Heritage harm: a building too big for its setting

"Too big for its location"

The removal of the basement, Historic England found, "brings other instances of harm, as it puts considerable pressure on the surrounding buildings forming Bath Court. The building feels too big, overdominant on this space, particularly in its relationship with the south range of first court and the Bodley Library." The increased height towards Christ's Lane "feels quite large when seen alongside the relatively modest elevations of the college."

On the proposal overall: "we are of the view that the building is too big for its location." The wall lifted to turret level at the Bodley corner "feels more overbearing in its relationship with the Bodley and evidences the difficulties to accommodate a building which is too large for what is a very domestic setting." The prominence of the chapel turret "should remain unchallenged."

Historic England tied the harm to the excessive bulk of the building

The conclusion tied the harm directly to the size: the proposals "would result in certain levels of harm to the significance of the listed building, primarily as a result of the excessive bulk of the new building, which we consider would detract from the setting of the surrounding buildings." The proposals "would be bulkier" than those previously granted consent. Historic England "would strongly encourage that massing is further reduced so it sits better within this context."

The College reduced the chimneys by 90 cm and left the massing unchanged

The Government's own heritage adviser found that a building "too big for its location" harms the significance of the Grade I college "primarily as a result of the excessive bulk of the new building", and asked for the massing to be reduced. The College reduced the chimneys by 90 cm and left the rest of the building as it was, so that Historic England's second letter could only record that "the overall massing of the building remains unchanged". The harm it identified remains unchanged with it, and the College presents that same bulk as causing no harm at all.

Historic England traces the bulk above ground to the loss of the basement

Historic England's own account of why the building stands as high as it does is in the same letter: "In order to meet the requirements of the brief and compensate for the loss of the basement, the building needs to extend further above ground."

Historic England’s advice applies to the second application

Read Historic England's first advice (29 July 2025) and its second advice (1 September 2025). Historic England has confirmed this advice also applies to the current application, 26/02109/FUL: its July 2026 letter records that the proposals "remain unchanged from those previously assessed", and on 27 August 2026, asked about the Framework of 17 August 2026, it wrote: "We are comfortable that our existing advice remains relevant and appropriate".

"Dominant scale," "ill-proportioned massing"

The Victorian Society, a statutory consultee, headed its principal concern "The Dominant Scale in Comparison to the Bodley Library." The building steps back about one metre but stands a whole storey higher, which the Society found "has the greater potential to be harmful to the setting of the Bodley Library than the proximity of the floor plan." The 2016 basement scheme "would not be overtly harmful… as the newly proposed scheme has the potential to be."

On the mass, the building "appears to lack the 'human scale' evocative both in the Bodley Library and the C15 first court." Its elevations "appear starkly unrelieved," and its upper storeys "overly impose themselves on the front elevation… increasing the sense of excessive scale." The clear views of the Bodley gable and turret staircase against sky "would be overwhelmed by the proposed building." Its recommendation was to align the floors with the Bodley's oriel window, "thus reducing the height by approximately half at each floor."

The Society found that the "dominant scale" and "ill-proportioned massing" harm the setting of the Grade I Bodley Library and rob the building of the "human scale" of its neighbours, and offered to cure that harm by reducing each floor by about half. The College did neither. "The same submitted scheme cannot improve its level of harm."

Read the Victorian Society's advice (August 2025), its response to the second application (6 July 2026), and its reply to the College's agent (9 July 2026).

"A damaging overdevelopment of the site"

The proposal is "substantially larger above ground level than both the existing building and the previously consented scheme." It "introduces a scale of development that is out of keeping with its context" and is "a damaging overdevelopment of the site." On Historic England's wording, Forshaw adds: "I would say 'too large' rather than 'quite large'."

