The Recommendation to Delete Liverpool as a World Heritage Site

World Heritage Committee

Of course the ‘State Party’ now is commissioners not Liverpool, so what will commissioners do to rectify the gross deficiencies identified in the report? The SoS should write to them on this issue.

Previous monitoring missions
October 2006: joint World Heritage Centre / ICOMOS Reactive Monitoring mission; November 2011:
joint World Heritage Centre / ICOMOS Reactive Monitoring mission; February 2015: joint World
Heritage Centre/ICOMOS Advisory mission
Factors affecting the property identified in previous reports
• Governance: Lack of overall management of new developments
• High impact research/monitoring activities: Lack of analysis and description of the townscape
characteristics relevant to the Outstanding Universal Value of the property and important views
related to the property and its buffer zone
• Legal framework: Lack of established maximum heights for new developments along the waterfront
and for the backdrops of the World Heritage property
• Social/cultural uses of heritage
• Buildings and development: Commercial development, housing, interpretative and visitor facilities
• Lack of adequate management system/management plan
Illustrative material see page http://whc.unesco.org/en/list/1150/
Current conservation issues
On 4 February 2020, the State Party submitted a state of conservation report, which is available
at https://whc.unesco.org/en/list/1150/documents/. A further revised and updated Desired state of
conservation for the removal of the property from the List of World Heritage in Danger (DSOCR), as
requested from the State Party by the World Heritage Committee at its 43rd session was not submitted
at the time, but was provided on 5 August 2020. The report by the State Party provides the following
information:
• The Liverpool City Council has prepared a ‘vision’ for the North Shore area within the World
Heritage site called North Shore Vision. The North Shore Vision covers an area of the City that
includes ‘Liverpool Waters’ and the immediately adjacent Ten Streets area as well as the Stanley
Dock Conservation Area. It seeks to place the regeneration of the area in the context of the historic
built environment, and in particular appreciation and acknowledgment of the Outstanding
Universal Value (OUV) and its attributes. The State Party wished to base its DSOCR around the
North Shore Vision and on tools that will be finalised subsequently. These tools include the Local
Plan, the Tall Buildings Policy and Supplementary Planning Document (note that the full North
Shore Vision document was submitted to the World Heritage centre and the Advisory Bodies on
7 May 2020);
• Public hearings for the draft Liverpool Local Plan were scheduled for late spring 2020, while its
adoption by the Liverpool City Council (LCC) was planned to take place in late 2020. The
Supplementary Planning Document adopted in 2009 is currently being revised and will be
finalized alongside the Local Plan. An update of the Tall Buildings policy is being developed and
will be included in the emerging Local Plan;
• The Princes Dock Neighbourhood Masterplan has been submitted and approved by LCC in 2018.
The Central Docks Masterplan was approved in October 2019;
• Ongoing initiatives have been designed to promote awareness about the World Heritage property
and its values, including a dedicated website launched in 2019
(https://www.liverpoolworldheritage.com);
• In 2019, LCC established a Heritage Priorities and Investment Steering Group working in
partnership with the National Lottery Heritage Fund (NLHF). Over 40 heritage projects both
State of conservation of the properties WHC/21/44.COM/7A.Add, p. 54
inscribed on the List of World Heritage in Danger
tangible (capital) and intangible have been identified and prioritised for future discussions with
NLHF;
• An overview was provided on works undertaken to improve the condition of buildings within the
property.
In the State Party’s view, no individual development, which has been given permission to date within
‘Liverpool Waters’ and the property, has impacted adversely to a significant extent on the OUV of the
property, including its authenticity and integrity.
The State Party repeated that it is neither desirable nor practical to enforce a moratorium for new
buildings and that OUV, including authenticity and integrity, are being sustained through the current
planning regime. The State Party argues that development has been a fundamental driver towards
improving the conditions of the property.
The State Party reiterates in the report its former notification to the Secretariat in line with Paragraph 172
of the Operational Guidelines that in December 2019, a full planning application was submitted for a
new football stadium in the Bramley-Moore Dock, within the property. The State Party, furthermore,
provided updated information on this project in 2021: LCC has approved the Everton Stadium project
proposal in February 2021. Media reports indicate that in March 2021, the UK Secretary of State for
Housing, Communities and Local Government reviewed and approved the project.


