The document accuracy letter, 25 September 2026

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CLAG: the document accuracy letter (25 September 2026) Request under section 62(3) of the Town and Country Planning Act 1990 that the Council require documents that assess the design applied for. They are a Heritage Statement, a Design and Access Statement, a Planning Statement, a Townscape and Visual Appraisal and a Sustainability Statement, with the BREEAM pre assessment and the sustainability checklist the Council’s own validation list requires. CLAG asks the Council to consult on them again, its own consultees included. The drawings before the Council show the chimneys at “24530 Top of Chimneys”. The documents Christ’s College (“the applicant”) relies on assess, explain and argue for a building with chimneys 900 mm higher. The Council’s own conservation officer records twice that the Heritage Statement “does not include subsequent revisions made to the chimney height and internal layout” and that the amendment “supersedes the heritage and design and access statements”. The environmental health conditions name the odour and noise assessments of May 2025 of that other building. No BREEAM pre assessment is on the register. CLAG asks for the Council’s answer by Tuesday 29 September 2026, before the case officer’s report to committee on this application (“the report”) is written. A report written on the documents as they stand gives members assessments of another building as assessments of this one, against the Council’s own officer’s record Submitted for the public register of application 26/02109/FUL, to be recorded under the heading above and displayed on the day it reaches the Council, Friday 25 September 2026: the Council’s notice of 19 August 2026 states that views are “published onto the website promptly” (document 9499001), and the applicant’s letters of 5 and 27 August 2026 were displayed within a day (documents 9486713 and 9506331). Application 26/02109/FUL: Christ’s College Library, St Andrew’s Street, Cambridge. Christ’s Lane Action Group (CLAG). Quotations are verbatim from the document cited, and documents are cited by their numbers on the register of this application unless another register is named. It states every point it relies on, so that it stands on its own. Nothing in this letter is a request for a taller flue or chimney. To: planning@greatercambridgeplanning.org and PlanningComments@greatercambridgeplanning.org, for the attention of Dominic Bush (case officer); copy Vanessa Blane (Senior Planning Lawyer, 3C Shared Services); copy Stephen Kelly (Joint Director of Planning and Economic Development, Greater Cambridge Shared Planning); copy legal@3csharedservices.org (the 3C Shared Legal Practice, the address the Council has stated as its accepted point of service). From: Christ’s Lane Action Group (residents@christs-lane.com). Filed Friday 25 September 2026.

Contents 1.

The applicant’s documents assess a design that is not the one applied for, on the Council’s own conservation officer’s record, and the Council can require documents that assess the design applied for

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2.

The Heritage Statement assesses the other design, so the Council cannot be satisfied under HE5(4) that it reflects the effects of the proposal, and a corrected statement is required under section 62(3)

3.

The Design and Access Statement, the Planning Statement and the Townscape and Visual Appraisal explain and argue for the other design, so the Council and the public have not had the applicant’s case for the design applied for

4.

The Sustainability Statement models the other design and the Council holds no assessment of the building against its own standard, so the sustainability the applicant asks the Council to weigh is unassessed

5.

Three of the Council’s own consultees advised on the other design, and the environmental health conditions would bind the applicant to assessments of it by name and date

6.

The Council states by Tuesday 29 September 2026 what it requires under section 62(3) and whom it consults again, or the report names each superseded document and states what each consultee assessed

1. The applicant’s documents assess a design that is not the one applied for, on the Council’s own conservation officer’s record, and the Council can require documents that assess the design applied for The drawings on this register, on which the Council will decide, show one building. The documents the applicant has filed in support of the application assess, explain and argue for another, with chimneys 900 mm higher. The Council’s own conservation officer has recorded it twice. The applicant’s Covering Statement tells the Council and the public that the reports match the drawings, and the applicant asks the Council to decide on those reports. Section 62(3) of the Town and Country Planning Act 1990 provides that the Council “may require that an application for planning permission must include (a) such particulars as they think necessary; (b) such evidence in support of anything in or relating to the application as they think necessary”. CLAG asks the Council to use it. If the Council requires the documents and consults on them, the report is written on assessments of the building applied for. If the Council determines on the documents as they stand, the report gives members assessments of another building as assessments of this one, against the Council’s own officer’s record, and every finding taken from them is a finding on the wrong building. 1.

