Greater Cambridge Local Plan Issues & Options 2020

1. Introduction 1.1 IWM Duxford retains the finest and best-preserved fighter base representative of the period up to 1945 in Britain with important associations with The Battle of Britain and the American Support for the Eighth Air Force. It closed as a military airfield in 1961 and became the first regional branch of the Imperial War Museums (IWM) in 1976. 1.2 In 2017/18, IWM Duxford attracted a total of almost 400,000 visits; 2/3 from people outside the Eastern Region and 12% from overseas. It directly employed 85 FTE posts whilst the 27 on-site third party organisations employed the equivalent of a further 150 FTEs. A report on the Economic and Social Impact of the Museum by Hatch Regeneris published in January 2019 calculated that the value of the site to the East of England equated to 1040 FTE jobs and £43m in GVA. 1.3 In addition, through its school programme activities, public learning and volunteering opportunities, IWM Duxford contributes to social inclusion and wellness far in excess of the monetary values above. 1.4 IWM is therefore very pleased to have the opportunity to comment on this early stage of the replacement Local Plan and in general terms supports the key themes under discussion. Turley have been asked by IWM to coordinate its responses.

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2.1 IWM Duxford is an active airfield which is not located particularly conveniently for public transport networks. It is also a conservation area containing 38 Listed Buildings the environmental performance of which is difficult to improve without impacting their heritage significance. As a major facility within the GC Plan area, these are key issues affecting our ability to achieve carbon neutrality and we therefore look to the new local plan to guide and support our efforts. 2.2 Comments regarding the need to better connect key destinations such as IWM Duxford to public transport facilities are given in answer to Q37. 2.3 Comments regarding the adaptation of historic buildings in response to climate change are in Q9. 2.4 The flying of historic aircraft in itself will never achieve carbon neutrality, and so IWM is actively looking at carbon offsetting. This is again considered further in the comments on Q9. Response to Q9 2.5 In terms of missing key actions, IWM recognises that the present local plan includes policies such as NH/15 (Heritage Assets and Adapting to Climate Change) and that the Council has produced the Sustainable Design and Construction SPD. However, with regard to historic buildings, the latter provides little additional information particularly in terms of advice on how heritage significance should be weighed against energy efficiency in practical ways. 2.6 IWM is also aware that guidance has been produced by Historic England and other respected bodies. The former is often quite specific and relates to specific aspects of building fabric, such as insulation or windows, whilst the latter is often generic or looks at residential building types. Its use is therefore limited given that many of the historic buildings at Duxford were designed for specific functions, of cheap / readily available materials and at a time when comfort and safety were differently perceived. 2.7 This lack of practical information needs to be addressed in the new local plan (and possibly also in revised SPD). What is needed is an understandable methodology for assessing climate change benefits; clearly defining the heritage significance of buildings and their component parts; balancing different levels of harm to different features; how you measure the resultant heritage harm and then to bring all this information together to decide which measures are acceptable. 2.8 IWM feel that the Council needs to work proactively with it and others both in developing an evidence base to support any policy / guidance and consequently learning from best practice, both in Gt Cambridge and elsewhere. A failure of the current local plan policy is that all the emphasis is placed on the applicant to provide information. At a time when the Council has declared a ‘climate emergency’ there needs to be a much more joined up and collaborative approach to this issue. 2.9 There is also a need for clear guidance for situations where carbon offsetting is justified. Altering some of the cheaply-built, utilitarian structures at Duxford to reduce their carbon footprint would fundamentally alter their heritage significance and their authenticity. Similarly, flying historic aircraft cannot in itself be done without a carbon footprint. 2.10 Offsetting is therefore the obvious answer. IWM would be keen to work with the Council to discuss the situations where offsetting is desirable or is acceptable and what form this should take so that it is of direct relevance to the place or issue concerned.

