draft of the Central Bedfordshire Local Plan 2015-2035.

It was clear that, in all of the assessment and analysis that the Council undertook to provide its evidence base for the Local Plan, it considered that it had established that the level of vehicle trip generation arising from the Policy SE4 proposals could be accommodated on the local highway network in a cost effective and deliverable way.

We have undertaken a first principles approach to forecasting the potential vehicle trip generation, in the same way as would be undertaken for a Transport Assessment, based on data from the TRICS database system.

This assessment has established that the Policy SE4 allocation of the RAF Henlow site in the submission draft of the Central Bedfordshire Local Plan 2015-2035, as proposed by Central Bedfordshire Council, for specialist high-technology, science, research and development uses, and some ancillary housing development, would be forecast to generate significantly more vehicle trips than the proposals currently being put forward by the DIO / Homes England.

Therefore, it can be concluded that, as the Council’s evidence showed the proposals contained in Policy SE4 could be accommodated on the highway network, then it follows that the DIO / Homes England proposals must also be considered acceptable by comparison.

There is, therefore, no grounds to delete the allocation from the Local Plan on highways grounds, and we would argue that the very much lower levels of vehicle trip generation emanating from the DIO / Homes England proposals suggest that this predominantly housing-led development would make an important contribution to housing delivery in the District during this plan period.

Appendix Three

Henlow Airfield

Stondon

Lower

Camp

Golf Couse

Playing Field

Henlo

w In

du

strial E

state

Oldfield Farm

Golf Course

Lindas Grove

Nursery

The Bird in

Airfield

(Greyhound)

Paul's

Park

Pit

Middlefield Farm

Su

sa

ns G

rove

St Michael's Church

Water

Depot

Transport

Grass Runway

Westfield Farm

Cherry

Tre

es

Moat

Silo

Pleasant

St A

nd

rew

's Chu

rch

Sewage Works

Works

Letter

Hal

l

Old Ramerick

Lower School Silos

Pavilion

Regency Court

Industrial

El

Old

Station

Old Manor Farm

Shelter

Sluice

Butts

Foot Bridge

Willo

w T

rees C

ara

van S

ite

Park Homes

Tel Ex

El Sub Sta

Hoo Farm

Dra

in

Tennis Courts

Dis

mantle

d R

ly

Issues

Poplars

Lily

Walk

Holwellbury Farm

Path (um)

Dis

mantle

d R

ailw

ay

Sinks

Courts

Business Park

The

Car Park

Tra

ck

Railw

ay

Ramerick Cottages

Surgery

Post

Lay-by

The Carriage House

Sta

Playground

Sub Sta

Ppg Sta

School

Co Const B

dy

Club

Path

Sludge Beds

ED

& C

o C

onst B

dy

Park Farm

Def

Stone

Gas Governor

Stanpit House

Chapel

Wind Sock

The Lodge

Grass

ED

& W

ard

Bdy

Mast

1.2

2m

TB

The Crown

Tanks

Avon

Ch

ase

The Hollow

Hunters Meet

The Chestnuts

Cedar Cottage

Ward

Bdy

Sock

Tank

52.0m

39.6m

42.6m

47.6m

48.4m

48.8m

50.0m

50.2m

61.9m

60.5m

39.0m

56.3m

51.6m

58.9m

50.9m

51.0m

56.6m

60.0m

50.6

m38.4m

63.8m

63.4m

54.3m

54.0m

51.9m

51.5m

49.1m

39.3m

48.9m

46.5m

47.2m

Garage

39.55m

(PH)

1.2

2m

RH

ED

Bdy

BM 63.52m

BM

60.2

7m

BM 47.71m

BM 51.09m

BM 57.00m

BM 49.26m

BM 55.06m

BM

51.9

0m

BM

38.6

7m

BM 48.72m

BM 41.57m

A 600

A 507

Wren Park

The Elms

A 6

001

Pump House

House

ED &

Pond

The Chase

BR

ITTAIN

S R

ISE

CTk

ETL

LB

TCBs

5 to

6

7 to

9

2 to

4

to

MID

DLE

FIE

LD

LA

NE

(TR

AC

K)

