The Curious Case of the City Hall Listing

Usually, when I advise clients on the merits of submitting an application for a Certificate of Immunity from Listing (COIL), I explain that the risk is that if it is not granted, then the building will automatically be listed. Not so for City Hall.

In July 2022, the Secretary of State for Digital, Culture, Media and Sport (DCMS) refused a request to grant a certificate promising not to list City Hall for 5 years, but it has not been listed, which is very unusual.

City Hall was constructed as the offices for the Greater London Assembly (GLA) to designs by Fosters & Partners, opening in 2002. The design was inspired by Foster’s work on the Berlin Reichstag (1999), and the architecture intended to convey the democratic values of the GLA: transparency, accessibility and openness.

In 2014, the More London Estate, including City Hall, was sold to the Kuwati-backed St Martins Property Group, from whom the GLA leased the Hall. In January 2022, the building was vacated, and in response to this, the Twentieth Century Society requested it be listed, which was rejected by DCMS (advised by Historic England) in March 2021.

One would have thought that in these circumstances, a COIL would be forthcoming, but not so. Historic England’s 2022 report concluded that it was too soon to fully assess the architectural significance of City Hall. The DCMS guidance on the Principles for the Selection for Listed Building (2010) states at paragraph 24 that in: “exceptional circumstances” they can neither grant the COIL, nor list the building.

Since then, St Martins Property has appointed Gensler architects to draw up proposals which replace the façade, add external balconies and create a more efficient floorplate with the removal of the helical main stair.

After engaging in pre-application discussions, the Twentieth Century Society has again put the building in for listing, which has recently been rejected for a second time.

DCMS rightly consider that some time needs to elapse in order to properly appraise the quality of new architecture in its historical context, so only buildings of the highest interest (at grade I or II*) can be listed if they are under 30 years old.

Reading between the lines, the rationale seems to be that given City Hall was constructed in 2002, so in the last 30 years, it would need to be Grade I or Grade II* to be listed now and does not meet this threshold. This indicates that DCMS (or rather its advisor, Historic England) think it could be listable at grade II, albeit they would need to wait until 2032 to do this, so they were reluctant to grant a COIL. This is somewhat of a paradox because a COIL only commits them to not list the building for 5 years.

Whether this is truly an exceptional circumstance is questionable. Nevertheless, City Hall remains unlisted for the time being.

This article was prompted by a recent piece from Architects’ Journal HERE.