Forshaw finds the harm on four assets at once

The harm falls on four assets. At the Bodley Library, the gable silhouette against clear sky "will be radically changed," the staircase tower's geometry "conflicts starkly with the sloping gable end and the splayed and crenelated staircase turret," and the new parapet is "higher indeed than the staircase turret that it adjoins." On Christ's Lane, the chimneys are "bulky and monolithic structures, rather industrial in character," rising "14 metres sheer from pavement level" on a lane about 6 metres wide, coalescing into "an overpowering mass of masonry… which will overwhelm the townscape." Within the college hierarchy, even reduced, the chimneys "will be as tall as the Gatehouse towers, and almost as high as the landmark cupola of the Hall, creating a presence… that is grossly disproportionate." In Bath Court, the mass "will loom over Bath Court, cutting out much of the existing daylight and sunlight… and will have an over-bearing impact on the character and appearance of Bath Court."

Forshaw puts the harm in the middle range and finds it avoidable

Forshaw found that one oversized building, "a damaging overdevelopment of the site," inflicts harm on the Bodley Library, Christ's Lane, First Court and Bath Court at once, an "overpowering mass of masonry" that is "grossly disproportionate" to the college. He assessed the cumulative effect as "within the middle range of less-than-substantial harm to several designated heritage assets of the very highest significance," harm not outweighed by public benefit, and avoidable, since the Create Streets basement alternative delivers the same capacity within three storeys above pavement level. In his conclusion the scheme should not be approved in its current form.

Forshaw answered the report’s claim of a fire requirement on 5 October 2026

On 5 October 2026, on the Council's report, Forshaw wrote that the harm he identifies "arises from the upper floors and the mass of the whole building", that "No document on the register states a fire requirement for the height of the tower, and no regulation imposes one", and that "The officer's report recites policy HE4(1)(b) at paragraph 16.6 and makes no finding under it."

Read Alec Forshaw's full appraisal and his comments of 5 October 2026.

Multi-layered harm to highly sensitive heritage

Cambridge's largest civic society did not formally object to the 2025 scheme. Faced with the identical building resubmitted as 26/02109/FUL, it does. CPPF aligns itself squarely with Historic England, whose advice it says the College has simply ignored: "in view of the legal challenge that proper consideration was not given to this advice, we are disappointed that this guidance has been ignored, and that no amendments have been made."

The society traces the bulk to the removal of the basement

The society traces the building's bulk to a single cause: "while the removal of the 2016 scheme's full basement was framed as a sustainability benefit, it has forced the building to expand upward to maintain internal capacity." The result, it concludes, is "multi-layered harm to highly sensitive designated heritage assets" that "stands in conflict with Policy 61" of the Cambridge Local Plan. It sets out three separate breaches: a "failure to preserve or enhance" the setting of the Grade I Bodley Library; an "inappropriate street profile," with ventilation stacks that will "overwhelm the modest scale of Christ's College's historic streetscape, notably Christ's Lane"; and "unjustified heritage harm" across the Bodley, Bath Court and the Central Conservation Area, where "the minimal public benefits identified here fail to outweigh these costs" under Policy 61 and paragraph 206 of the NPPF.

The society says a lower and less bulky design is achievable

The society's conclusion is that a better scheme is plainly available: "a deliverable, contextually sensitive alternative that honours the human scale of Christ's Lane is entirely achievable." CPPF urges the applicant and Council to "negotiate a lower and less bulky design."

Read Cambridge Past, Present & Future's objection (9 July 2026).

The Council's own officer finds harm, states its degree only after the benefits, and confines it to a stair tower without reasons

The Council's conservation officer's comments of 26 August 2026 (register document 9505685) are marked "No objection" on their first page. On their fourth page they find: "The harm to heritage assets is considered to primarily relate to the setting of the Bodley Library, which forms part of the grade I listed asset 'buildings surrounding Entrance (First) Court with the south-east range of Second Court'. The harm arises from the relative scale and proximity of the stair tower." And: "When considering the above heritage effects with reference to NPPF policies HE4 (1, 2), HE5 (1-4), HE6 (1-3) and HE9, the positive effects are not considered to fully outweigh the harm. On balance, the harm is considered to be at the lower end of the scale, and therefore NPPF policy HE6 (4) is engaged."