Coach

JU

BIL

EE

TH

E S

IDIN

GS

HILLSID

E RO

AD

FS

FB

FL

IGH

T

Pump

BLUEBELL DRIVE

HITCHIN R

OAD

ASTRAL CL

CF

TCB

SIGNAL CLOSE

Gas

STATION

CLO

SE

TH

E R

AILW

AY

MO

RR

IS C

L

TH

E O

VA

L

OLDFIELD FARM ROAD

40 to 4522 to

30

34 to 36

PEAR TREE CLOSE

STATIO

N R

OAD

DO

VE

HO

US

E D

RIV

E

WH

ITT

LE

THREE STAR CARAVAN PARK

SP

RE

CK

LE

Y C

L

PLUM TREE ROAD

FAKESWELL LAN

E

BIRCH GROVE

CS

TE

DD

ER

AV

E

CL

MIDLAND W

AY

ALLT

ON

RO

AD

CE

NT

RA

L A

VE

NU

E

THE CRESCENT

ARLESEY ROAD

OW

EN

JO

NE

S C

LO

SE

117 to 123

290 to 298

LONG CLOSE

BU

RN

ET

T A

VE

NU

E

WHITWORTH JONES AVENUE

CH

ER

RY

TR

EE

S

CHESTNUT AVENUE

THE GARDENS

SOUTHERN AVE

POLLARDS WAY

NE

NE

RO

AD

CR

CO

CS

PO

MY

RT

LE

GA

RD

EN

S

AVON ROAD

BO

RT

ON

AV

EN

UE

SOUTHERN AVENUE

APPLECROFT

SHANNON CLO

SE

EN

DE

AV

OU

R C

LO

SE

NORTHERN AVENUE

WE

ST

ER

N A

VE

NU

E

BE

DFO

RD

RO

AD

CROSSWAYS CL

OLY

MP

US

RO

AD

WE

ED

ON

CL

EA

ST

ER

N

CLO

SE

DA

WS

ON

CLO

SE

DE

RW

EN

T R

OA

D

NEW

RO

AD

c

17 19

OR

CH

AR

D W

AY

Drain

Grass Runway

TCB

Drain

Car Park

Drain

Slu

dge

Be

ds

ED & Ward Bdy

Path (um)

Pond

Pond

El Sub S

ta

Drain

Tra

ck

Dra

in

El Sub Sta

Track

Depot

Def

ED

& W

ard

Bd

y

A 507

Track

Track

Track

Stone

PLU

M T

RE

E R

OA

D

Grass Runway

El S

ub S

ta

Def

Gra

ss R

unw

ay

Path (um)

Dra

in

CS

Drain

CR

The

Tra

ck

AVON ROAD

Dra

in

Path (um

)

Playing Field

Def

CHESTNUT AVENUE

Silo

ED

& W

ard

Bdy

BE

DFO

RD

RO

AD

CR

A 507

Drain

CTk

DO

VE

HO

US

E D

RIV

E

Tank

Dra

in

CS

Dra

in

CR

Dra

in

A 6

00

ORCHARD WAY

Drain

Camp

Dra

in

CR

Tra

ck

Tra

ck

Drain

Drain

ETL

Path

(um

)

Pa

th (u

m)

Ramerick Cottages

Silo

Pond

Pond

Drain

Track

Tra

ck

Dra

in

ED & Ward Bdy

Tank

Pa

th

Moat

50.0m

Water

CTk

Track

El Sub Sta

Henlow Airfield

CTk

MID

DL

EF

IELD

LA

NE

(TR

AC

K)

Shelter

Drain

Path

(um

)

