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Dear Mr Cunningham,
Threatened Withdrawl of World Heritage Status for Liverpool Maritime Mercantile City by World Heritage Committee – Legal Duties and Responsibilities of Commissioners
I write to you as newly appointed Lead Commissioner for Liverpool under the purposes confirmed by statuary direction of the Secretary of State and his letter of the 10th inst. appointing you as lead commissioner to exercise powers under Part I of the Local Government Act 1999.
The planning and building control function falls under the regeneration function over which your and the other commissioners now control. We understand one of your commissioners is a chartered town planner.
There has been considerable local concern at this point and a call by local leader to meet with the committee. They no longer lead on this issue – quite frankly it would be on your watch. This would be an international scandal. Liverpool filling in its docks is the equivalent of Paris filling in the Seine or New York filling in the Hudson.
I advise you take as the model the way the State Party and local government has responded to a similar threat in Vienna. This should be taken as a model by yourselves.
Unlike almost every other country in the world there is no dedicated statutory protection for World Heritage Sites in the UK, they are protected by normal planning and listed building controls.
Over many decades there has been concern about the loss of heritage in Liverpool. In recent years there has been considerable improvements, however concerns remain about the excessively close relationship between certain development interests and local politicians to the detriment of heritage. Indeed these concerns and the report commissioned by the Secretary of State following the arrest of certain parties led to your appointment.
These concerns exist throughout the city. For example, the long overdue designation of certain parts of the City Centre, such as Renshaw Street for conservation area status. However, the greatest concerns existing in the area known as the Northern Shore Area, and in particular two planning applications:
- Peel Properties approved outline permission for Liverpool Waters
- The application by Everton Football Club for a new stadium Bramley-Moore Dock. Which has been before planning committee but no permission has yet been issued as a S106 obligation is required.
The SoS has declined to call in either application against the advice of Heritage England.
Although Peel Properties agree the 2013 consent for Liverpool Waters will not go ahead within the parameters of that planning consent there is no statutory framework yet in place which protects the outstanding universal value of the WHS. That is the issue. Non-statutory masterplans exist (over which controversy exists) and statutory development plans promised but long delayed. If there were a binding system of controls in place, such as a local development order reinforced by a design code, this issue could be resolved. That responsibility now rests with you.
- That you ask for a high level secondee from Heritage England, with the agreement of DCHLG and DCMS to take over management of the WHS and draw up urgent recommendations to yourselves and ICOMOS and ICCROM.
- In the interim you ask the Secretary of State to issue a development order (holding direction) requiring his agreement on issuing any planning consent in the North Shore Area, including on reserved matters applications in pursuant of the Liverpool Waters scheme.
That would give breathing space for the following action:
- To commission independent Consultants, under your and the WHS manager suggested under a) to prepare a masterplan and design code for the Northern Shore Area, including binding controls on heights and appearance of buildings.
- For that masterplan to consider an alternative on shore site or sites within the masterplan area for a premier league standard facility that avoided filling in docks which form part of the OUV of the WHS.
- That following this decide, with the SOS, on ways of putting the masterplan in statutory form.
- On conclusion of this lift the holding direction and decide applications for the North Shore.
Liverpool of course must evolve. It cannot be a zero- sum shell game of conservation OR Regeneration. A properly considered masterplan and design code can achieve both. With good will such an action plan can resolve this impasse.
CC Heritage England
Liverpool Civic Society