2.5 In terms of missing key actions, IWM recognises that the present local plan includes policies such as NH/15 (Heritage Assets and Adapting to Climate Change) and that the Council has produced the Sustainable Design and Construction SPD. However, with regard to historic buildings, the latter provides little additional information particularly in terms of advice on how heritage significance should be weighed against energy efficiency in practical ways. 2.6 IWM is also aware that guidance has been produced by Historic England and other respected bodies. The former is often quite specific and relates to specific aspects of building fabric, such as insulation or windows, whilst the latter is often generic or looks at residential building types. Its use is therefore limited given that many of the historic buildings at Duxford were designed for specific functions, of cheap / readily available materials and at a time when comfort and safety were differently perceived. 2.7 This lack of practical information needs to be addressed in the new local plan (and possibly also in revised SPD). What is needed is an understandable methodology for assessing climate change benefits; clearly defining the heritage significance of buildings and their component parts; balancing different levels of harm to different features; how you measure the resultant heritage harm and then to bring all this information together to decide which measures are acceptable. 2.8 IWM feel that the Council needs to work proactively with it and others both in developing an evidence base to support any policy / guidance and consequently learning from best practice, both in Gt Cambridge and elsewhere. A failure of the current local plan policy is that all the emphasis is placed on the applicant to provide information. At a time when the Council has declared a ‘climate emergency’ there needs to be a much more joined up and collaborative approach to this issue. 2.9 There is also a need for clear guidance for situations where carbon offsetting is justified. Altering some of the cheaply-built, utilitarian structures at Duxford to reduce their carbon footprint would fundamentally alter their heritage significance and their authenticity. Similarly, flying historic aircraft cannot in itself be done without a carbon footprint. 2.10 Offsetting is therefore the obvious answer. IWM would be keen to work with the Council to discuss the situations where offsetting is desirable or is acceptable and what form this should take so that it is of direct relevance to the place or issue concerned.

2.11 IWM considers that currently the practice amongst Council officers to resist even relatively minor changes to heritage assets even when the benefit in sustainability and other terms is quite great needs to fundamentally alter. This practice has very clear implications for institutions with a large portfolio of heritage assets and their ability to meet climate change targets. It is considered that a more balanced and pragmatic approach needs to be adopted by the Council if this issue is to be realistically addressed (see Question 9). Response to Q9 2.5 In terms of missing key actions, IWM recognises that the present local plan includes policies such as NH/15 (Heritage Assets and Adapting to Climate Change) and that the Council has produced the Sustainable Design and Construction SPD. However, with regard to historic buildings, the latter provides little additional information particularly in terms of advice on how heritage significance should be weighed against energy efficiency in practical ways. 2.6 IWM is also aware that guidance has been produced by Historic England and other respected bodies. The former is often quite specific and relates to specific aspects of building fabric, such as insulation or windows, whilst the latter is often generic or looks at residential building types. Its use is therefore limited given that many of the historic buildings at Duxford were designed for specific functions, of cheap / readily available materials and at a time when comfort and safety were differently perceived. 2.7 This lack of practical information needs to be addressed in the new local plan (and possibly also in revised SPD). What is needed is an understandable methodology for assessing climate change benefits; clearly defining the heritage significance of buildings and their component parts; balancing different levels of harm to different features; how you measure the resultant heritage harm and then to bring all this information together to decide which measures are acceptable. 2.8 IWM feel that the Council needs to work proactively with it and others both in developing an evidence base to support any policy / guidance and consequently learning from best practice, both in Gt Cambridge and elsewhere. A failure of the current local plan policy is that all the emphasis is placed on the applicant to provide information. At a time when the Council has declared a ‘climate emergency’ there needs to be a much more joined up and collaborative approach to this issue. 2.9 There is also a need for clear guidance for situations where carbon offsetting is justified. Altering some of the cheaply-built, utilitarian structures at Duxford to reduce their carbon footprint would fundamentally alter their heritage significance and their authenticity. Similarly, flying historic aircraft cannot in itself be done without a carbon footprint. 2.10 Offsetting is therefore the obvious answer. IWM would be keen to work with the Council to discuss the situations where offsetting is desirable or is acceptable and what form this should take so that it is of direct relevance to the place or issue concerned

2.12 IWM Duxford incorporates a significant land area in which the operation and retention of the airfield greenspace and habitats is directly dependent on protecting the ability to fly historic aircraft in acrobatic displays. Similarly, the landscape setting of the airfield with views across flat open countryside to the ridge of hills to the south is a fundamental aspect of its heritage significance. 2.13 This importance is acknowledged in paragraph 8.36 of the 2018 local plan which states ‘given its national significance, the District Council will give IWM Duxford special consideration within the context of protecting the quality of the surrounding landscape in this sensitive site on the edge of the Cambridge Green Belt’. 2.14 Similarly, the present local plan (para 10.37) requires developments within the Aerodrome Safeguarding Zone to be subject to consultation with IWM. The extent of the safeguarding is shown on Figure 13 in the Local Plan and broadly requires consultation on buildings over 10m tall within 2km of the airfield and 45m tall within 10km. As the latter covers parts of neighbouring authorities in North Hertfordshire and Uttlesford Districts, it is vital that the ‘duty to cooperate’ with neighbouring authorities is adhered to. 2.15 The IWM consider it vital that this special consideration is retained within the Greater Cambridge Plan and that the safeguarding consultation is more strictly enforced by being tied to a specific policy within the new plan. This will protect the IWM’s ability to fly from the airfield and its important landscape setting.

