,*UBS UBS Investment Bank1 Finsbury AvenueLondon, EC2M 2PPTel. +44-20-7567 8000ww.ubs.com

Carsten KengeterChairman and Chief Executive OfficerMember of the UBS Group ExecutiveBoardTel: +44-20-7567-9005Fax: +44-20-7568-0182Email: carsten.kengeter@ubs.com

By email and post

Confidential

The Rt Hon Jeremy Hunt MPSecretary of State for Culture, Olympics,Media and SportDepartment for Culture, Media and Sport2 - 4 Cockspur Street

LondonSW1Y 5DH

CC: Rt Hon George Osborne MP

Rt Hon Vince Cable MP

3 (f~ 20\\Your ref: 17717Our ref: 20110531_DCMS_5BG

Dear Mr Hunt

PLANNING (LISTED BUILDINGS AND CONSERVATION AREAS) ACT 1990BUILDINGS WITH SPECIAL ARCHITECTURAL HISTORIC INTEREST

BROADGATE PHASES 1-4 (NOS 1-2,3,4,6 AND 8-12 BROADGATE AND 100LIVERPOOL STREET, INCLUDING THE OCTAGON ARCADE, THE BROADGATE CIRCLEAND STAGE AREA, THE SCULPTURES "FULCRUM", "LEAPING HARE ON CRESCENTAND BELL", "GO BETWEEN" AND "GANAPATHI AND DEVI", AND THE ASSOCIATEDPAVING AND LANDSCAPING), CITY OF LONDON, GREATER LONDON

I understand that you have recently received, or will shortly receive, a recommendation fromEnglish Heritage regarding the potential listing of the above buildings and structures.

UBS is a longstanding and committed supporter of London. To list the buildings would haveserious consequences for both UBS and we believe, the City as a whole.

We have been working on the proposal for a new UK headquarters at 5 Broadgate foralmost 5 years and have contractually committed to lease the new building, which weintend to fully occupy. The proposals, which received the unanimous support of the City ofLondon Planning Committee and were subsequently endorsed by the Mayor of London, areready to proceed. Subject to your decision regarding listing, work will start on site in thenext three months.

UBS Investment Bank is a business group of UBS AG

UBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares. incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1. CH-4501, Basel and Bahnhofstrasse 45, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

Our representations to English Heritage (submitted on 17 May in response to their recentconsultation) consisted of an Assessment prepared on our instructions by leadingarchitectural consultant, Professor Robert Tavernor, as to the merits of listing BroadgatePhases 1-4. Professor Tavernor's Assessment (including details of his qualifications andexperience) is enclosed with this letter for your ease of reference.

When considering your decision as to whether or not to list these buildings, you will ofcourse have to assess whether the buildings are of special architectural or historic interest.Further, given that the buildings are less than 30 years old, in order to list the buildings theyneed to meet the policy criteria which make it clear that any building which is less than 30years old should normally be of "outstanding quality" and under threat.

In this respect, Professor Tavernor concludes:

" ... my opinion is that Broadgate Phases 7 -4 are not of "outstanding quality" anddo not possess sufficient 'special interest' - architectural, historic, or group value -to warrant their listing"; and" ... for all the reasons stated above, it is my consideredopinion that Broadgate Phases 7 -4 do not make the grade for listing on any level" .

Having taken advice from a number of consultants we agree with the conclusions ofProfessor Tavernor and do not believe that a decision to list at any Grade can be the rightone. The Broadgate scheme was intended to be flexible and adaptable and to be able toprovide for the needs of global financial institutions such as UBS. This is no longer the caseand the buildings need upgrading and/or replacing in order to remain attractive foroccupiers such as us. After full consideration by our own technical teams and in consultationwith various building owners, we have concluded that such upgrading and/or replacingwould not be feasible. To list the buildings would therefore have serious consequences forUBS and, we believe, the City as a whole.

If the proposed development of 5 Broadgate has to be abandoned because 4 and 6Broadgate (and/or any of the sculptures that are to be relocated as a result of thedevelopment) are listed, we will have to find alternative future accommodation that we canoccupy by 2016. We do not consider this to be feasible given the scale and nature of thespace required. Such a decision would force us to fundamentally reconsider our occupationstrategy in London.

UBS has a long-history with Broadgate, as one of the original occupiers and is proud to be amajor supporter of the arts in London. Our relationship with the London SymphonyOrchestra dates back to 1987 and now includes sponsorship through the UBS Soundscapesconcerts and support for the LSO 'On Track' programme - a grass-roots young talentprogramme enabling children from deprived backgrounds to engage in music making. Ourarts sponsorship also focuses on the developing arts scene in Shored itch, immediately to thenorth of Broadgate.