The drawings show the chimneys at “24530 Top of Chimneys” (Christ’s Lane elevation, drawing CCL-GRA-XX-XX-DR-A-004700, revision P03, document 9423880).

2.

The chimneys were lowered by 900 mm on the earlier application in August 2025, on the Council’s own record: “The alterations included reducing the height of the proposed chimneys by 900mm in response to both Historic England and Conservation Officer consultee comments.” (the Council’s report to its Planning Committee of 29 October 2025 on the earlier application for the identical scheme, 25/02161/FUL (“the 2025 report”), paragraph 3.7).

3.

The Council’s conservation officer’s comments of 13 July 2026 (document 9462719) and 26 August 2026 (document 9505685; “the conservation officer’s comments”) record, in July and again in August 2026, that the applicant’s Heritage Statement (Turley, May 2025, document 9423964; “the Heritage Statement”) “does not include subsequent

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revisions made to the chimney height and internal layout (consented under 25/02162/LBC)”, and that the amendment is one “(which supersedes the heritage and design and access statements)”. Both list the documents reviewed as “Heritage Statement – Turley, May 2025”, “Design and Access Statement – Grafton Architects, May 2025” and “Townscape and Visual Appraisal – Caroe Architects, May 2025”. 4.

The applicant’s Covering Statement of June 2026 (Turley, document 9423967; “the Covering Statement”) says the reports match the drawings: “It should be noted that no changes have been made to the detail of the drawings nor consequently to the reports submitted in support of that application.” (paragraph 1.7). The drawings show the lower chimneys; the reports assess the higher ones as the proposal.

5.

The applicant asks the Council to decide on those reports. Its letter of 1 August 2026 states: “Our position on heritage harm is clearly set out in our Heritage Assessment; we have assessed it properly and ours remains the only thorough and comprehensive analysis.” (document 9481026). Its letter of 27 August 2026 on the National Planning Policy Framework of 17 August 2026 (“the NPPF”) (document 9506331) claims the Heritage Statement as its assessment under HE5(2) of the NPPF, its four categories of effect on a heritage asset.

6.

CLAG’s letters of 13 August 2026 identified the documents and asked for corrected documents and a further consultation. The Council’s written reply of 26 August 2026 states that the submissions “will be addressed, as appropriate, in the Officer report.” No corrected document has been required.

CLAG asks the Council to require, under section 62(3), the five documents named in the summary, corrected to the design applied for and written under the NPPF (sections 2 to 4), with the BREEAM pre assessment and the sustainability checklist (section 4). CLAG asks the Council to consult on them again, its consultees included (section 5), and to answer by Tuesday 29 September 2026 (section 6). Every fact in this letter comes from the applicant’s own documents, the Council’s own documents or the evidence on the register.

2. The Heritage Statement assesses the other design, so the Council cannot be satisfied under HE5(4) that it reflects the effects of the proposal, and a corrected statement is required under section 62(3) HE5(1) of the NPPF requires a proposal affecting heritage assets to be “accompanied by an assessment of the significance of the assets affected (including any contribution made by their setting) and of the potential effect of the proposal on their significance”. HE5(4) requires that “Decision-makers should be satisfied that assessments accurately reflect the effects on heritage assets caused by development proposals.” The Heritage Statement is the applicant’s assessment under HE5(1). The building it assesses is not the building on the drawings, on the Council’s own officer’s record. An assessment of another design is not a conservative assessment of this one; it is not an assessment of this one. If the Council requires a corrected statement, the assessment before members is an assessment of the design applied for, made under the NPPF and after the consultees’ advice on that design. If the Council determines on the statement as it stands, it cannot be satisfied under HE5(4), because its own officer has twice recorded that the statement does not describe the proposal. 1.

The Heritage Statement assesses chimneys 900 mm higher than the drawings show, which it calls “the taller chimney stacks” (paragraphs 5.11 to 5.17). The reduction by 900 mm is the Council’s own record (section 1, item 2).

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2.

