LISSCA (Liverpool Street Station Campaign), a coalition of conservation groups which includes SAVE Britain’s Heritage and The Victorian Society, commissioned carbon expert Simon Sturgis to interrogate the Network Rail-backed application submitted in April.

Despite significant changes to Herzog & de Meuron’s original and subsequently scrapped plans, heritage campaigners remain opposed to the ‘hugely damaging’ internal and external changes to the Grade II-listed station, as well as the proposed 18-storey office tower over the terminus.

Now they claim Sturgis’s in-depth embodied carbon assessment (see attached document below) shows the application for the £1.5 billion scheme, which includes ‘extensive demolition’, should be rejected on environmental grounds.

According to the architect, who heads carbon consultancy Targeting Zero, the proposals breach ‘a significant number of national and local environmental policies’ and ‘fail’ against the latest industry benchmarks for carbon emissions.

He believes the application uses such flawed methodology that all carbon assessment figures contained in the planning application should be considered invalid.

The current proposals, Sturgis says, fail to meet current sustainability and energy efficiency standards, ‘let alone those likely to be in place on completion in 2036’.

The report reads: ‘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 2,200 kgCO2e/m2 GIA. This is approximately what you would expect of an equivalent office building built in circa 1990.’

He adds that the over-station development has an ‘inefficient layout with a sub-optimum wall-to-floor ratio’ and will require a ‘massive, high-carbon transfer structure’ to build over the station concourse which ‘adds 25 per cent to the carbon cost’.

Sturgis also questions whether retrofitting options for 50 Liverpool Street have been properly looked at.

Network Rail disputes the findings.

James Hughes, director of the Victorian Society, which had already voiced its opposition to the plans said: ‘This report shines a stark and revealing light on one of the profound shortcomings of the Liverpool Street 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, added: ‘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.’

Network Rail had hoped the reworked proposals would allay some of the concerns raised about the initial plans.

ACME’s 98m-tall scheme , with its outdoor garden terraces, is slightly shorter than Herzog & de Meuron’s abandoned 15 and 21-storey designs, which received more than 2,200 objections, including from Historic England.

The submitted scheme features yellow brick vaults at office and station entrances which ‘closely relate to the original part[s] of the station’, according to planning documents.

ACME’s validated Liverpool Street application (May 2025)

Unlike the previous plans, ACME’s proposals also leave the Grade II*-listed Great Eastern Hotel untouched while the Hope Square entrance has been designed to create a ‘civic gateway into the City of London’, which also ‘brings development back to the historic building line’ from pre-1874, when the station was built.

ACME was appointed to the scheme last year following controversy around the size of the Herzog & de Meuron scheme. Developer Sellar also exited the project at the same time, with Network Rail’s property arm taking over.

Both proposals involve demolishing much of the now-listed 1990s concourse.

The Herzog & de Meuron team has subsequently drawn up all-new proposals, undertaken without a commercial development partner and currently entirely speculative, which would raise the over station scheme on stilts (see Return ticket: Can Herzog & de Meuron make a Liverpool Street comeback?)

Herzog & de Meuron’s 2023 Liverpool St scheme vs ACME’s April 2025 proposals

Network Rail, the station owner, said in April that the submitted scheme was better ‘realigned’ with the existing station architecture than earlier proposals. The building dates back to 1875 with a 1990s extension that was listed in 2022.

Explaining the design ACME founding director Friedrich Ludewig added at the time of the planning submission: ‘We have embraced the challenge to design new entrances reflecting its position as the UK’s busiest train station, and roof structures that speak to the original 1875 structures and the 1990s extension.

‘We are retaining the essential qualities of the existing station, celebrating elements that were previously hidden, creating sustainable new workplaces and providing spaces to expand into for generations to come. Liverpool Street station will become the world-class transport hub that the City of London and all Londoners deserve.’

Response from Network Rail

As Britain’s busiest station, Liverpool Street is long overdue the transformation it deserves. No other development makes such a vast contribution to reduce the carbon footprint in London through the significant upgrade to allow more customers to travel more sustainably.

This investment in sustainable transport will allow the station to grow from 115m to 150m passengers per annum and beyond while enhancing accessibility for all. This equates to 2 billion additional passengers undertaking sustainable transport journeys over the next 60 years.

Network Rail’s planning application:

proposes a new office building in the most-connected location in London, sited directly adjacent to the UK’s busiest transport hub
is designed to emit no carbon in use and use low carbon materiality in construction
will utilise all proceeds from the development to fund transport improvements for the Network Rail and TfL station which are vital for the Capital’s infrastructure.