Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208279

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

This submission is made by Turley on behalf of Imperial War Museum (IWM). IWM is in broad support of the Plan as a whole. The Area of Major Change (AMC) policy is broadly supported. IWM welcome the continued recognition of IWM Duxford as a unique museum of international historic importance with a range of complimentary uses operating at the airfield site. The supporting text supporting further development opportunities is welcome. The draft policy requires the submission of a site-wide masterplan and IWM strongly supports a masterplanning approach and regards this as fundamental to managing a successful future for the airfield site.

Comment

Representation ID: 208280

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

This draft policy requires major development to provide 20% net gain on site or if not possible then as off-site credits. This is double the mandatory requirement of 10%. This increase in biodiversity net gain required for all major development is a significant additional cost which can impact viability and can compromise designs. It is requested that the Councils consider the policy requirement remain at the mandatory threshold of 10%.

Comment

Representation ID: 208281

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

Point 4 of the policy recognises there are different types of flying activities which have different noise impacts and provides examples.IWM in partnership with Gonville and Caius College and Henry Boot Development (HBD) is bringing forward proposals, led by HBD for an advanced aviation and related technologies hub at IWM Duxford. This would include for research and development, prototype testing and manufacture for low and zero carbon advanced air mobility technologies and supporting operations. The environmental impacts compared to conventional aircraft will be less. This being the case it should be recognised in the policy and supporting text. It is suggested this be amended to read as set out in the full representation.

Comment

Representation ID: 208282

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

The text should recognise that IWM Duxford unlike Wimpole Hall or other visitor attractions has a specific designation as an Area of Major Change under policy S/AMC/IWM: Imperial War Museum Duxford. This acknowledges and establishes support in principle for appropriate development at IWM Duxford as set out in the AMC policy. Policy J/VA refers to small scale additional development for new facilities. The AMC designation for IWM Duxford allows for development of considerably greater scale than this. It is suggested this be amended to read as set out in the full representation.

Comment

Representation ID: 208283

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

The development of Whittlesford Parkway as a travel hub together with employment and housing is wholly supported by IWM. The introduction of a bus turning circle is vital and a fundamental part of making Whittlesford station an effective travel hub to enable any significant mode shift to sustainable travel for IWM visitors and staff, being the nearest rail station.

Comment

Representation ID: 208284

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

This policy repeats an issue with Policy 60 of the 2018 Cambridge Local Plan policy by continuing to imply that any building which breaks the skyline is unacceptable. Even modest additions at high level can break the skyline – it depends on where you are looking from. The policy would be clearer if it stated ‘developments that cause significant change to the existing skyline and / or are significantly taller….’. The policy extends into the villages and rural areas of South Cambridgeshire, so this clarity is necessary for new development at IWM Duxford – otherwise any new building or addition to the height, no matter how modest, would break the skyline from somewhere and potentially be unacceptable.

Comment

Representation ID: 208285

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

The requirement in point 2 that development proposals must ‘preserve or enhance’ and comply with the rest of strands a) to g) of this policy is not in line with statutory duty. It is similarly not in accordance with paragraphs 213 to 215 of the NPPF where in some circumstances, public benefits can outweigh harm to heritage significance.
In point 3 (a) who ‘formally’ assesses this (ie whose opinion determines if a building is considered unsound)? Similarly, how could an applicant ever demonstrate that ‘all possible measures’ have been explored in point b).
It is not clear if all of strands a), b) and c) must be met or if these are either / or situations.

Comment

Representation ID: 208286

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM fully supports the strategic commitment set out in the GCLP to positively address the issue of climate change mitigation and adaptation within the plan period. IWM consider it appropriate to propose that there are a number of unique factors that apply to our organisation and development activities that places particular challenges to our development activities and meeting the proposed sustainability policies such as viability as a charity, suitable design of buildings for exhibiting pieces.

Comment

Representation ID: 208287

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM consider that the requirements for a “standalone Sustainability Statement” for all major development, and for Sustainability Statements to accompany minor development applications are reasonable. IWM welcomes the recognition that the Sustainability Statement should be “proportionate to the scale and nature of the application”. With respect to the content of the Sustainability Statement, IWM believe that the list of content described in paragraph 2 will need to be amended to reflect the final approved policies post examination which may include the need to remove the requirement for ‘net zero carbon’ should the proposed NPPF changes be implemented.

Comment

Representation ID: 208288

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM have concerns regarding this draft Policy. While the intent of this requirement is understood, matters relating to overheating risk, ventilation and internal environmental performance are already comprehensively addressed through the Building Regulations (part O) and associated guidance. As stated above IWM have to design buildings with large open spaces and exits and entrances which present unique challenges to address such as ventilation and overheating. IWM request that the policy be amended to include the following text: Buildings of a unique nature and type (e.g. visitor attractions) may be provided additional commercial or technical flexibility.