Tra

ck

Dra

in

LB

CR

Water

NORTHERN AVENUE

Pond

Track

Water

Tank

Pond

Track

Issues

Dra

in

Drain

Drain

Dra

in

ED

& W

ard

Bdy

Co Const Bdy

Drain

Tra

ck

ED

& W

ard Bdy

Tra

ck

Pavilion

Def

Pump House

A 6

001

Dra

in

HIT

CH

IN R

OA

D

Track

HIT

CH

IN R

OA

D

Nursery

Def

Drain

Drain

ED & Co Const Bdy

Drain

Pond

ED & Co Const Bdy

ED & Ward Bdy

A 600

A 6

00

A 507

ED

& W

ard

Bdy

Playing Field

CR

BU

RN

ET

T A

VE

NU

E

El Sub Sta

Def

Track

Def

Drain

Pond

Henlow Airfield

Drain

A 6

00

Playground

Track

Dra

in

BE

DF

OR

D R

OA

D

CR

CR

61.9m

El Sub Sta

Drain

Drain

CS

Drain

A 6

00

Drain

Grass Runw

ay

LB

Def

Tra

ck

Drain

Tra

ck

Drain

Gra

ss R

unw

ay

ED

Bdy

Pond

Track

Track

Track

TH

E O

VA

L

Dra

in

1.2

2m

TB

Golf Course

Drain

El S

ub S

ta

Playing Field

STA

TIO

N R

OA

D

El S

ub S

ta

LB

FBED

& W

ard Bdy

CS

TCB

Pla

ygro

und

Tra

ck

STATION ROAD

Dism

antled Railw

ay

Drain

Tra

ck

Path (u

m)

Tra

ck

Dra

in

CF

Playground

Drain

LB

Golf Course

El Sub Sta

Dra

in

Sub Sta

CS

51.6m

Track

Track

48.4m

OLDFIELD FARM ROAD

Drain

ED & Ward Bdy

ED & Ward Bdy

CTk

Dra

in

Golf Course

Henlow Airfield

HIT

CH

IN R

OAD

Drain

TCB

TCB

Drain

Water

El Sub Sta

El S

ub S

ta

Dism

antled Railw

ay

Tra

ck

Path

(um

)

Tra

ck

LB

Grass Runw

ay

Drain

Issues

Lay-by

Tra

ck

Pond

Drain

Dra

in

Def

Drain

Track

A 6

00

El Sub Sta

CS

Stadium

St

Hand Hotel

Wren

Ramerick

(disused)

Church

Mount

(Rifle Range)

Crown

Farm

Dism

antled

Tennis

Cottages

Estate

Derwent Lower

Museum

Henlow

60.6m

38.9m

Pumping

Peckworth

BM

55.

