Draft Greater Cambridge Local Plan for consultation

Comment

Representation ID: 208289

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM note that the Government is progressing the Future Buildings Standard (FBS). If changes to legislation to prevent local authorities from setting standards above Building Regulations is approved then Policy CC/ NZ will need to be significantly amended or deleted. IWM note that the space heating (15-20kWh per m2) is extremely challenging (if not impossible) for the specific type of buildings required at IWM Duxford. It is suggested this be amended to read as set out in the full representation.

Comment

Representation ID: 208290

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM have concerns with respect to CC/NZ 2&3 which prohibits the use of fossil fuels and gas. The IWM fully support the need for the decarbonisation of heating however given the unique nature of our buildings and the need to store our aircraft and military equipment under certain conditions we believe that this warrants specific flexibility. The policy text does note that certain development (e.g. heavy manufacturing or R&D) could be afforded flexibility, and we request that flexibility is also applied to visitor and tourist attractions.

Comment

Representation ID: 208291

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

In relation to Part C, the policy states that “proposals must seek to maximise opportunities to generate on-site renewable energy to enable the development, where possible, to achieve all energy demands through onsite energy generation”. IWM consider such a policy to be extremely challenging for our buildings from both a commercial and technical perspective. It is suggested this be amended to read as set out in the full representation.

Comment

Representation ID: 210576

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

It is requested that the draft policy be amended to:
2. ‘Development of the site will be masterplan that masterplan led which will enable…….’ This minor alteration of the wording covers all future development proposals in the AMC and accommodates the existing IWM Duxford masterplan and the AvTech 1 / IWM Lab masterplan currently in preparation.

Comment

Representation ID: 210594

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

Part D of draft Policy CC/NZ introduces the concept of an “Energy offset fund” to enable developers to make payments in lieu of failure to meet the energy and carbon standards. IWM are concerned that the policy does not give any detail with respect to the cost of the fund and therefore do not believe this aspect of the draft Policy is sound and in accordance with Paragraph 59 of the NPPF which requires local plan policies to be accompanied by up-to-date viability assessments.

Comment

Representation ID: 210595

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM fully support the need to improve water efficiency in new developments given the serious issue within the Greater Cambridge area with respect to water stress. In relation to criterion 2 of the policy, IWM consider that the practical and viability implications of the proposed standards should be carefully considered. In particular, the requirement for non-domestic building to obtain 5 credits for category Wat 01 (BREEAM) is a challenge given the consumption of water. IWM are committed to deploying water efficiency measures in their new development and existing building and flexibility with these targets would be welcome. It is suggested this be amended to read as set out in the full representation.

Comment

Representation ID: 210600

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

The Topic Paper presents the changes to the Policy since the previous consultation exercise, with very little change with respect to the technical requirements. IWM fully support the need for integrated water management and this has been an absolute priority at IWM Duxford. IWM repeat concerns expressed previously with respect to the application of paragraph 6 of the Policy. The policy as currently drafted risks placing an unreasonable and disproportionate evidential burden on applicants at the planning application stage. IWM consider that Policy CC/IW should be implemented flexibly, with appropriate reliance placed on the statutory duties of water companies and ongoing engagement through established mechanisms such as WRMPs and DWMPs.

Comment

Representation ID: 210603

Received: 30/01/2026

Respondent: Imperial War Museum

Agent: Turley

IWM support the intent of Policy CC/CE and welcome the flexibility built into paragraph 1 of the policy, which allows proposals to demonstrate compliance with the circular economy principles where “practical and viable” to meet all requirements in full. However, IWM have concerns regarding paragraph 5 of the policy, which introduces a requirement for the submission of a CE Statement. IWM also believe that the submission of a Sustainability Statement should be limited at outline planning application stage given that building design information is very limited at that stage. A CE statement should be reserved for detailed design stage only where it will be more meaningful in terms of information.