Analysis and Conclusions of the World Heritage Centre, ICOMOS and ICCROM
At its 36th session (Saint-Petersburg, 2012), the World Heritage Committee considered that the
proposed development of ‘Liverpool Waters’ constituted a potential danger to the World Heritage
property and noted that the implementation of the development would irreversibly damage the attributes
and conditions of integrity that warranted inscription. Regarding these, the Committee decided to
inscribe the property on the List of World Heritage in Danger, with the possibility of deletion from the
World Heritage List, should the project be approved and implemented. It also requested the State Party
to develop, in consultation with the World Heritage Centre and the Advisory Bodies, a proposal for the
DSOCR and a set of corrective measures, for examination by the World Heritage Committee at its
37th session in 2013 (Decision 36 COM 7B.93).
At its 37th session (Phnom Penh, 2013), the State Party informed the Committee that the Secretary of
State for Communities and Local Government decided not to call in the ‘Liverpool Waters’ development
for consideration at the national level, and that LCC had granted consent to the framing document of
this project, the Outline Planning Consent (OPC) – Development Consent Order (2013-2042), submitted
by the developer, which forms the basis of both the Neighborhood Master Plans and the individual
planning applications. Following this, the Committee repeatedly requested the State Party to:
• Consider all measures that would allow changes to the extent and scope of the proposed
‘Liverpool Waters’ scheme to ensure the continued coherence of the architectural and townplanning attributes, and the continued safeguarding of the OUV of the property, including the
conditions of authenticity and integrity;
• Establish substantive commitments to limit the quantity, location and size of allowable built form
and linking the strategic city development vision to a regulatory planning document, which
provides legal guidelines on the protection of OUV.
The State Party prepared the first draft DSOCR in 2013, and a second draft was submitted to the
Secretariat in 2014. Following the Reactive Monitoring mission to the property in 2011, an Advisory
mission was conducted by the World Heritage Centre and ICOMOS in 2015 to consult with the State
Party, whether a DSOCR and corrective measures could be agreed. The mission concluded that the
second draft DSOCR was inconclusive as to the removal of threats to the property and also considered
a need to reduce the urban density and height of the proposed development from the maximum granted
for the ‘Liverpool Waters’ project.
Following this, the State Party submitted updated DSOCR documents for the 41st (Krakow, 2017), 42nd
(Manama, 2018) and 43rd (Baku, 2019) sessions of the Committee. These documents did not provide
a comprehensive desired state of conservation, nor appropriate corrective measures. Despite several
meetings over recent years, the State Party has not followed the Committee’s Decision 42 COM 7A.7,
for substantive commitments to establish limitations on the quantity, location and size of allowable built
form in order to acknowledge the importance of protecting key attributes which contribute to the OUV of
the property, and the significance of the context of the property and its buffer zone. Based on the State
Party’s approach the effectiveness of the DSOCR would rely on the content of additional documents,
State of conservation of the properties WHC/21/44.COM/7A.Add, p. 55
inscribed on the List of World Heritage in Danger which are yet to be prepared or finalized, including the Local Plan, the revised Supplementary Planning Document, the majority of the Neighborhood Masterplans, and the Tall Building (skyline) Policy. The
timeline for developing and approving all these documents extend well into the future and, therefore, the
presented DSOCR versions were not considered appropriate for adoption by the Committee. A further
updated DSOCR was not submitted together with the state of conservation report by the State Party for
the 44th session of the Committee scheduled for 2020, as requested. However, a new proposed DSOCR
was provided by the State Party on 5 August 2020, for which ICOMOS has prepared a technical review,
concluding that in its present form the DSOCR is not suitable to be proposed for adoption by the
Committee.