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4S01, Basel and Bahnhofstrasse 4S, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

We have also developed deep links with the local community and operate one of the City'slongest standing and most highly acclaimed Community Affairs programmes. Our flagshipproject in London, The Bridge Academy which opened in 2007, is widely acknowledged as aleading example of an education / business partnership - indeed it was extolled as such onlylast week by the Minister for Schools. In addition to our financial contribution and ongoingdeep involvement in its governance, over 1,500 UBS volunteers have participated in theproject since its inception. Many of these links would be difficult to maintain in their currentform if UBS were forced to relocate from the City of London.

As you are no doubt well aware, the Chancellor of the Exchequer said in his BudgetStatement that "we want the City of London to remain the world's leading centre forfinancial services". He also said that the Government would tackle the planning system as itis "a chronic obstacle to economic growth". 5 Broadgate represents a combined investmentin excess of f850m, by UBS, British Land and Blackstone in the City and will generate asignificant number of constructions jobs over the next 3-5 years (equivalent of 5,000 personyears of effort for shell & core construction alone). Listing Broadgate Phases 1-4 would seemto contradict the Chancellor's statements on both counts.

In light of our serious concerns, I wanted to send you the attached memorandum, whichcontains more detail of the consequences to UBS of a decision to list. In summary, ourargument centres on the following key points:

. The buildings do not meet the architectural or historic criteria for listing

. The existing buildings cannot be upgraded to meet our requirements for resilience,

security and sustainability

. There are no suitable alternatives that could be occupied before 2016

. Listing would prevent investment in excess of f850m which in turn would generate a

significant number of construction jobs over the next 3-5 years

. The move is contrary to the government's growth agenda and would impair the City'sability to attract and retain global financial organisations like ours.

If there is anything else that I can personally do to provide more clarity on the issue,including a meeting if necessary, then please feel free to contact me directly. My officewould also be happy to provide any further details you may require. I have asked NigelMorley (NìgeI.Morley@ubs.com, 020 7568 0522), to provide whatever information isnecessary.

I very much look forward to hearing from you.

Yours sincerely, .#

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4501, Basel and Bahnhofstrasse 45, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

Listing of Broadgate Phases 1-4 - Memorandum on Consequences

1.0 UBS and the Broadgate Estate

UBS is a premier global financial services company which provides wealth management,investment banking, asset management and business banking services to our clientsthroughout the world. We have over 7,000 employees and c. 3,000 external staff andcontractors currently working in or around our Broadgate Campus of five buildings, wherethe origins of our occupation began in 1984.

Of the buildings you are now assessing, UBS currently occupy parts of 1 & 2 Broadgate, thewhole of 100 Liverpool Street and 8-10 Broadgate. Until very recently it also occupied partsof 6 Broadgate, which it vacated in order to facilitate the development of 5 Broadgate. Theonly office buildings in the current assessment that UBS have not occupied are 3 and 4Broadgate; the latter is now of particular interest, however, given its proposed demolition toaccommodate the development of 5 Broadgate.

2.0 The Need for a UK Headquarters Building

The buildings we currently occupy on the Broadgate Estate are ageing, fragile ofinfrastructure, inefficient (our operations are split between five separate buildings), and donot meet the operational standards required by our business going forward, particularly interms of resilience, security and sustainability (see below).

Our requirement for a new UK headquarters building was identified primarily toaccommodate our investment banking operations, for which we need to house up to 3,000trading floor staff in a single building. That trading function would occupy up to 50% of anynew building. The single building will also accommodate other client facing functions whichwould benefit from being adjacent to and in the same building as investment banking, forexample corporate finance, wealth management and others.

After full consideration by our own technical teams and in consultation with various buildingowners, we have concluded that our immediate and long term requirements for resilience,security and sustainability (which are not in our opinion exceptional for a major tradingenvironment) cannot be met through a refurbishmenVupgrade of our existing buildings, norby a speculative development: they can only be met by a purpose designed building. Webriefly address each of these requirements in turn below:

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4501, Basel and Bahnhofstrasse 4S, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

2.1 Resilience

Resilience is the "fallback" capacity of the building services to continue to operate inthe event of failure due to internal or external factors. It is fundamental to thetrading environment in order to mitigate the major business risks that would arisefrom any interruption both to critical and other operations. The plant and systemsserving the trading floors and critical functions (where energy demands arematerially higher than those for standard speculative office space) will therefore beprovided in duplicate at 5 Broadgate in many instances. This will require a plantprovision of nearly 30% of the gross external area compared to that in a speculativebuilding, which is usually in the range of 10-15%.

A requirement for this level of resilience is not unusual for our type of business.Indeed other emerging requirements from competitors in London are for an evengreater resilience throughout entire buildings, not just the trading floors and othercritical areas.