2.16 The IWM as a visitor destination delivers social value derived from the wellbeing impact on visitors and volunteers, as well as from its bespoke programme of community activities and education activities. These social impacts are generated from the array of activities that IWM carries out which include: • Day-to-day activities of the museum; • Events such as Air Shows and large conferences; and • Third party organisations located at the Duxford site from aircraft and maintenance engineering companies to organisations associated with military heritage. 2.17 The social impacts that IWM provides bring great value to the community (local, regional, national and international). These impacts include improved learning outcomes, increased social cohesion, increased health and wellbeing and preservation of heritage. 2.18 An Economic and Social Impact of IWM report was commission January 2019, by Hatch Regeneris. This records how the IWM is visited by thousands of school children each year and almost one fifth of all schools in the East visit the museum annually. The role of volunteers at IWM make a significant contribution to its operations. Volunteering can have very positive impacts on the personal health and well-being of volunteers, improving mental and physical health, life satisfaction, self-esteem and happiness. 2.19 The important role in promoting well-being and social inclusion that IWM and visitor attractions in the region have, needs to be recognised in the new plan and given weight. Improving accessibility to these facilities for all by improving sustainable transport links from rural areas (see response to Q37) should be supported to improve social inclusion in the Greater Cambridge area. 2.20 The IWM should therefore continue to be recognised as an important major tourist / visitor attraction, educational and commercial facility as is currently established in the current local plan policy E/7.

Q22: How do you think we should protect, enhance and adapt our historic buildings and landscapes? 2.21 See comments on Q9 and Q11 regarding adapting historic buildings in response to climate change. 2.22 IWM is committed to its responsibilities as the custodian of the heritage assets at Duxford as part of its duty to preserve for the nation its collection as a national museum. The current resistance to relatively minor changes described in Q11 directly impacts IWM’s ability, as a charity with limited funds, to conserve and protect the built heritage of the site by creating prohibitive delays, costs and conditions. A more balanced and pragmatic approach by the Council would facilitate more proactive action by IWM across a greater range of its heritage assets. 2.23 See response to Q12 regarding protection of historic landscape setting of the airfield. 2.24 IWM welcomes the positive working relationship it has with both the Council and Historic England. On a site which is wholly within a conservation area (the IWM assisted with and supported its designation) and contains such a high number of heritage assets, the continuation of such relationships is vital. 2.25 To assist this, IWM drew up a masterplan (which has recently been refreshed) which was itself informed by a Conservation Management Plan, a landscape study and a transport study. 2.26 Masterplans are extremely useful and important documents which allow a long term vision for complex sites with multiple designations to be shared and the potential of them to be unlocked whilst involving key stakeholders throughout the process. They provide continuity and broad certainty which benefits the freeholder and any tenants, statutory bodies and consultees and the public. 2.27 The next local plan should actively encourage the drawing up of masterplans for sites such as IWM Duxford and include a commitment to devise a process by which such documents can be enshrined in policy, as SPD or at least endorsed by the Council. Without this, personnel changes to Council officers and members mean that they lack permanence and become resource-hungry because of the need to constantly remind people of their existence. Response to Q9 2.5 In terms of missing key actions, IWM recognises that the present local plan includes policies such as NH/15 (Heritage Assets and Adapting to Climate Change) and that the Council has produced the Sustainable Design and Construction SPD. However, with regard to historic buildings, the latter provides little additional information particularly in terms of advice on how heritage significance should be weighed against energy efficiency in practical ways. 2.6 IWM is also aware that guidance has been produced by Historic England and other respected bodies. The former is often quite specific and relates to specific aspects of building fabric, such as insulation or windows, whilst the latter is often generic or looks at residential building types. Its use is therefore limited given that many of the historic buildings at Duxford were designed for specific functions, of cheap / readily available materials and at a time when comfort and safety were differently perceived. 2.7 This lack of practical information needs to be addressed in the new local plan (and possibly also in revised SPD). What is needed is an understandable methodology for assessing climate change benefits; clearly defining the heritage significance of buildings and their component parts; balancing different levels of harm to different features; how you measure the resultant heritage harm and then to bring all this information together to decide which measures are acceptable. 2.8 IWM feel that the Council needs to work proactively with it and others both in developing an evidence base to support any policy / guidance and consequently learning from best practice, both in Gt Cambridge and elsewhere. A failure of the current local plan policy is that all the emphasis is placed on the applicant to provide information. At a time when the Council has declared a ‘climate emergency’ there needs to be a much more joined up and collaborative approach to this issue. 2.9 There is also a need for clear guidance for situations where carbon offsetting is justified. Altering some of the cheaply-built, utilitarian structures at Duxford to reduce their carbon footprint would fundamentally alter their heritage significance and their authenticity. Similarly, flying historic aircraft cannot in itself be done without a carbon footprint. 2.10 Offsetting is therefore the obvious answer. IWM would be keen to work with the Council to discuss the situations where offsetting is desirable or is acceptable and what form this should take so that it is of direct relevance to the place or issue concerned Response to Q11 2.11 IWM considers that currently the practice amongst Council officers to resist even relatively minor changes to heritage assets even when the benefit in sustainability and other terms is quite great needs to fundamentally alter. This practice has very clear implications for institutions with a large portfolio of heritage assets and their ability to meet climate change targets. It is considered that a more balanced and pragmatic approach needs to be adopted by the Council if this issue is to be realistically addressed