The degree is stated only after a benefit the Council conceded was an error

The degree is stated only "On balance", after four "positive heritage effects" have been set against the harm. The Framework's policy HE5(2)(c) says: "The degree of harm should be identified"; a balance is not an identified degree. One of the four effects is "Sustaining the ongoing use and conservation of the grade I listed building by providing improved, accessible library facilities." That is the consideration the Council conceded in the High Court it was an error to weigh: the buildings have been in collegiate use for five centuries, and the applicant's own Planning Statement says at paragraph 7.99 that "staff and student numbers will remain as per existing". The third ground of the judicial review, R (Christ's Lane Action Group) v Cambridge City Council, Christ's College Cambridge interested party, AC-2025-LON-004656, began in this office: its response of 18 September 2025 said that "the works overall would help to secure the building's optimum viable use", and the 2025 report carried it into the balance. Another of the four is an enhancement to the Central Conservation Area, a benefit to a different asset, measured against the 1970s library the scheme demolishes. The report adopts the net figure as "low" (16.35) and weighs "the identified low level of harm" against the public benefits (26.34).

The comments find the harm in the stair tower and give no reason for the narrower finding

The harm is located in "the relative scale and proximity of the stair tower" where Historic England found it in "the excessive bulk of the new building", to "the setting of the surrounding buildings". No reason for the narrower finding is given in the comments or in the report. The conservation officer told the Committee on 7 October that Historic England's "comments are broader" and that its "views are their independent views. I won't seek to justify or explain those". The Amendment Sheet says: "Updated comments from the Council's Conservation Officer are not required."

Read the conservation officer's comments of 26 August 2026, and our letter to the conservation officer of 25 September 2026.

The four grounds of the judicial review are four misstatements of this harm to members, and the 2026 report repeats each

The claim is R (Christ's Lane Action Group) v Cambridge City Council, Christ's College Cambridge interested party, AC-2025-LON-004656. On 28 April 2026 the Council and the College signed a draft consent order agreeing that the permission of 7 November 2025, 25/02161/FUL, be quashed on all four grounds. We did not sign it, so that the grounds are heard by a judge in Court. On Tuesday 20 October 2026 the Court set aside, on our application, its order of 25 August 2026, which had approved the draft consent order we had not signed, and quashed the permission on all four grounds of our claim. The hearing took place in Court 18 at the Royal Courts of Justice, before Mr Justice Kolinsky, in R (Christ's Lane Action Group) v Cambridge City Council, AC-2025-LON-004656, in the Planning Court. The Council's report of 28 September 2026 says at paragraph 1.15 that "the Council and the Interested Party have conceded in writing to all four grounds of challenge". Each ground is an error in how this harm was assessed and weighed in the report on which the first permission, 25/02161/FUL, was granted, and each is repeated in the report of 2026.

1 Historic England found harm. The report told members that, in line with comments received from Historic England, there was no overall harm. Historic England wrote on 29 July 2025 that "the building is too big for its location" and that the proposals would cause harm "primarily as a result of the excessive bulk of the new building". The report's conclusion at 14.33 told members: "In line with comments received from Historic England and the Council's Conservation officer, who raise no objection to the development, the development is not considered to result in any overall harm to the relevant heritage assets, applying paragraph 215 of the NPPF". Our claim: "This was factually incorrect, and positively misleading." The ground: "The Committee was materially misled as to Historic England's advice."

In 2026 the report as published put Historic England's name to the officer's own figure at 1.25 and 16.38, and the Amendment Sheet withdrew both two days before the vote, "to clarify that the level of harm is an assessment of the officer and not Historic England".

2 The report found harm to the Grade I listed Bodley Library and told members, in the same paragraph, that the overall impact was neutral. At 14.31 the report found "a level of harm identified to the highly significant Grade I listed Bodley Library" and concluded: "The overall impact upon the relevant listed buildings is therefore considered to be neutral". At the meeting the officer said "the overall harm is considered to be neutral" and, in the same answer, "because there is harm identified, public benefits need to be provided". Our claim: "These two conclusions are logically inconsistent." The ground: "The Committee was materially misled as to the existence and/or extent of harm to the significance of designated heritage assets."