2.2 Security

Security risks have increased dramatically over the last 20 years or so. Modernrequirements, account of which must be taken in any base building design (manycurrent measures cannot be easily retro-fitted), may include enhanced façade designto incorporate a level of blast protection, high level air intake positions, and externalbarriers to prevent vehicle impact and reduce the potential threat of vehicle-borneexplosive devices. All three are fundamental both to UBS's requirements and toother similar users.

4 and 6 Broadgate (and so 5 Broadgate) are not above stations/transportinterchanges or above underground lines, unlike for example 100 Liverpool Streetand 8-10 Broadgate, where UBS occupation was seriously affected during theterrorist incidents of 7 July 2005 when a full evacuation was required.

2.3 Sustainability

Sustainability and environmental performance are now very material considerationsfor all developers and occupiers, in terms of the construction and actual use of officebuildings. UBS, in common with other global financial organisations, takes itsresponsibilities in this regard seriously and its own policies are summarised in our2010 Annual Report, which is accessible on our website (www.UBS.com) under thesection entitled" About Us / Corporate Responsibility" and more particularly theheading "Corporate Responsibility in Operations".

5 Broadgate has been rigorously designed to achieve a very high sustainabilityperformance. UBS believe that it will become increasingly difficult to achieve similarstandards in any refurbishmenVupgrade of our existing Broadgate buildings,certainly in the long term, and not without changing their external appearance andsignificantly compromising existing structures.

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4S01, Base! and Bahnhofstrasse 45, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

3.0 The Character of Broadgate and the Consequences of Listing

The phases of Broadgate under current consideration were designed specifically toaccommodate the UK headquarters requirements of financial institutions as envisaged at thetime of Stock Exchange Deregulation in the mid to late 1980s. At that time, tradingoperations were limited to two floors whereas a much greater proportion of any tradingbuilding is now required for such use - approaching 50% in the case of 5 Broadgate.

In UBS's opinion, the buildings are no longer suitable for such purpose without majorchanges to meet modern requirements, and even then they would not compare well withnew build opportunities. In terms of unit size, the buildings were arguably outdated by thetime they were constructed in that both 1 and 2 Broadgate and 100 Liverpool StreeV8-1 0

Broadgate were designed as two buildings but were in fact first occupied as one.

As the global importance of London as a financial centre has increased over the years, banksand other financial services companies have expanded and there are now several users whohave, or potentially need, a single building of 700,000 sq ft (the approximate net internalarea of 5 Broadgate) or more. Those in the same business as UBS are likely to have similarrequirements for resilience, security and sustainability (see section 2 above).

Listing will mean that Broadgate Phases 1-4 will not be able to meet the flexibility andadaptability requirements of major financial institutions that trade in securities. Broadgate asa location has become a success due to the nature of occupiers that have been attracted tothe location. If listed, the likelihood of such occupiers remaining long term in Broadgatemust be questioned.

4.0 The Consequences of Listing for UBS

4.1 Impact on Current Occupation

Given the requirement to obtain listed building consent for any works which affectthe character of a listed building, listing the buildings under current considerationwould have a significant practical impact on the operation, adaptation and ongoingmanagemenVmaintenance of our current Broadgate buildings.

Whilst we understand that a building included on the statutory list does notpreclude alterations to the building, given the volume of changes that are made onan ongoing basis to UBS buildings in and around Broadgate (in excess of 30 projectsper year) this impact (both administrative and timing) would be untenable and UBSwould be forced to vacate.

We believe that the constraints imposed by listing would be unacceptable to anymajor financial services occupier. This is particularly the case as the buildings atBroadgate are ageing and will require significant upgrading for any user in the nearfuture. Such works will become significantly more complex if the buildings are listed,such that they will cease to be a viable option for us and others.

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offces are at Aeshenvorstadt 1, CH-450l, Basel and Bahnhofstrasse 45, CH-800l Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

We note that in certain circumstances concerns over adaptations to buildings in thenormal course of use and occupation can be lessened by the use of a managementagreement with the local authority, making clear the nature of works thatwould/would not require listed building consent. We became familiar with such anarrangement in the advice given to us at the time of the aborted attempt to list 1Finsbury Avenue in 1997/98. However, the continually evolving nature of ourbusiness is such that, even with such an agreement in place, the listed buildingrequirements would simply be too restrictive to make Broadgate a viable location forus in the future.

4.2 Impact on Future Occupational Requirements

Broadgate, with its transport links and amenities in the heart of the City of London,but located outside the extensive network of City conservation areas that imposerestrictions on redevelopment is now one of the most important commerciallocations in the City of London.

We have spent a considerable amount of time assessing alternative sites anddevelopment options, both in the City and other parts of London. Very few optionsare available that are capable of meeting our requirements (which are of course verysimilar to the requirements of our competitors - and such requirements are knownto exist - and therefore this concern is not specific to UBS).

