Specialist carbon report commissioned by the LISSCA coalition finds that a 19-storey tower proposal over Liverpool Street Station breaches a significant number of national and local environmental policies.
Network Rail and Acme architects’ controversial tower block proposals for Liverpool Street Station, which would bulldoze the celebrated concourse, should be thrown out by the City of London planning committee, a leading carbon expert has warned.
In a detailed technical report commissioned by LISSCA (Liverpool Street Station Campaign) to examine the carbon impacts of the proposals, Simon Sturgis, managing partner of Targeting Zero and a government adviser on sustainability, finds that the proposed scheme:
- Represents “a huge and unnecessary waste of resources” proposing extensive demolition of useable station fabric and failing to examine retrofitting options for 50 Liverpool Street in any detail
- Is not compliant with a significant number of UK and London carbon emission-related environmental policies and fails against the latest industry benchmarks for carbon emissions – by as much as 33%
- Uses such flawed methodology that he concludes all carbon assessment figures contained in the planning application should be considered invalid and the “submission should be rejected on this basis”
- Is “likely to be commercially redundant on completion”, performing poorly against national and local net zero targets
Sturgis’s report, published on 28th August, states: “This proposal shows minimal ambition or intention to meet current best practice in terms of low carbon construction, or the UK’s trajectory to net zero.
It adds: “This submission is essentially the same as buildings designed in the last decades of the 20th century, showing no significant evidence of meeting current policies… The overall whole life carbon figure for the submission is 2,200kgCO2e/m2 GIA, this is approximately what you would expect of an equivalent office building built in circa 1990.”
The report criticises the inefficient layout and “completely unsustainable design approach” – including a poor wall to floor ratio and a facade that would have to be replaced every 30 years – which means the “building is likely to be redundant on completion.” He explains: “Occupier and investor awareness of ESG issues is increasing, and therefore buildings such as this which have not evolved meaningfully past 20th century office design are highly likely to be downgraded in value.”
James Hughes, director of the Victorian Society said: “This report shines a stark and revealing light on one of the profound shortcomings of the Liverpool Street Station scheme. Network Rail claims that its scheme is environmentally exemplary. What this report demonstrates is that the scheme is anything but. It fails to abide by local and national policy, is environmentally backward, and would be redundant upon completion. On this basis alone it should be rejected.”
Henrietta Billings, director of SAVE Britain’s Heritage, said: “It is shocking that a building designed in 2025 should be based on a 1990s rationale. The design and construction industry has made huge strides in the face of the climate emergency and there is no longer any excuse for last-century thinking. We urge the City of London to give this application the short shrift it deserves.”
Failing net zero
In the report, Sturgis states that in light of the UK government’s legally binding commitment to net zero by 2050, and the City of London’s target for 2040, significant changes are required to office design to meet these targets.
The proposed over-station office development, however, requires a “massive high carbon transfer structure” to build over the station concourse which adds 25% to the carbon cost. Sturgis concludes that this building was not designed to meet best practice and current policies and targets for net zero.
The report’s findings are in stark contrast with Network Rail’s claims that this building will “be net zero carbon in operation and to achieve the highest level of environmental performance in one of the most sustainable locations in the country.”
‘Not commercially viable’
Network Rail say the tower is needed to pay for station upgrades, but its own advisors have admitted in the planning application documentation the £1bn scheme is “not technically viable” without an upswing in the market to cover a £220m shortfall. Meanwhile, more than 2,000 people have already written to the City of London Corporation to object to the plans.
About the author of the report
Simon Sturgis is Managing Partner of Targeting Zero, and a member of the Construction Industry Council (CIC) Climate Change Expert Panel, the British Council for Offices Sustainability Group and was a Sustainability Advisor to the RIBA Stirling Prize (2017/18). He is an advisor to the EU Commission, Green Construction Board, RICS and the Building Research Establishment.
How you can help:
A committee date has not yet been set for the City to determine the planning application. This means there is still time to have your say and submit your comments to the City of London.
Email the Local Planning Authority at [email protected] including planning application reference 25/00494/FULEIA to make your views known.
The fundraiser to Save Liverpool Street Station remains open to fund legal and other fees for this campaign.
Visualisation shows Network Rail and Acme’s plans for the entrance on Liverpool Street.