The conservation officer’s comments record it twice, in the words at section 1, item 3, and the comments of 26 August 2026 then conclude “with reference to NPPF policies HE4 (1, 2), HE5 (1-4), HE6 (1-3) and HE9”. So HE5(4) is applied, by the Council’s own officer, to a statement the same comments record as not describing the proposal.

3.

The Heritage Statement predates Historic England’s advice on the design (29 July 2025, document 9457102, and 1 September 2025, document 9457105) and the conservation officer’s comments on it. It answers none of them.

4.

The applicant claims the statement as its assessment under HE5(2) in its letter of 27 August 2026 (document 9506331): “We maintain that we have fully and proportionately described the significance of all assets potentially impacted by this scheme, showing those aspects which have a positive effect (HE5 2a); have no effect (HE5 2b), or cause ‘harm’ (HE5 2c).” The scheme so described is the one with the higher chimneys.

5.

The only assessments of the design applied for on the register are the consultees’. They are Historic England’s letters of 29 July 2025 and 1 September 2025, to which its emails of 8 July 2026 (document 9457100) and 27 August 2026 (document 9508056) refer the Council, and the conservation officer’s comments. Both consultees find harm to the setting of the Grade I listed building. Nothing from the applicant on this register answers those findings, because nothing from the applicant assesses that design.

6.

The Heritage Statement also states no dimension for the building’s relationship to the Grade I library it adjoins, and its own drawing gives one. The Christ’s Lane elevation marks “20840 Bodley” at the apex of the Bodley Library’s gable and “22830 Top of Parapet” for the new building, so on the applicant’s own levels the new parapet stands 1.99 metres above the apex of the Grade I library’s gable (drawing 004700 P03, document 9423880; the difference is CLAG’s subtraction of the applicant’s two levels). The Heritage Statement measures the new building against two other things: the stacks are to be experienced “as a background element to the ridge height of the Bodley Library”, and “the overall height of the stacks (and new library building) will be lower than the overall height of the adjacent Bradwell’s Court building” (document 9423964, section 5). The applicant’s own presenter told the Development Control Forum of 29 July 2026 that the view from Christ’s Lane is the one “from where the new library will appear taller than the Bodley” (the Council’s published minutes, item 23; CLAG’s transcript extract of the Development Control Forum of 29 July 2026, filed with this letter, entry 4.31). An assessment of the effect on the Grade I library’s setting that does not state the dimension its own drawing gives is not one the Council can be satisfied “accurately reflect[s] the effects” (CLAG’s design and development plan paper, filed with this letter, section 3).

CLAG asks the Council, under section 62(3), to require a Heritage Statement that assesses the design applied for under HE5(1) and HE5(2) of the NPPF, and to consult on it. If the Council requires it, the harm the consultees found is answered by the applicant for the design applied for and carries the weight HE6(3) gives it before any balance under HE6(4) of the NPPF, its weighing of harm to a designated asset against public benefits. If the Council determines on the statement as it stands, the proposal is determined without the assessment HE5(1) requires, and the Council has not taken “reasonable steps to acquaint himself with the relevant information” (Secretary of State for Education and Science v Tameside Metropolitan Borough Council [1977] AC 1014 at 1065). Members given the statement as the assessment of this proposal are misled as to what has been assessed, against the Council’s own officer’s record (R (Mansell) v Tonbridge and Malling BC [2017] EWCA Civ 1314, [2019] PTSR 1452 at [42]). The justification HE4(2) requires is taken from a document about another design, so the policy is not applied to the proposal before the Council (Tesco Stores Ltd v Dundee City Council [2012] UKSC 13 at [18]).

