Greater Cambridge Local Plan: Proposed Submission

It is suggested this be amended to read as below with additional text in yellow.

The examples set out in point 4 should include: ‘advanced air mobility flying’.

With regard to the supporting text the following amendment to paragraph 10.63 is suggested:

‘Certain types of flying activity may result in a different level or type of potential impact from that caused by conventional modern aeroplanes taking part in ‘normal’ flights. For example, in the case of advanced air mobility flying where environmental impacts will be less.

Conversely some disturbance may often (but not always) be more severe’.

Representations were submitted through the Regulation 18 consultation. The need for the policy is acknowledged to manage potential environmental and amenity impacts of development associated with aviation and related uses. IWM noted that the draft policy recognised there are different types of flying activities which have different noise impacts and provided examples – point 2b. The policy now also refers to drones.

The supporting text at 10.63 states:

Certain types of flying activity may result in a different level or type of potential impact from that caused by conventional modern aeroplanes taking part in ‘normal’ flights. Such disturbance may often (but not always) be more severe.

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.

The policies within the Local Plan should not duplicate NPPF policies.

Whilst welcoming some clarifications, Imperial War Museum maintains its objection that Policy GP/HA is inconsistent with the August 2026 NPPF. The policy requires development to satisfy multiple criteria without the balanced approach provided by national policy. In particular, NPPF decision-making policy HE4 already requires heritage assets to be conserved in a manner appropriate to their significance. Given this national framework, the necessity of additional local policy requirements in GP/HA is unclear and risks duplication rather than adding material planning value.

To avoid confusion highlight the explanation provided in H.13 within the policy, or make it clear that any new building taller than the one it replaces does not automatically ‘break the skyline’ it depends on the context in which it is viewed.

At Regulation 18 Stage, Imperial War Museum commented on confusion which the phrase ‘break the skyline’ brings. Whilst the clarification is given in Appendix H (specifically H.13) is helpful -
‘Skyline refers to the outline or profile of buildings, structures, and natural features visible against the sky when viewed from a distance or from specific vantage points’
that is not our experience of how members of the public interpret the phrase. It would avoid confusion to highlight the explanation provided in H.13 within the policy, or to make it clear that any new building taller than the one it replaces does not automatically ‘break the skyline’ it depends on the context in which it is viewed.
As this policy effectively uses the old Cambridge Local Plan Policy and extends it into the villages and rural areas of South Cambridgeshire, the above clarification is even more 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.

It is requested that the text of 8.102 be amended as follows:

In South Cambridgeshire there are a number of assets which have become major tourist visitor attractions, such as the World War II airfield at Duxford which is now home to the Imperial War Museum, and Wimpole Hall which is owned by the National Trust. Facilities such as these can only be developed where the assets exist.
Imperial War Museum Duxford is treated as a special case as a museum which is a major tourist / visitor attraction, educational, commercial and aviation facility and is designated as an Area of Major Change under policy S/AMC/IWM: Imperial War Museum Duxford (AvTech 1) which provides scope for further development focused on aviation and other uses which are complementary and support the future of the museum site.

For other Tourist facilities and attractions, such as Wimpole Hall, this could include visitor and information centres, toilets, tea rooms, or picnic sites.

The policy is intended to support the districts existing attractions and assets. It is not the intention of the policy to encourage new major tourist attractions.

The policy refers to visitor attractions outside the defined development of Cambridge will be permitted only where they utilise and enhance existing assets, are appropriate for their location and acceptable in terms of need, environmental and traffic impacts.
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 (inc AvTech 1). 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.

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.

Point 2 to be replaced with:
Development must provide the statutory biodiversity net gain requirement in accordance with Schedule 7A of the Town and Country Planning Act 1990 (unless exempt from those requirements). Biodiversity net gain should be provided on-site where feasible and effective, or off-site where on-site opportunities have been demonstrated to be exhausted and this has been agreed by the Local Planning Authority. Requirements for biodiversity net gain in excess of the statutory minimum shall only apply to specific site allocations where justified and demonstrated to be deliverable.