Following the confirmation from the State Party that a moratorium remains in place for the Central Docks,
at its 40th session (Istanbul/UNESCO 2016), the Committee requested the State Party to ensure that
only repair and reuse of historic buildings, maintenance works and small scale projects should receive
permission within the rest of the property until the DSOCR is finalized and adopted. This request has
been repeated by the Committee in its following sessions, but the State Party has advised that such a
request is neither necessary nor legally feasible. Hence the State Party has continued to permit new
constructions that have negatively impacted the attributes which contribute to the OUV of the property.
At its 41st session (Krakow, 2017) the Committee noted with regret that the implementation of the
‘Liverpool Waters’ scheme had started with the granting of planning permission for individual buildings.
This process of granting planning permits for individual buildings without a strategic vision anchored in
regulatory frameworks has continued until the present. Construction projects continue to receive
approval and are being implemented within the property and its buffer zone, both in the frame of the
‘Liverpool Waters’ scheme and independently. The Committee considered that the stated inability of the
State Party to control further developments clearly reflects inadequate governance systems and
planning mechanisms that undermine protection and management and therefore, fail to sustain the OUV
of the property. The Committee set out four specific requirements to be met to prevent the property from
being considered for deletion from the World Heritage List, as follows:
a. Reverse course and stop the granting of planning permissions which have a negative impact on
the OUV of the property,
b. Provide substantive commitments to limitation on the quantity, location and size of allowable built
form,
c. Link the strategic city development vision to a regulatory planning document,
d. Submit, lastly, a DSOCR and corrective measures in a form that might be considered for adoption
by the Committee (Decision 41 COM 7A.22).
In its state of conservation report for the 42nd session of the Committee (Manama, 2018), the State
Party advised (on the basis of the stated position of Peel Holdings, the developer of ‘Liverpool Waters’)
that there is no likelihood of the scheme coming forward in the same form as in the OPC. However, this
statement was not followed by binding implementation measures. At its 43rd session (Baku, 2019), the
Committee therefore, regretted that the submission of Princes Dock Masterplan and changes to the
‘Liverpool Waters’ scheme has not been submitted to the Secretariat and the Advisory Bodies for review
and comments before their adoption by the LCC, and expressed its utmost concern that these
documents put forward plans, which do not ensure the adequate mitigation of the potential threats to
the OUV for which the property was inscribed on the List of World Heritage in Danger.
In October 2019 and January 2020, in its technical reviews of the Central Docks and Princes Dock
Neighbourhood Masterplans, ICOMOS concluded that aspects of the allowable developments under
these plans would fundamentally adversely affect the inscribed property and its buffer zone, resulting in
an unacceptable impact on the OUV of the property. Subsequent consideration of a proposed
amendment to the ‘Liverpool Waters’ Masterplan did not realign the OPC with the requirements for
maintenance of the OUV of the property. The cumulative effect of the OPC and the related series of
individual project approvals and implementation, exacerbated by the absence of a satisfactory DSOCR,
have now reached a point where the property has lost characteristics which supported its inclusion in
the World Heritage List, and the OUV of the property continues to deteriorate through a process that
appears to be irreversible.
In February 2020, the State Party submitted notification under Paragraph 172 of the Operational
Guidelines of the foreshadowed proposed new football stadium to be constructed on the site of BramleyMoore Dock, within the property. This proposal, presented in more than 400 documents, would require
infill of the historic dock, and construction of a very large new built form on the Liverpool waterfront.
State of conservation of the properties WHC/21/44.COM/7A.Add, p. 56
inscribed on the List of World Heritage in Danger
ICOMOS has advised that the proposal, if implemented, would have a completely unacceptable major
adverse impact on the authenticity and integrity, therefore, the OUV of the property and should not
proceed at this location and that the proposal is also contrary to the State Party’s own guidance
documents, and contrary to explicit Decisions of the World Heritage Committee.
The State Party has recently developed and published the North Shore Vision for the northern part of
Liverpool, resulting in a document that includes a part of the property and its buffer zone, but its focus
is not on protecting OUV but rather on outlining integrated development approach for an area of the city
that is in need of social and economic realignment. The relevant authorities of the State Party should
have afforded greater weight to the objectives and requirements of the United Kingdom’s National
Planning Policy Framework, and in particular the provisions of paragraphs 192, 193, 194, 196 and 200,
to give priority to sustainable conservation and use of heritage assets for community benefit, and afford
primacy to conservation of World Heritage, over and above the desire to permit an inappropriate level
of intervention and change allowable under the OPC. The North Shore Vision itself doesn’t require a
separate technical review, a section dedicated to its content having been included by ICOMOS in its
technical review of the proposed DSOCR.