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3. The Design and Access Statement, the Planning Statement and the Townscape and Visual Appraisal explain and argue for the other design, so the Council and the public have not had the applicant’s case for the design applied for Article 9(3) of the Town and Country Planning (Development Management Procedure) (England) Order 2015 (“the 2015 Order”) requires a design and access statement to “explain the design principles and concepts that have been applied to the development”. The Council’s published list of what an application must include (Greater Cambridge Shared Planning, “Full planning permission: application checklist”; “the validation checklist”) requires a planning statement giving “An assessment of how the proposal has taken account of adopted national and local policy” and a visual assessment. The Design and Access Statement (Grafton Architects, May 2025, documents 9423960 to 9423962 and 9427162), the Planning Statement (Turley, May 2025, document 9423963) and the Townscape and Visual Appraisal (Caroe Architects, May 2025, document 9423730; “the Appraisal”) are those documents. Each explains, argues for and illustrates the building with the higher chimneys, and none has been rewritten for the design applied for. If the Council requires corrected documents, the Council and the public have, for the first time, the applicant’s own explanation of the design principles of the building applied for, to test against the consultees’ findings on that building. If the Council determines on the documents as they stand, the design and access statement before it explains the design principles of a development that is not applied for. A report that gives members its account, or the Planning Statement’s, gives them an account of another building as the account of this one. 1.

The Design and Access Statement, part 2 (document 9423961), printed page 44, presents the proposed Christ’s Lane elevation dimensioned “25430 Top of Chimneys”. The drawings show “24530 Top of Chimneys”.

2.

Its printed page 32 is headed “The Advantages of the Taller Chimneys” and closes: “In summary, we think there are significant benefits, not only architecturally, but also from a passive ventilation and air quality perspective, in maintaining the proposed chimney height and proportion of these important functioning elements of the design.” The design principles explained are those of chimneys the applicant then lowered.

3.

The Planning Statement states, of this application: “Whilst the application has been submitted with the taller chimneys, the College are happy to continue to discuss this issue and modifications to the proportions and detailing could be covered by condition if necessary.” (paragraph 7.32). The application was submitted with the lower chimneys. It also states: “There is a difference of opinion between the DRP and officers regarding the height of the chimneys. The submitted proposals reflect the views of the Panel.” (paragraph 1.12). The submitted proposals do not.

4.

The Planning Statement assesses the proposal against the National Planning Policy Framework of December 2024, by paragraph number (paragraphs 8.20 and 8.21). Its account of the consultees ends with the Council’s advice of May 2025, before Historic England and the conservation officer advised on the application. The only document from the applicant that addresses the NPPF in force is its letter of 27 August 2026 (document 9506331), which assesses nothing and refers the Council back to the Heritage Statement.

5.

The Appraisal is the appraisal of May 2025, filed again; its views show the building with the higher chimneys. It is filed without the applicant’s own replacement page 34 of 30 September 2025 (document 7378938 on the register of 25/02161/FUL), which supplied section 8.3, “Summary of Impacts to Representative Views & Visual Receptors”; on the

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copy on this register that column is blank but for one sentence. The Covering Statement says of these reports that they “remain the same” (paragraph 1.5). The copy filed carries two further marks of a document not checked before filing: its methodology page carries a drafting note left in the text, “FIND QUOTE for this and table below!” (page 38 of the document), and its copyright page reserves the rights in the work to “Caroe Architecture Ltd and of the National Trust”, a client with no part in this application, and calls the Appraisal “this Heritage Statement” (page 52 of the document). CLAG asks the Council, under section 62(3), to require a Design and Access Statement, a Planning Statement and a Townscape and Visual Appraisal that explain, assess and illustrate the design applied for under the NPPF, and to consult on them. If the Council requires them, the application is accompanied by the documents article 9(3) of the 2015 Order and the validation checklist require of it, and the applicant’s case for the building applied for can be judged against the lower designs on the register. If the Council determines on the documents as they stand, the application does not comply with article 9(3). A report that carries the Design and Access Statement’s account of the design, or the Planning Statement’s account of the application and of the consultees, misleads members on a matter of fact (Mansell at [42]).

4. The Sustainability Statement models the other design and the Council holds no assessment of the building against its own standard, so the sustainability the applicant asks the Council to weigh is unassessed The applicant asks the Council to weigh the scheme’s sustainability against the heritage harm. Its letter of 27 August 2026 (document 9506331) claims substantial weight for the scheme’s energy measures under CC2(2) of the NPPF: “The phrasing ‘substantial weight’ is relevant here when considering the balance against any heritage harms identified.” The evidence for that benefit is the Sustainability Statement (Skelly & Couch, revision 2.0, 16 May 2025, document 9423735; “the Statement”). The Statement models the building with the higher chimneys, and the Council holds no assessment of the building against its own standard. If the Council requires a corrected Statement, the BREEAM pre assessment and the checklist, the sustainability of the building applied for is assessed against the Council’s own standard for the first time. If the Council determines on the Statement as it stands, a report that counts the scheme’s sustainability as a public benefit counts evidence about another building as evidence about this one. Policy 28 of the Cambridge Local Plan 2018 (“Policy 28”) is applied without the demonstration of compliance the Council’s own documents require. 1.