24m

Wind

Box

House

Karen

Sub

Bungalow

Bungalow

Runway

TCBs

Gov

PA

RK

FA

RM

CLO

SE

CL

TE

DD

ER

AV

EN

UE

TEDDER AVENUE

RY

LE

Y

PO

RO

SE

MA

RY

LA

NE

PA

TH

DE

RW

EN

T R

D

AV

EN

UE

BM

MEADOW WALK

262-276

ORCHARD

CO

OP

ER

20c

17c

30c

ME

AD

OW

SW

EET

147c

168c

WAY

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

1

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

4

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

2

7

7

7

7

7

7

7

7

7

7

7

7

7

7

7

7

7

7

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

8

3

3

3

3

3

33

3

3

3

3

3

3

3

3

3

3

6

6

6

6

6

6

6

6

6

6

6

6

6

6

6

66

6

9

9

9

9

9

9

9

9

9

9

9

9

9

9

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

5

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

10

26

26

26

26

26

26

26

26

26

26

13

13

13

13

13

13

13

13

13

13

89

72

72

84

20

20

20

20

20

20

20

2020

39

39

39

31

31

31

31

31

31

31

31

31

31

31

31

31

31

31

66

66

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

14

22

22

22

22

22

22

22

22

22

22

22

22

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

11

24

24

24

24

24

24

24

24

24

12

12

12

12

12

12

12

12

12

12

12

12

12

12

12

12

12

12

61

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

15

42

42

42

42

16

16

16

16

16

16

16

25

25

25

25

25

25

25

25

25

25

25

25

45

45

45

27

27

27

27

27

27

30

30

30

30

30

30

33

33

33

33

35

35

35

35

35

35

35

35

40

40

40

40

40

40

81

23

23

23

23

23

23

23

23

30a

85

85

192

157

18

18

18

1818

18

1818

18

18

18

18

18

18

178

174

111

111

224

41

41

41

41

21

21

21

21

21

21

21

21

58

58

32

32

32

274a

133

64

46

46

46

151

18

5

54

54

62

62

19

19

19

19

19

19

19

19

19

19

29

29

29

143

114

114

242

117

48

48

48

156

43

43

43

43

43

43

43

129

129

37

37

37

37

37

149

112

23b

195

13

7

18

3

22a

99

125

125

11a

21b

147

6a

95

95

63

63

17

17

17

17

17

17

57

57

167b

30d

100

226

115

193

252

144

18a18b

73

73

177a

12

7

124

124

170

151a

28

28

28

9a

152

76

71

70

228

98

182

194

168d

67

135

116

131

52

52

52

38

38

38

38

258

21a

105

166

153

206

206

169

91

20a

20a

193a

139

249

197

190

7a

233

34

34

34

34

2d

60

60

60

59

59

55

55

44

53

101

101

36a

167

22b

181

71a

77a

159

197a

232

83

77

82

220

d

225

36

36

146

147a

168a

79

79

141a

141b

147b

17a

204

65

65

56

254

136

136

104

134

167a

112a

4a

120

201

107

168b

141

187

96

168

47

47

90

50

5a

69

2a

JOH

N H

OW

LA

ND

CL

JOHN HOWLAND CLOSE

Windgrove

Hare

park

61.3m

CR

Dra

in

Ward Bdy

Drain

El

Ward Bdy

A 6

001

Path (um)

Path (um)

Dra

in

THE CRESCENT

CLO

SE

OLDFIELD FARM ROAD

Old

A 6

00

The

BE

DF

OR

D R

OA

D

CR

Pond

A 6

00

(PH)

House

A 507

ED

& W

ard

Bdy

ED

& W

ard

Bdy

HIT

CH

IN R

OA

D

ED

& C

o C

on

st B

dy

OR

CH

AR

D W

AY

Drain

ED

Bdy

The

CR

BE

DF

OR

D R

OA

D

Ward Bdy

Stondon

El

ED &

515400

515400

515600

515600

515800

515800

516000

516000

516200

516200

516400

516400

516600

516600

516800

516800

517000

517000

517200

517200

517400

517400

517600

517600

517800

517800

2348

00

2348

00

2350

00

2350

00

2352

00

2352

00

2354

00

2354

00

2356

00

2356

00

2358

00

2358

00

2360

00

2360

00

2362

00

2362

00

2364

00

2364

00

2366

00

2366

00

2368

00

2368

00

2370

00

2370

00

2372

00

2372

00

2374

00

2374

00

2376

00

2376

00

2378

00

2378

00

2380

00

2380

00

RAF Henlow

MOD Boundary Plan

SCALE

Bedfordshire

GRID REF: TL 165 357

§The scale ratio stated is accurate when reproduced at size stated by the Geographic Information Unit,Waterbeach. Any other reproduction by conventional or electronic means.e.g. printing from a PDF,may alter the scale of the map. Please check the dimensions of the grid to confirm any change inscale before taking measurements.

This map is © Copyright DE 2005 and may not be copied or reproduced in any form, nor added to or otherwisealtered in any way without the express permission of the Geographic Information Unit, DE Waterbeach

Due to the Ordnance Survey’s Positional Accuracy Improvement (PAI) Programme, some data on this mapmay be misaligned with its related OS feature. The originating GI office will be able to advise you of thePAI data conversion programme, its impact on this map and any further information you may require. MOD, DE OPERATIONS NORTH

STIRLING HOUSE, DENNY END ROAD,WATERBEACH, CAMBS. CB25 9QETel : 01223 255415This map is reproduced from Ordnance Survey material with the permission of Ordnance Survey on behalf of

the Controller of Her Majesty's Stationery Office © Crown Copyright. Unauthorised reproduction infringes CrownCopyright and may lead to prosecution or civil proceedings. Defence Estates Licence No. 10003250, 2008.

SNProduced By : 01/04/08Plan Dated : mod_bnd_A1Plan Reference:

-----Revised :

DEFENCE ESTATESDelivering Estate Solutions to Defence Needs

1:5,000 @ A1

MOD Freehold Boundary

of 93

PM34: EMP5 – RAF Henlow

EMP5 – RAF Henlow, Henlow Addition of EMP5 site to Policy maps

As submitted

Proposed

Modification

TIM.BYRNE

Polygonal Line

jones lang lasalle ltd head of strategic growth central

Documents