Over the period since the inscription of the property on the List of World Heritage in Danger, the State
Party has been provided with consistent advice through Committee Decisions, missions and technical
reviews. The State Party has not complied with the advice and repeated requests of the World Heritage
Committee. It has neither developed a tool and framework document in the form of a DSOCR and
corrective measures, which defines the state of conservation that a property must reach in order to
demonstrate that it is no longer threatened by ascertained or potential serious and specific danger and
would enable its removal from the List of World Heritage in Danger, nor demonstrated either adequate
commitment to limit the quantity, location and size of allowable built form, nor put mechanisms in place
to prevent the implementation of the ‘Liverpool Waters’ scheme and other construction projects in the
property and its buffer zone from having a major negative impact on the OUV of the property.
Furthermore, the new North Shore Vision incorporates both implementation of the ‘Liverpool Waters’
scheme and the recently-approved stadium on the site of the historic Bramley-Moore Dock. The
necessary corrective measures have not been taken in conformity with Paragraph 191(a) of the
Operational Guidelines. Moreover, the State Party itself has unequivocally confirmed on multiple
occasions that with regard to its obligations to comply with the national and local planning framework, it
has no ability to put in place the requested moratorium for new building projects, nor to stop nor to
significantly change the approved OPC for the ‘Liverpool Waters’ scheme. This indicates that there are
no legal and instrumental means available in the governance of the property that would allow the State
Party to protect the OUV of the property.
The World Heritage Centre and the Advisory Bodies conclude that despite some successful projects
aiming to protect the OUV of the property through adaptive reuse of buildings mostly in the historic
centre of Liverpool, within the property and its buffer zone, the inevitable process for the implementation
of the ‘Liverpool Waters’ project and other large scale infrastructure projects in the waterfront and
northern dock area of the property and its buffer zone have progressively eroded the integrity of the
property and continue to do so as the most recent project proposals and approvals indicate. These
actions have already resulted in serious deterioration and loss of attributes that convey the OUV of the
property to the extent that it has lost characteristics which determined its inclusion in the World Heritage
List, in conformity with Paragraph 192(a) of the Operational Guidelines. The approved planning
application for a new football stadium in Bramley-Moore Dock within the property adds to the ascertained
threat on the property’s OUV and is directly contrary to the approach requested by the Committee for
this property. Furthermore, it reflects the lack of commitment from the State Party to protect this property
in the long-term. At its 36th session in 2012, the Committee decided to inscribe the property on the List
of World Heritage in Danger, and specifically identified at the time the possibility of deletion of the
property from the World Heritage List, should the ‘Liverpool Waters’ project be approved and
implemented. The Committee has considered several times (Decisions 36 COM 7B.39, 37 COM 7A.35,
38 COM 7A.19, 40 COM 7A.31, 41 COM 7A.22 and 42 COM 7A.7) the possibility of deletion of the
property from the World Heritage List owing to the clear deterioration and irreversible loss of attributes
conveying the OUV of the property including its authenticity and integrity, arising from the ‘Liverpool
Waters’ development OPC, and decided, at its 43rd session, to delete the property from the World
Heritage List at its 44th session, if the Committee decisions related to the adoption of the DSOCR
and the moratorium for new buildings were not met.