UBS regard both the City of London and Broadgate as an ideal location for its coreUK operations and does not wish to locate these elsewhere in London or the UK.

If the proposed development of 5 Broadgate has to be abandoned because 4 and 6Broadgate (and/or any of the sculptures that are to be relocated as a result of thedevelopment) are listed, UBS will have to find alternative future accommodation thatwe can occupy by 2016 - that date being driven by the need to invest in newtechnology to maintain and enhance our competitiveness and to tie in with leasebreaks. We do not consider this to be feasible given the scale and nature of thespace required. A decision to list would therefore force us to fundamentallyreconsider our occupation strategy in London.

5.0 Timing of Decision and the Need for Certainty

The application for a Certificate of Immunity from Listing in respect of 3, 4 and 6 Broadgatewas submitted in September 2010. A decision regarding listing will therefore have taken aperiod of at least 8 months to resolve, which has lead to a significant amount of uncertaintyfor both UBS and the developer.

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4501, Basel and Bahnhofstrasse 4S, CH-800l Zurich). Registered Address: 1 Finsbury Avenue.London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

Whilst this is clearly a very important decision with significant ramifications for all interestedparties, we would like this delay to be noted, particularly at a time when the Government isstating that the top priority in reforming the planning system is to promote sustainableeconomic development and jobs. In a statement issued by the Rt. Hon. Greg Clark MP on23rd March 2011, it is stated that benefits to the economy should, where relevant, be animportant consideration when other development related issues are being considered,including issues of heritage. Indeed, the DCMS has been directed to encourage Governmentagencies and non-departmental bodies to adopt the same approach.

In the recently released" Plan for Growth" issued by the Treasury and Department forBusiness, Innovation and Skills (March 2011) it is acknowledged in the foreword that "wewant to remain the world's leading centre for financial services". It is further acknowledged(at paragraph 1 .26) that" one of the most significant burdens highlighted consistentlyduring the Growth Review has been the UK's overly slow and bureaucratic planningsystem". Whilst the importance of adequately considering heritage assets cannot beunderestimated, the timing of such considerations does need to be carefully considered such

that planning decisions are not unnecessarily delayed. This is particularly the case in light ofthe recently announced 12 months "planning service guarantee".

The planning application for 5 Broadgate was considered by the City's Planning and

Transportation Committee on Tuesday 19th April and the Committee unanimously resolvedto grant planning permission which was subsequently endorsed by the Mayor of London. Aprompt decision is therefore urged so that we have some certainty going forward and canmake the necessary arrangements as to the future location of our operations.

6.0 Conclusions

UBS needs to be in occupation of a new headquarters by 2016 - it is no longer possible forus to upgrade our existing buildings to fully cater for our long term requirements. We placegreat importance on continuing our connection with Broadgate, but this will not be possibleif the buildings under consideration are listed. A decision to list will therefore have seriousconsequences for UBS and mean that we are forced to fundamentally reconsider ouroccupation strategy in London.

The proposed development represents a combined investment by UBS, British Land andBlackstone in excess of f850m and would generate a significant number of constructionjobs over the next 3-5 years (equivalent of 5,000 person years of effort for the shell & coreconstruction alone). Subject to the decision being taken regarding listing, we are committedto commence development as soon as possible, indeed contracts have already been placedthat enable the scheme to start within three months.

We do not consider that these Broadgate Phases merit such protected heritage status. Theyare not buildings of "outstanding quality", whether considered in respect of their individualspecial architectural or historic interest or on the basis of group value. This is a viewinformed by, and shared with, our team of advisers and in particular Professor RobertTavernor.

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004S07 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4S01, Basel and Bahnhofstrasse 45, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue,London EC2M 2PP. A member of the London Stock Exchange.

,*UBS

It has always been intended that the buildings in Broadgate Phases 1-4 would be adaptable,but understandably in the 1980s the architects were unable to predict the future demandsof global institutions such as UBS. In the representations submitted to you by the City on 3rdMarch, it is stated that "there was no rigid and prescribed architectural approach to thedesign of the buildings and the Masterplan was inherently flexible so that new buildingscould in the future replace the original buildings within the overall pattern of the buildingfootprints and open spaces" .

Broadgate provides a rare and unique area within the City of London. Its importance whenfirst developed was that it provided what the conservation areas could not, both in terms ofdesign and scale, for financial occupiers with major trading requirements. These design andscale requirements have moved on with time, but if these buildings were listed, this wouldprevent modern equivalents being provided. Indeed, the ability of the City to retain majorglobal financial organisations with trading requirements such as ours undoubtedly relies onits ability to provide large bespoke buildings, which will be seriously impaired if BroadgatePhases 1-4 are listed.

UBS is a longstanding and committed supporter of London. We strongly believe that adecision to list would send out the wrong message to major financial institutions who maywish to continue, increase and/or improve their presence in the City of London both nowand in the future.