Plan-Making Policy N1(2) of the National Planning Policy Framework (17 August 2026) states that development plans should only require biodiversity net gain in excess of the statutory requirement where this relates to specific site allocations and is fully justified and deliverable. It also states that local standards should not apply to categories of development that are exempt from the statutory biodiversity net gain regime.
As drafted, Policy BG/BG appears to impose biodiversity net gain requirements beyond the statutory framework without limiting them to specific allocations or providing the justification required by national policy. The policy therefore conflicts with the National Planning Policy Framework and fails the test of soundness that a plan must be consistent with national policy.
The policy should be amended to confirm that any biodiversity net gain requirements exceeding the statutory minimum apply only where justified through a specific site allocation policy. It should also make clear that development exempt from statutory biodiversity net gain requirements is not subject to additional local biodiversity net gain standards. Reference should also be made to the statutory biodiversity net gain framework contained in Schedule 7A of the Town and Country Planning Act 1990.
As a further point, if Policy BG/BG duplicates or materially departs from the national BNG framework, there is also an argument that it is inconsistent with the 2024 NPPF approach to avoiding duplication of national policies within development plans.

The amendment policy wording from the Reg 18 version is welcomed as it recognises that IWM Duxford already have a masterplan in place. The wording in this Reg 19 version states:
Development of the site will be masterplan led. A masterplan for development focused on aviation and other complementary uses to support the future of the museum site must align with the wider masterplan for IWM Duxford. This approach will enable development and associated infrastructure provision to be planned for and delivered in a comprehensive manner.
For clarity the IWM masterplan which has been in place for some years covers the museum and airfield. The use of term ‘wider’ could be understood to mean land outside the bounds of the IWM estate and encompassing the whole allocation.
It is suggested this be amended to:

Development within the site will be masterplan led. A masterplan for development focused on aviation and other complementary uses to support the future of the museum site must align with the masterplan for IWM Duxford museum and airfield. This approach will enable development and associated infrastructure provision to be planned for and delivered in a comprehensive manner.

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 extension of the designation to include the land as shown in Figure 87 of the draft Local Plan, is welcomed in supporting an ongoing sustainable future for IWM Duxford.
IWM in conjunction with Gonville and Caius College and selected development partner Henry Boot Development are currently progressing a scheme for an advanced aviation and related technologies hub (AvTech 1) for up to 42,500 sq m together with a new conservation and storage building (IWM Lab) for IWM. HBD are leading the planning application process under a Planning Performance Agreement which is currently at pre-application stage.
The supporting text to the draft policy recognises ‘there are opportunities for further development focused on aviation and other uses which are complementary and support the future of the museum site.’
This is welcomed and the partnership described above is wholly in line with this. It presents a rare opportunity for IWM to tackle one of the longstanding challenges it faces to provide large object storage and dedicated bespoke conservation and training space as well as supporting the long-term future of the museum and its airfield.
The draft policy requires the submission of a site-wide masterplan.
IWM strongly supports a masterplanning approach and regards this as fundamental to managing a successful future for the airfield site at IWM Duxford. To this end a masterplan for IWM Duxford was prepared in 2016. An extract from the introduction to the masterplan states:
The vision for IWM Duxford will capitalise on the site’s existing strengths, address existing issues and enable IWM Duxford to meet its role and remit. This requires forward thinking, understanding priorities and a strong sense of commitment to ensure a high-quality visitor experience at all times and for all audiences. A masterplan is the only sensible means of successfully planning and implementing a coordinated long-term vision.
This masterplan which was prepared in consultation with key stakeholders including the local authority and Historic England continues to guide future development at IWM Duxford. The objectives of the masterplan are as follows:
• Enabling the planned increase of visitor numbers
• Protecting the site’s heritage and placing the historic site at the heart of the visitor experience
• Creating a unique public offer and visitor experience
• Ensuring the long-term viability of the site and airfield
• Making efficient use of the grounds and addressing key operational issues
• Maximising the site’s commercial potential without impacting on the visitor experience

It is considered this wholly aligns with the draft policy.
The masterplan provides a flexible framework for development and is not a fixed set of proposals thereby recognising that priorities, opportunities and constraints change over time.
It is worth noting IWM Duxford also has a Conservation Management Plan in place which complements the masterplan.
Development of the western part of the AMC will be for a unique aviation led employment hub. It will not be a visitor attraction and tourist facility but a complimentary commercial use.
A masterplan for AVTech is currently being prepared. This is considered vital by both HBD and IWM to ensure a co-ordinated approach which encompasses the close complimentary relationship between the future uses and activities at AvTech and those at IWM Duxford and gives full consideration to the sensitivities of the historic airfield site. The AvTech masterplan will sit comfortably alongside the IWM masterplan.
The preparation of one site wide masterplan is not considered necessary, nor will it provide benefits over and above two complimentary masterplans. The key is ensuring a masterplanning approach is taken across the AMC.