On 25 February 2011, the State Party submitted a state of conservation report followed by supplementary information on 5 April 2011, in response to a request from the World Heritage Centre for details on the proposed Liverpool Waters Development. Preliminary information on the proposed Liverpool Waters Development was submitted in 2010, in accordance with Paragraph 172 of the Operational Guidelines.
The proposed development covers 60 ha in the property and its buffer zone to the north of Pier Head. It extends some 2km along the waterfront and covers five docks with open water: Bramley Moore Dock, Nelson Dock, Salisbury Dock, Collingwood Dock, (all protected Grade II), Princes Dock, Princes Half-Tide Dock and East Waterloo Dock, and other former dock areas of West Waterloo Dock and Trafalgar Dock have been subject to earlier in-filling.
The dock site is reclaimed land – a feature of the development of the Liverpool Docks – bounded by the River Mersey in the west and by the Dock Wall and Tobacco Warehouses in the East. The docks are characterized by their monumental construction and materials of granite and sandstone, as is the river wall and the major part of the Dock Wall which is built of cyclopean granite. Some of the original entrances have associated entrance lodges, built of brick and granite, and monumental entrances. The docks originally housed single storey linear transit sheds on the quaysides, with ancillary facilities such as entrance lodges, cranes and an elevated railway. The site historically had the character of a low-rise, utilitarian and industrial area.
An outline planning application for the Master Plan was submitted in October 2010. This includes proposals for 9,152 residential units, 305,499 sqm of commercial business space, 69,735 sqm of hotel and conference space as well as retail, leisure and community facilities and a cruise ship terminal. The scheme proposes a high density of development and incorporates two clusters of tall buildings, with towers up to approximately 195 metres in height, and a series of medium rise blocks, approaching 45 metres high, along the river frontage. Many of the buildings have underground parking. The scheme is planned to be developed over at least a 30 year period.
As the Environmental Impact Assessment submitted by the developer has failed to consider adequately the impact of the proposals on the Outstanding Universal Value (OUV) of the property, and because of the scale of the proposals, the State Party report included a separate, independent Impact Assessment commissioned by English Heritage, the Government‘s adviser on the historic environment. This detailed report was based on the approved Statement of Outstanding Universal Value and considered impact on the attributes of the OUV. The overall conclusion of this assessment is that the proposals will result in an array of negative impacts on the OUV (a number of which will be of major magnitude), and that overall there will be a significantly damaging impact on the OUV.
In detail, the assessment considered that the vital relationship of the property with the river will be severely compromised through mid-rise buildings on the sea wall; the legibility of the Central Docks and the central commercial core of the City will be damaged by the secondary cluster of tall buildings; the cumulative effect of the development will be to overwhelm the defining traditional characteristics of the area with opposing modern ones (in other words, low, horizontal and transverse historic emphases will be replaced by height, verticality and the longitudinal); the underground archaeology will be compromised by the insertion of underground parking across historic dock walls, into the bottoms of dock basins, and into the fill of historic quaysides; and the failure of the development to respect fundamental notions of form and function will damage authenticity. The scheme is also said to be non‐compliant with national and local policies, including Liverpool City Council’s Urban Development Plan.
The Management Plan for the property, parts of which were adopted as supplementary planning guidance following the recommendations of the 2006 mission, has also not been respected. An objective of the plan states that Liverpool City Council will ‘ensure that new development respects the significance of the Site and is appropriate to the historic urban grain and the architectural and townscape context’.