1 June 2011UBSAG

UBS Investment Bank is a business group of UBS AGUBS AG is registered as a branch in England and Wales Branch No. BR004507 (A public company limited by shares, incorporated in Switzerlandwhose registered offices are at Aeshenvorstadt 1, CH-4501. Basel and Bahnhofstrasse 45, CH-8001 Zurich). Registered Address: 1 Finsbury Avenue.London EC2M 2PP. A member of the London Stock Exchange.

Assessment of the special architectural and historicinterest of Broadgate Phases 1.4 (Nos. 1-2, 3, 4, 6 and8-12 Broadgate and 100 Liverpool Street, including theOctagon Arcade, the Broadgate Circle and Stage Area, theSculptures 'Fulcrum', 'Leaping Hare on Crescent and Bell','Go Between' and 'Ganapathi and Devi', and theassociated paving and landscaping)

Professor Robert Tavernor, BA, DipArch, PhD, RIBA

May 2011

'-oc'-~.g

1.0 INTRODUCTION

1.1 This report has been written to form the basis of the representations being made by my client,

UBS, during the consultation period following the second Initial Report by English Heritage

(EH) officers (dated 29 March 2011), regarding the potential listing of Broadgate Phases 1-4

in the City of London (the City).

1.2 Phases 1 and 2 were completed between June-July 1986, Phase 3 in September 1987, and

Phase 4 in May 1988 (Broadgate, Rosehaugh Stanhope, 1988, pp. 51-2). The overriding

principle recognised in the Department of Culture Media and Sports' (DCMS) Principles of

Selection for Listing Buildings (March 2010) is that "in order to be listed, a building must have

'special interest" (para 6). Broadgate Phases 1-4 are all less than 30 years old, and because

of their young age would need to be of 'outstanding quality' - of Grade i or 11* quality - to be

listed.

1.3 As i set out below, my opinion is that Broadgate Phases 1-4 are not of 'outstanding quality'

and do not possess sufficient 'special interest' - architectural, historic, or group value - to

warrant their listing.

2.0 RELEVANT PROFESSIONAL EXPERIENCE

2.1 i am a registered architect and a member of the Royal Institute of British Architects (since

1985). I am Emeritus Professor of Architecture and Urban Design at the London School of

Economics and Political Science (LSE). I have been Forbes Professor of Architecture at the

University of Edinburgh (1992-5), Professor of Architecture and Head of the Department of

Architecture and Civil Engineering at the University of Bath (1995-2005); and Professor and

Director of the LSE Cities Programme (2005-10). I have held various visiting academic posts

internationally, including Visiting Professor at the University of California at Los Angeles

(UCLA, 1998), European Union Visiting Scholar in planning and conservation at the University

of Texas A&M (2002); and Visiting Professor in Architecture and Urbanism at the University of

São Paulo, Brazil (2004). I am currently Visiting Professor at the University of Bath (since

2009).

2.2 I am the author of books, book chapters, and peer review journal essays on the foundations of

architecture and urban design through history, and my writings recently have focused on

London. Through the Tavernor Consultancy I provide architectural, heritage and urban

planning advice to institutions, developers and architects. I am regularly engaged in planning

applications that relate to Conservation Area and Listed Building issues. The majority of my

work has related to large-scale masterplanning and building design submissions (including in

i

London: Greenwich Peninsula, Croydon Gateway, New Wembley, Bishopsgate Goods Yard,

Battersea Power Station, and currently Earls Court) and the design of individual buildings,

some tall and often located in or visible in relation to historic settings. Internationally, I

provided the visual and heritage assessment principles for the Russian city of Perm, the first

application of such principles in the Russian Federation, part of a new city planning concept

which won the Grand Prix at the Moscow Architecture Biennale 2010.

2.3 My expertise in the urban development of London led to the DCMS asking me to give

evidence to the UNESCO and ICOMOS Worid Heritage Committee i~ the autumn of 2006

regarding the impact of modern architecture in the City on the Tower of London.

3.0 ASSESSMENT OF THE SPECIAL ARCHITECTURAL AND HISTORIC INTEREST OF

BROADGATE PHASES 1-4

3.1 The Secretary of State uses the following two criteria (Principles of Selection for Listing

Buildings (2010, paras 9-10)) when assessing whether a building is of special interest and

therefore should be added to the statutory list: architectural interest and historic interest. He

may also take into account the extent to which the exterior contributes to the architectural and

historic interest of any group of buildings of which it forms part (i.e. the "group value"). I will

now assess Broadgate Phases 1-4 against each criterion.