2.28 The IWM at Duxford is Britain’s largest aircraft museum. In 2017/18 it attracted almost 400,000 visitors and so was the most visited paid-for attraction in the region. Its airshows that year attracted 90,000 visitors alone. 2.29 It is important that key tourist facilities and visitor attractions such as IWM Duxford continue to be fully supported in the new plan. In addition to the economic benefits to the Greater Cambridge area and the social value they bring, they help spread visitor numbers away from central Cambridge. Policies need to support and protect such facilities whilst allowing for appropriate expansion and development in context with each site. 2.30 The proposed development of a hotel on the IWM site will service the conference facilities and museum visitors allowing for extended stays, enhancing visitor experience and can help reduce the carbon footprint of the site. 2.31 Key to supporting IWM Duxford, and encouraging carbon reduction will be the ability to better link it to more sustainable transport modes (see Q37). Q37. How should we encourage a shift away from car use and towards more sustainable modes of transport such as public transport, cycling and walking? 2.32 A key aspect of any future transport strategy, which needs to be promoted through the new local plan, will be to properly connect key generators and destinations. 2.33 The relatively rural location of IWM Duxford (next to the A505 / M11 junction) means that 96% of visitors arrive by car. This means a high carbon footprint and large area for car parking which could otherwise be landscaped. 2.34 If this is to change, there needs to be support for better links to transport hubs and routes. This will give visitors and staff alternatives to the private car and mean that by better linking with local schools and villages, the benefits for social well-being will be greater (see Q16). 2.35 Any ways to encourage public transport operators to adopt a single ticket system and ensuring that profitable routes subsidise rural routes so that these can be delivered at a usable frequency for commuters could be an important aim of the Greater Cambridgeshire plan. 2.36 The plan also needs to support the creation of an expanded network of safe green routes for walking and cycling, (with suitable surfaces for mobility scooters, e-bikes, e-scooters etc) which can link between public transport and employment hubs and visitor destinations.

2.32 A key aspect of any future transport strategy, which needs to be promoted through the new local plan, will be to properly connect key generators and destinations. 2.33 The relatively rural location of IWM Duxford (next to the A505 / M11 junction) means that 96% of visitors arrive by car. This means a high carbon footprint and large area for car parking which could otherwise be landscaped. 2.34 If this is to change, there needs to be support for better links to transport hubs and routes. This will give visitors and staff alternatives to the private car and mean that by better linking with local schools and villages, the benefits for social well-being will be greater (see Q16). 2.35 Any ways to encourage public transport operators to adopt a single ticket system and ensuring that profitable routes subsidise rural routes so that these can be delivered at a usable frequency for commuters could be an important aim of the Greater Cambridgeshire plan. 2.36 The plan also needs to support the creation of an expanded network of safe green routes for walking and cycling, (with suitable surfaces for mobility scooters, e-bikes, e-scooters etc) which can link between public transport and employment hubs and visitor destinations.

2.37 Policy E/7 of the 2018 Local Plan is very much welcomed by the IWM as it positively supports the operation of the site and its potential to evolve.