The Statement is the document filed with the earlier application, unchanged, on the Covering Statement’s own words (paragraph 1.7, quoted at section 1, item 4). Its overheating model “represents the building geometry” (page 26), and the geometry modelled is the building with the chimneys 900 mm higher.

2.

The Statement’s own authors, the applicant’s mechanical and electrical consultants, then revisited the design. The applicant’s letter of 27 August 2025 records that “the architects and MEP consultants (Skelly and Couch) have revisited the proposals” and that the change “equates to a reduction in height of c900mm.” (document 7357152 on the register of 25/02161/FUL). No revisited assessment is on this register.

3.

The validation checklist requires, for “All new non-residential development”, “A BREEAM Pre-Assessment demonstrating that the proposals will meet the requirement for achievement of BREEAM ‘excellent’”. The register holds none.

4.

The validation checklist requires for all development “A sustainability statement and checklist”, integrated within the Design and Access Statement, citing Policy 28 and the

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Greater Cambridge Sustainable Design and Construction Supplementary Planning Document, adopted in January 2020 (“the SPD”). The register holds no checklist. The Statement is a standalone document on the applicant’s own framework, the RIBA Sustainable Outcomes, which it says was “reviewed by and agreed with the Sustainability Officer” (page 3). 5.

The SPD requires the demonstration the validation checklist asks for: “Compliance with the policy should be demonstrated by submission of a BREEAM pre-assessment, completed by an accredited BREEAM Assessor, which clearly demonstrates achievement of the BREEAM ‘excellent’ standard.” (paragraph 3.2.8).

6.

The Council’s letter of 10 June 2026 (document 9426229) states that the application was checked against “our published validation checklist” and asks for two documents whose pages had uploaded blank. It asks for nothing else. Under articles 11(3) and 34(6) of the 2015 Order the particulars on the Council’s published list are requirements of a valid application.

CLAG asks the Council, under section 62(3), to require a Sustainability Statement that assesses the design on the drawings, the BREEAM pre assessment of the new library by an accredited assessor, and the completed sustainability checklist, and to consult on them. If the Council requires them, the benefit weighed under HE6(4) of the NPPF, its weighing of harm to a designated asset against public benefits, is a benefit of the building applied for, assessed against the Council’s own standard. On the applicant’s own figures its efficiency measures fail that standard until roof panels are added, which any lower design carries (CLAG’s sustainability evidence, section 3, filed with this letter). If the Council determines on the Statement as it stands, the report counts evidence about another building, which the applicant’s own consultants have revisited, as evidence about this one (Mansell at [42]). Policy 28 is applied without the demonstration the SPD (paragraph 3.2.8) and the validation checklist require (Tesco at [18]). The Council determines without the information its own list names as required (Tameside at 1065).

5. Three of the Council’s own consultees advised on the other design, and the environmental health conditions would bind the applicant to assessments of it by name and date The report will give members the advice of the Council’s own specialists as the Council’s assessment of this proposal. The environmental health, sustainability and urban design advice on this register is advice on the building with the higher chimneys, given in 2025 and carried into this application unchanged. DM6(1) of the NPPF provides that conditions should be attached only where they are “Necessary to make the development acceptable in planning terms” and “Sufficiently precise to make them capable of being complied with and enforced”, and article 35(1)(a) of the 2015 Order requires the decision notice to state “their full reasons” for each condition. A condition that names an assessment of another building meets neither. If the Council consults the three consultees again on the design as drawn, the advice before members is advice on the building applied for, and the conditions recommended are tied to assessments of it. If the Council determines on the advice as it stands, members are given the 2025 advice as the Council’s assessment of this application, and the conditions incorporate, by name and date, assessments of a building the applicant does not propose. 1.