State of conservation of the properties WHC/21/44.COM/7A.Add, p. 57
inscribed on the List of World Heritage in Danger
Draft Decision: 44 COM 7A.34
The World Heritage Committee,

  1. Having examined Document WHC/21/44.COM/7A.Add,
  2. Recalling Decisions 36 COM 7B.93, 37 COM 7A.35, 38 COM 7A.19, 39 COM 7A.43,
    40 COM 7A.31, 41 COM 7A.22, 42 COM 7A.7 and 43 COM 7A.47, adopted at its 36th
    (Saint Petersburg, 2012), 37th (Phnom Penh, 2013), 38th (Doha, 2014), 39th (Bonn,
    2015), 40th (Istanbul/UNESCO, 2016), 41st (Krakow, 2017), 42nd (Manama, 2018) and
    43rd (Baku, 2019) sessions respectively, and in particular its repeated serious concerns
    over the impact of the proposed ‘Liverpool Waters’ development in the form presented in
    the approved Outline Planning Consent (2013-2042) which constitutes an ascertained
    threat to the Outstanding Universal Value (OUV) of the property, and that the
    implementation of the development, as planned, would irreversibly damage the attributes
    and conditions of integrity that warranted inscription;
  3. Also recalling its repeated requests to the State Party to:
    a) Consider all measures that would allow changes to the extent and scope of the
    proposed ‘Liverpool Waters’ scheme to ensure the continued coherence of the
    architectural and town-planning attributes, and the continued safeguarding of the
    OUV of the property, including the conditions of authenticity and integrity,
    b) Establish substantive commitments to limitation on the quantity, location and size
    of allowable built form and linking the strategic city development vision to a
    regulatory planning document, which provides legal guidelines on the protection of
    the OUV,
    c) Establish a moratorium for granting of planning permissions which have a negative
    impact on the OUV of the property,
    d) Submit, a Desired state of conservation for the removal of the property from the
    List of World Heritage in Danger (DSOCR) and corrective measures in a form that
    might be considered for adoption by the Committee;
  4. Further recalling that, according to Article 6.1 of the Convention, the properties inscribed
    on the World Heritage List constitute the world’s heritage, the protection of which is the
    duty of the international community as a whole, and that it is the duty of the international
    community to assist and to cooperate with States Parties in their endeavour to conserve
    such heritage;
  5. Recalling furthermore that States Parties have the obligation under the Convention to
    protect and conserve the cultural and natural heritage situated on their territory, notably
    to ensure that effective and active measures are taken for the protection and
    conservation of such heritage;
  6. Notes with deep regret that inadequate governance processes, mechanisms, and
    regulations for new developments in and around the World Heritage property, have
    resulted in serious deterioration and irreversible loss of attributes conveying the OUV of
    the property along with significant loss to its authenticity and integrity, that the process
    of further deterioration is irreversible, and that the State Party has not fulfilled its
    obligations defined in the Convention with respect to protecting and conserving the OUV,
    as inscribed, of the World Heritage property of Liverpool – Maritime Mercantile City;
  7. Also notes with deep regret that as a result of approved and implemented development
    projects, the property has deteriorated to the extent that it has lost characteristics, which
    State of conservation of the properties WHC/21/44.COM/7A.Add, p. 58
    inscribed on the List of World Heritage in Danger
    determined its inclusion in the World Heritage List, in conformity with Paragraph 192(a)
    of the Operational Guidelines and that the necessary corrective measures have not been
    taken in conformity with Paragraph 193 of the Operational Guidelines;
  8. Regrets that the entreaties of the World Heritage Committee at its 36th, 37th, 38th, 39th,
    40th, 41st, 42nd and 43rd sessions have not resulted in protection of the property;
  9. Also regrets that the process for the implementation of the ‘Liverpool Waters’ project and
    other large-scale infrastructure projects in the waterfront and northern dock area of the
    property and its buffer zone has resulted in serious deterioration and irreversible loss of
    attributes that convey its OUV, and that further projects, such as the approved new
    football stadium in Bramley-Moore Dock within the property, add to the ascertained threat
    of further deterioration and loss of the OUV of the property;
  10. Further regrets that the State Party has not complied with the repeated requests of the
    Committee, and has itself indicated that there are no legal and other means available in
    the governance of the property that would allow the State Party to comply with all of the
    Committee’s requests so as to ensure the protection of the property and retention of its
    OUV in the long-term;
  11. Decides to delete Liverpool – Maritime Mercantile City (United Kingdom of Great
    Britain and Northern Ireland) from the World Heritage List.

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