Architectural Interest

3.2 "To be of special architectural interest a building must be of importance in its architectural

design, decoration or craftsmanship; special interest may also apply to nationally important

examples of particular building types and techniques (e.g. buildings displaying technological

innovation or virtuosity) and significant plan forms". (Principles, 2010, para 9)

3.3 The Masterplan for Broadgate was conceived by Arup Associates for the developer

Rosehaugh Stanhope Plc. Arup Associates describe their design on their website as follows:

"Broadgate is a new financial centre located on a 3.5-hectare site, which was formerly a car

park and railway station, close to the City. The project consists of offices, with shops and

restaurants situated around newly created public squares. These squares, landscaped and

planted with semi-mature trees, provide outdoor spaces for a range of activities. During the

winter the centre of the square at Broadgate becomes an outdoor ice-skating rink, whilst in

summer it is used for concerts, exhibitions and open-air theatre. Each of the four office

buildings is focused around an atrium, which brings light and sun into the heart of the building.

The external walls of the offices consist of a three-dimensional sculpted grid of red granite,

which acts as a screen to the windows behind. The buildings step back at the upper floor in

2

order to reduce their impact on the squares. These upper levels incorporate a series of

landscaped terraces alongside the offices."

3.4 Arup Associates are organised in multi-disciplinary project teams that integrate architecture,

structural engineering, cost consultancy, urban design and product design. Architect Peter

Foggo led the project team responsible for Broadgate Phases 1-4. Peter Foggo (1930-93)

was employed by the design arm of Ove Arup and Partners, an internationally acclaimed

engineering firm, when it became Arup Associates in 1963, established jointly by Ove Arup

and Philip Dowson (both subsequently knighted). The multi-disciplinary design ethos of Arup

Associates deliberately subsumed the design status of the architect within that of the team,

though each team was certainly design led.

3.5 Broadgate Phases 1-4 were designed by 'Group 2' with Foggo in the lead. Foggo remained

with Arup Associates as a Partner and Director until establishing his own independent

practice, Peter Foggo Associates, in 1989, which specialised in City office buildings (following

his death in 1993 his practice continued as Foggo Associates). He therefore left Arup

Associates just one year after completing Broadgate Phase 4. However, it is important to

emphasise that Broadgate was conceived, designed and built by Arup Associates (Group 2) -

not Peter Foggo - and the subsequent awards for Phases 1-4 belong to Arup Associates.

Phi lip Dowson was knighted in 1980 and awarded the highest order for architecture in Britain,

the RIBA Gold Medal, in 1981. Peter Foggo received no such honours even though he was a

very talented architect and operated at a high level and within the Arup Associates commune.

Ultimately, he was a private man who maintained a low professional and public profile and

preferred to be subsumed within the identity of the team.

3.6 Arup Associates received major national awards for their work on Broadgate, but it is their

earlier output between 1963 and 1966 that has been recognised with listed status, because it

was then that the novel multi-disciplinary approach of Arup Associates was at its freshest and

most innovative, with Dowson at his creative peak. These include the Dowson-Ied designs for

the metallurgy building at Birmingham University; Long Wall house in Suffolk and

Leckhampton House in Cambridge; and the Point Royal Tower, Bracknell.

3.7 In contrast, Peter Foggo, encouraged by Stuart Lipton (subsequently knighted) who had

learned greatly from then current development and design approaches in the US, made

extensive use of American-inspired fast track pre-fabrication systems for Broadgate Phases

1-4. The buildings that resulted from this approach exhibit the economies of the concept,

simple structural grids centred on a central atrium, clad with prefabricated panels. In their

description of the development above, Arup Associates describe the "three-dimensional

sculpted grid of red granite, which acts as a screen to the windows behind" and the stepped

"upper levels (that) incorporate a series of landscaped terraces alongside the offices". This

modelling of the exterior and the interior atria are the most architecturally significant aspects

3

of the designs. All else was built for speed of construction (prefabricated structural frame,

curtain walling and toilet pods), ease of interior fit out, both initially and over time, and the

interiors have been periodically updated.

3.8 Foggo was professionally antipathetic to the use of steel (and preferred concrete) and sought

- as part of the Arup Associates design ethos - a design approach in which structure,

services and interior design were integral to the architecture. I understand from an eminent

architectural colleague of his at the time, Rab Bennetts, that he accepted the separation of"

structure and interiors from the 'architecture' with considerable reluctance, and only because

his client insisted. This makes sense. The resulting designs for Broadgate Phases 1-4 are not

typical of Foggo's and Arup Associates' design output. The approach Foggo reluctantly took

at Broadgate is associated with Post Modernism in architecture, a stylistic approach in which

the exterior is not a 'rational' continuation of the structural logic or 'idea' of the building (typical

of main stream Modernism), and is applied for visual effect. The "sculpted grid of red granite,

which acts as a screen to the windows behind" is typical of Post Modernism in that it is a

heavy material to hang externally, and would - rationally - be used as a load bearing not

hanging materiaL. Lightweight frames of steel and/or timber external screening would have

allowed the integrity of the building to be read externally, in the manner that Foggo designed

before and after Broadgate. According to representations submitted by the City to EH by

email on 3rd March, it was in fact the City - rather than the client - who insisted on the granite

external screen: "the major and characteristic feature of the e/evational treatment of 3, 4 and

6 Broadgate was introduced on the insistence of the City" and was "contrary to and against

the architects' strong wish and therefore the original design integrity of the architecture was

compromised'. Whoever is to blame, the effect is unsatisfactory aesthetically and has

diminished the architecture.