In 2026 the 2025 error is repeated: the conservation officer and the case officer give members different accounts of how the one figure, "low", was reached. The conservation officer's comments reach it "On balance", after four positive heritage effects are set against the harm (6.14). The report states the same figure before the benefits (16.35), and no sentence says how it was reached. On 7 October the case officer told members: "I set out the level of harm prior to assessing heritage benefits". The conservation officer called the figure "the balance". No consultee put the harm at "low" before the benefits: Historic England wrote of "certain levels of harm" from "the excessive bulk of the new building" (29 July 2025) and gave no degree; the Victorian Society said "low-to-moderate"; the independent heritage appraisal on the register "upper end". In April 2026 the Council conceded before the Court that advice giving the harm and "neutral" at once was an error. The 2026 report gives one figure that is a balance in one officer's account and the harm before the balance in the other's, and the degree before any weighing is on no document.

3 Members were told the library would "help to secure the listed building's optimum viable use". The listed buildings have been in that use for five centuries; the Council conceded this was an error, and then it proceeded to repeat the error. "Optimum viable use" is a term of the heritage guidance for a listed building whose upkeep depends on finding a use that pays for it; securing such a use is a public benefit that can be weighed against harm. The 2025 report told members at 14.19 that the library "would help to secure the ongoing use of the listed buildings for their intended, educational use" and at 14.31 that it "would help to secure the listed building's optimum viable use". Our claim: "There can be no question that the optimum viable use of the listed buildings as an educational institution is already secured". The ground: "The Committee took into account an irrelevant consideration - optimum viable use ('OVU')."

The 2026 report says at 1.12 that the point "is not, therefore, relied upon", and at 26.25 counts "improved, accessible library facilities" that "would help to support and sustain the ongoing use of the Grade I listed College buildings" among the social benefits, to which 26.26 gives "significant weight". The words have changed and the benefit claimed is the same: the continued use of buildings whose use was never in question.

4 The Council had twice consented a lower library on this site. Members were told to assess the scheme "on its own merits" and were never asked whether the lower design would avoid the harm. The Council granted permission for Rick Mather Architects' design, with a basement, in 2013 and 2016, and its report of 2016 found: "The proposed new library would meet the needs of Christ's College". The 2025 report "said nothing whatsoever about the 2011/2016 schemes, whether in the context of OVU or generally" (our claim, paragraph 81); the officer's amendment sheet for that meeting told members "the current proposal must be assessed on its own merits". The ground: "The Committee failed to take into account a relevant consideration – the existence of less harmful alternative modes of development."

In 2026 the report tests the alternatives for "viability and prospect of implementation" (16.52), gives the consented design "very limited weight" because "The applicant has made the case that this previous scheme is no longer viable for the College" (16.57), and concludes that none of them "carry any notable weight" (26.33). The report takes into account the College's letter about its masterplan, not the masterplan (16.63 to 16.66).

Read the four grounds

Four independent authorities examined this building, the Government's own heritage adviser, a statutory consultee, Cambridge's largest civic body, an independent expert of fifty years' standing.

All four found the same thing: harm to Grade I heritage, caused by a building that is "too big," "overdominant," an "overpowering mass of masonry" that is "grossly disproportionate."

What experts call harm. The college terms a benefit.

Not one of the four assessors was answered: "the overall massing of the building remains unchanged". The College has resubmitted that identical, unchanged building and asks the Council to accept that it causes no heritage harm at all. Identical application 26/02109/FUL controversially approved on 7 October.

Where things stand

Sources: Historic England, 29 July 2025 (register document 9457102, filed again 8 July 2026 as 9457100) and 1 September 2025 (9457105); Historic England, 27 August 2026 (9508056); the conservation officer, 26 August 2026 (9505685) and 18 September 2025 (7370966); the Victorian Society, 22 August 2025 (7355397), 6 July 2026 (9455369) and 9 July 2026 (9464487); Cambridge Past, Present & Future, 9 July 2026; Alec Forshaw, the appraisal of October 2025 (9458570) and the comments of 5 October 2026 (9545338); the covering statement (9423967); the Planning Statement; the harm register, 25 September 2026.