Environmental health: the response of 20 July 2026 (document 9468203) and its corrected reissue of 18 August 2026 (document 9499190) describe the scheme as “an almost identical resubmission” and state that “our previous updated and corrected comments etc remain relevant / valid”. Their recommended conditions name the odour

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assessment (Greenavon, revision V1, 16 May 2025, document 9423723) and the plant noise assessment (Cass Allen, revision 3, 23 May 2025, document 9423991). Both assess the building with the higher chimneys, so a permission on those conditions binds the applicant to assessments of another building. 2.

Sustainability: the officer’s advice of 18 June 2026 (document 9435149) is the text placed on the register of the earlier application in July 2025 (document 7323968 on the register of 25/02161/FUL), word for word, under a different officer’s name. The Council consulted again on 19 August 2026, “To allow further representations to be made on the implications of the updated National Planning Policy Framework (NPPF) (17th August 2026) relating to the proposal.” (document 9499001), and the officer’s further comment states: “my comments of 18/06/2026 still apply” (document 9500177).

3.

Urban design: the response of 23 June 2026 (document 9439492) states: “No amendments are being proposed as part of this application and as such we maintain our support for the proposed scheme”. The assessment it appends is the response of 26 June 2025, whose comments relate “to the Design Access Statement dated 23 May 2025”, the document that explains the higher chimneys (section 3, item 2). Its reply to the consultation on the NPPF reads in full: “We have no further urban design comments following our response dated 23rd June 2026.” (document 9500904).

4.

The conservation officer’s comments of 26 August 2026 assessed the plans, recorded the applicant’s documents as superseded, found harm and were given again under the NPPF: “Revised comments to reflect updated NPPF, August 2026” (document 9505685). The landscape officer advised again under the NPPF (document 9504134). The three consultees at items 1 to 3 assessed the design as drawn on no document on this register.

CLAG asks the Council to consult the environmental health, sustainability and urban design consultees again on the design as drawn and under the NPPF, each response stating which drawings and which documents it assessed. If the Council consults them again, the conditions recommended are tied to assessments of the building applied for and the sustainability advice is the officer’s own assessment of this application. If the Council determines on the advice as it stands, a report that carries the 2025 advice as the Council’s assessment of this application misleads members on what its own consultees assessed (Mansell at [42]). A permission on the recommended conditions names, as the assessments the applicant must comply with, assessments of a building the applicant does not propose, and such a condition is not “Necessary to make the development acceptable in planning terms” (DM6(1)(a) of the NPPF, its policy on the use of planning conditions).

6. The Council states by Tuesday 29 September 2026 what it requires under section 62(3) and whom it consults again, or the report names each superseded document and states what each consultee assessed CLAG asks the Council to state in writing, by Tuesday 29 September 2026, what it will require of the applicant under section 62(3), by when, and whom it will consult again. The date is set so that the corrected documents and the further consultation come before the report is written. The Council answered CLAG’s letter of 7 August 2026 (document 9490029) on 13 August 2026, six days later, and the Council’s environmental health officer corrected the figure CLAG’s letter of 7 August 2026 to the officer identified (document 9494186) by a reissued response on 18 August 2026, eleven days later (document 9499190); CLAG asks for this answer within four days. 1.

CLAG asks for the documents that assess the design applied for (sections 2 to 4), the BREEAM pre assessment and the checklist (section 4), and the consultee responses on

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the design as drawn (section 5), on the register before the report is written. CLAG asks for a further consultation on them. 2.

CLAG asks that the register record this letter and the Council’s answer, so that members and the public see the same record.

If the Council requires the documents and consults on them, the report is written on assessments of the building applied for, made under the NPPF, and on advice given on it. The committee date follows the further consultation (CLAG’s determination timing letter, filed with this letter). If the Council determines on the documents as they stand, the report has to name each document the Council’s own officer records as superseded and state what it does about it. It has to state, for each assessment and each consultee, which drawings and which documents were assessed, and on what basis the Council determines without the sustainability documents its own list requires. The errors named in sections 2 to 5 stand on the record before the report is written. CLAG will rely on this letter and on the Council’s answer, or on the absence of one. Christ’s Lane Action Group residents@christs-lane.com

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