3.9 The fast-track overly stylised Post Modern approach Foggo adopted means that the design

quality of Broadgate Phases 1-4 is not only different from Arup Associates' usual high quality

work, but appears markedly different from the architecture of 'signature architects' of the time

- for example, Richard Rogers and Partners' L10yds of London, built between 1978 and 1986

and which therefore just predates Broadgate Phases 1-4. L10yds of London, while making

extensive use of prefabrication (including prefabricated structures, curtain walling and toilet

pods) exudes quality because of the high refinement, consistency and all-pervading

thoroughness of its detailing. Consequently, the building costs of Broadgate Phases 1-4 are

estimated to have cost a third less (per sqft) than L10yds of London, a landmark building in

the City which is recognised internationally as one of the finest office designs of the late 20th

century.

3.10 The cost-savings have inevitably had a detrimental impact on the architectural interest of

Broadgate Phases 1-4. To some extent this has been mitigated by the arrangement of these

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buildings around the central Circle. This was a good move urbanistically, which puts the visual

focus on the space, rather than the appearance of the buildings themselves, which create a

backdrop and frame to the new public realm. This, again, has an obvious American precedent

in the lower plaza of the Rockefeller Centre, in Manhattan, NYC, built in 1939, which was

designed to promote and attract public activity at street level with the commercial buildings set

around. The lower plaza is famously used as an ice skating rink: it is of a very high

architectural quality and supported by public art with statues by Paul Manship (Prometheus),

Isamu Noguchi (News) and Diego Rivera (Man at the Crossroads) among many others. While

the public space and sculptures at Broadgate enhance the locality, they pale in comparison in

scale and quality to the Rockefeller's.

3.11 While of interest from a construction perspective and in relation to the cost-savings made,

Broadgate Phases 1-4 are in my opinion of little or no architectural interest.

Historic Interest

3.12 'To be of special historic interest a building must ilustrate important aspects of the nation's

social, economic, cultural, or military history and/or have close historical associations with

nationally important people. There should normally be some qualiy of interest in the physical

fabric of the building itself to justify the statutory protection afforded by listing'. (Principles,

2010, para 9)

3.13 Broadgate is not linked to an historic event or individuaL. It followed in the wake of Prime

Minister Margaret Thatcher's liberalising 'Big Bang', when the City sought to modernise its

office stock in order to compete effectively with the Isle of Dogs Enterprise Zone status,

granted by the Conservative Government in 1982, and which led to the design of Canary

Wharf - a purpose designed urban quarter laid out with larger buildings than were possible in

the City, with American-style trading floor plates stacked into broad, tall buildings. Canary

Wharf was the UK's first real skyscraper and was designed by the American-based architect

Cesar Pelli. Construction began in Canary Wharf in 1988, and slightly post-dates Broadgate

Phases 1-4.

3.14 Mrs Thatcher took an interest in the building of Broadgate and visited the site twice during

construction in 1985 and 1986 (Broadgate, Rosehaugh Stanhope, 1988, pp. 50) - though of

course she also famously visited Canary Wharf, a new major urban quarter in London

intended to break the commercial mould, and which was the result of her Government's policy

initiative. Broadgate Phases 1-4 was a timely response to this initiative, but does not match

what has been built at Canary Wharf in scale or design quality - architectural and urban. It

warrants no more than a footnote to the historical events taking place during the tumultuous

Thatcher years.

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3.15 Consequently, I do not consider that Broadgate Phases 1-4 is of special historical interest.

Group Value

3.16 When making a listing decision, it is stated (Principles, 2010, para 10) that the Secretary of

State: 'may take into account the extent to which the exterior contributes to the architectural

or historic interest of any group of buildings of which it forms part. This is generally known as

group value. The Secretary of State will take this into account particularly where buildings

comprise an important architectural or historic unity or a fine example of planning (e.g.

squares, terraces or model vilages) or where there is a historical functional relationship

between a group of buildings. If a building is designated because of its group value, protection

applies to the whole of the property, not just the exterior.'

