A report from the Greater London Authority’s (GLA) London Review Panel in late 2024 recently discovered by the AJ raised ‘significant concerns’ about the huge overhaul of the terminus and over-station development. The plans were approved by the City of London in February.

In the report, unnamed members of the London Review Panel outlined concerns over several elements of ACME’s designs, including the station entrances, scale, commercial units, public realm and carbon cost. The panel ‘strongly’ recommended changes to the scheme and a follow-up design review.

However, the AJ understands the late 2024 review was the only GLA review of the ACME proposals before Network Rail’s planning submission in spring 2025.

‘While the reduced height from previous schemes is noted, the panel remains unconvinced that the scale is appropriate and would welcome further justification that the massing of the building is the right approach in this context’, said the report.

It added: ‘The panel strongly recommends revisiting several aspects of the proposal to address identified shortcomings and deliver a project that reflects the site’s importance as a gateway to London […] Further engagement with the panel is encouraged to address their concerns.’

While some concerns raised by the London Review Panel appeared in the City of London’s officer’s report ahead of February’s planning committee hearing, the full design review was not included in the agenda pack, nor was it published on the corporation’s own planning portal. None of the groups opposing the scheme contacted by the AJ had seen the full document.

‘The panel remains unconvinced that the scale is appropriate’

The AJ understands the full London Review Panel report was uploaded to the GLA’s website in December 2025, a year after the panel took place and just weeks before the planning decision.

In response, The Twentieth Century Society (C20) told the AJ: ‘So now we know. The mayor’s own expert, independent review panel strongly expressed their view that the proposed office block at Liverpool Street station “lacks clear justification” and they “remain unconvinced that the scale is appropriate …[or that it] is the right approach”.

‘Most unambiguously, the panel “acknowledges the need for improvements and upgrades to Liverpool Street Station [but] questioned whether this scale of intervention is necessary to achieve the desired operational improvements for the station”.’

Heritage groups told the AJ that Network Rail continued to refuse to share details of a baseline scheme of station improvements against which the ACME proposals with overhead development could be tested. Network Rail told the GLA’s independent review panel this scheme exists but has not been shared.

A spokesperson for the Victorian Society, which leads the Liverpool Street Station Campaign (LISSCA), a group of mainly heritage bodies opposing major redevelopment of the station, said: ‘The London Review Panel exists to advise the mayor on projects of strategic importance to London.

‘In this case its advice was clear: while (like the Victorian Society) it actively supported the principle of improving the station, it nonetheless raised significant concerns about the scale, massing and justification of the over-station development and questioned whether that level of intervention was necessary at all.

‘The panel also identified a wide range of unresolved issues – including heritage impact, public realm, daylight, environmental concerns and design quality – and explicitly called for the scheme to be revisited to address these shortcomings. In addition, despite the fact a baseline scheme was requested (and said to have been commissioned by Network Rail), that has never been released.’

ACMEs submitted Liverpool St scheme

The Victorian Society added: ‘Set against the unprecedented level of public opposition, it is striking that concerns about the scheme extend not only to heritage bodies and the public, but also to the mayor’s own independent design advisers.’

Meanwhile, SAVE added in comments to the AJ: ‘The report by the mayor’s independent design experts highlights a number of “significant concerns” around the justification, design and heritage impacts of this highly contentious scheme that echo those raised by SAVE and other national organisations since the plans were first revealed.

‘Like us, they also asked to see a study showing improvements to the station independent of commercial development to provide a baseline against which the proposals could be tested. The panel strongly felt further consultation with the panel was needed.

‘The report raises a number of important questions: did Network Rail’s project team provide the panel with the information they requested and engage with them further as they asked for? Why weren’t these views of the panel included in the City of London’s report and recommendation to councillors as part of the planning process?’

The GLA was consulted alongside other statutory consultees, such as Historic England and St Paul’s cathedral, which also raised concerns about the scale of the over-station development. The AJ understands Network Rail’s own internal review processes raised concerns. However, details of those findings are unknown.

‘The report raises a number of important questions’

Last month, the AJ reported that the ACME scheme was subject to a legal letter raising concerns about Network Rail’s procurement of the practice to the job – replacing Herzog and de Meuron, developer Sellar and transit operator MTR – and the funding for the new designs.

C20, the Victorian Society and SAVE have all called on Khan to rule on the scheme and refuse the proposals on the basis that ACME’s designs would introduce harm to built heritage and cause a decade of unjustified disruption for commuters, while requiring a 97m-tall office tower over the concourse to fund around £500 million of improvements to the station.

A spokesperson for Network Rail insisted feedback from the GLA’s panel on ACME’s initial designs had informed the final submission.

Resulting amendments included changes to the entrances, an increase in the number of escalators, larger lifts for wheelchair users, wider staircases, bus station access and better integration with surrounding public spaces with a clear wayfinding strategy.

A spokesperson for Network Rail said: ‘The GLA’s London Review Panel formally reviewed the emerging Liverpool Street station design at Stage 1.

‘Network Rail and its design team used the panel feedback, along with other stakeholder comments, to evolve the scheme. The final design submitted to the City of London in April 2025 comprehensively responds to suggestions made in the report.’

They added: ‘Following positive determination by the City of London’s planning committee, we will continue to engage with the GLA as part of its Stage 2 process.’

ACME’s submitted Liverpool St scheme (April 2025)