3.17 In the wake of the 'Big Bang', the emphasis was on producing buildings that were simple and

quick to build and which achieved a maximum visual impact externally - to exude corporate

authority and wealth. The external appearance of each building was to be enhanced by its

relationship to landscaped external space, and the public facilities that would animate them

provided by shops, restaurants and cafes. Canary Wharf epitomises this approach in London,

having the scale, and quality of design and materials (especially with subsequent phases of

building there), designed to American standards. Broadgate, including Phases 1-4, is very

much a British interpretation of the American model - more modest in scale and mass, and

indeed in quality of materials and architecture.

3.18 Broadgate Phases 1-4 are built around the Circle, the external publicly accessible hub of the

development, which is augmented by three tiers of galleries and retail booths. As I've

mentioned already, the Rockefeller Center lower plaza and approach is the obvious

precedent for this spatial and social arrangement, but it is much earlier in date, much grander

(with 14 buildings, several very tall) arranged around it, and with high quality art works at key

points. At Broadgate, there is no balance between the buildings and the space. The space -

the Circle and its retail booths - are enhanced by sculptures and the spatial, people-mingling

experience. The architecture of the buildings is very secondary.

General Principles for Listing

3.19 The general principles applied in the listing of buildings (DCMS) include the: age and rarity,

aesthetic merits, selectivity, national interest, and state of repair - the latter is not relevant

because of the recent age and high level of maintenance at Broadgate.

3.20 The older a building is the more likely it is to have special interest. The listing of buildings less

than 30 years old, which would include Broadgate Phases 1-4, should only normally be

undertaken "if they are of outstanding quality and under threat'. Broadgate Phases 1-4,

however, are not of outstanding quality and whether or not they are under threat is therefore6

irrelevant. Broadgate does not merit any exceptional treatment in this regard and therefore

the principle for listing of age and rarity is not applicable.

3.21 Any special interest resides in their fast-track construction methods and the resulting speed

and economy of build. Aesthetic considerations were secondary, and Broadgate Phases 1-4

lack remarkable external and internal design qualiies. I note that Samantha Hardingham

described their architecture as "faceless" and "feeble" (London, A Guide to RecentArchitecture, 6th Ed., London, 2003), and Jonathan Glancey referred to their granite facades

as possibly "the architectural cliché of the 1990s" (New British Architecture, London, 1989).

Their aesthetic appearance is at best modest.

3.22 Regarding the principle of selectivity, Broadgate Phases 1-4 are neither the most

representative nor most significant examples of the type. Canary Wharf is far more significant,

and Sir Stuart Lipton's Paternoster Square Development adjacent to St Paul's Cathedral,

begun a decade after Broadgate was initiated and completed in 2003, has a far more

interesting Masterplan and the architecture is undoubtedly of a higher quality. It contains the

London Stock Exchange. Arguably, Stanhope learned from Broadgate and refined their

approach by employing a range of high quality architects for each of the buildings.

3.23 Finally, with regard to the DCMS principles, these are not "significant or distinctive regional

buildings" and are therefore of no particular national interest.

4.0 CONCLUSIONS

4.1 Special architectural interest. The buildings and structures under consideration are not

sufficiently important in their architectural design, decoration or craftsmanship; nor are they

nationally important examples of particular types of buildings, techniques or plan forms, such

as to merit listing. As acknowledged in EH's Initial Reports, the interiors of the buildings were

specifically designed to be fitted out to the tenants' specifications, and stripped out and

remodelled when the need arose. It is therefore evident that the interiors are unremarkable

and do not demonstrate any special architectural interest.

4.2 Special historic interest. The buildings currently being considered for listing do not possess

any historic interest beyond the fact that they are office buildings of the 1980s that were

designed to be flexible and to suit the requirements of financial institutions and the new

technologies of the time. The public spaces and public art that are also being considered

similarly do not have any historic interest of note.

4.3 Group value. It is informative also to consider previous guidance issued by the Department of

Environment in 1993 (Guidance Notes to those concerned in the survey for listing) which

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states that "a building must not be chosen merely because its neighbours are good and one is

afraid that if it were demolished it would be replaced by an incongruous monstrosity. The

design of a new building can and should be controlled under general planning powers and it is

not permissible therefore to place a building on the statutory list simply to ensure a congruity

of neighbourhood which could as well be achieved in a new building. It must be possible to

say that the existing building has some quality in relation to the context which no new building

could have." The intention of the group value classification is undoubtedly the same as it has

always been. The existing buildings at Broadgate cannot be said to have a quality in relation

to their context that no new building could have.

4.4 The "30 year rule". For a building to be considered to be of outstanding quality, it should

merit listing as either Grade I or Grade 11*, that is, it should be held to have more than just

"special" architectural or historic interest. Even if it could be considered that the buildings and

structures have special architectural or historic interest (which i reject) they certainly cannot be

held to have more than special interest.

4.5 For all the reasons stated above, it is my considered opinion that Broadgate Phases 1-4 do

not make the grade for listing on any leveL.

Professor Robert Tavernor

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