Ancient City of Nessebar

• Lack of a management plan (issue resolved)
• Urban development pressure (issue resolved)
• Lack of an urban master plan and of a conservation master plan of monuments and archaeological sites (issue resolved)
• Illegal constructions (issue resolved)

Following consultations with the World Heritage Centre and ICOMOS held in January and February 2017, the State Party submitted a detailed state of conservation report on 26 February 2017, with several annexes, accessible at https://whc.unesco.org/en/list/217/documents/, which informs on the following:

• Response to previous Committee recommendations;
• Delay in approving and implementing the Management Plan due to:
  • Negative advice of the Ministry of Finance for an ad-hoc National Fund “Nessebar-World Heritage” separate from the State Budget and for Value Added Tax exemption for Nessebar residents,
  • Negative advice from the legal directorate of the Ministry of Culture on the proposal for a separate Act on the Preservation and Development of the Ancient City of Nessebar,
  • Reported inconsistencies between the boundaries of the property and its buffer zone as they are shown in the draft Management Plan and those mentioned in protection regimes adopted in 2015 based on the Ordinance n. 174/1991 (2km of buffer zone around the peninsula) corresponding to boundary clarifications carried out in 2008 and finalized with Decision 32 COM 8D;
• A working group was established by the Ministry of Culture to revise and achieve approval of the Management Plan by the Council of Ministers, including a proposal for financing required activities;
• Protective status of Nessebar was strengthened by order of the Minister of Culture No. RD9Р-14 (5 June 2015);
• Draft proposals for related protection regimes and conservation prescriptions have been prepared;
• The general development plan for Nessebar was drafted and submitted for conciliation with the Ministry of Environment and Water together with Environmental Impact Assessment (EIA) report;
• A detailed development plan will be prepared for the property and its buffer zone in December 2016;
• Moratorium on new constructions remains valid, though some building permits have been issued for allowed activities;
• An underwater archaeological survey was conducted before approval of Reconstruction and Modernization of Fishing harbour – Northern dike – Nessebar;
• Conservation works at protected monuments and archaeological sites are being carried out or funded;
• Documentation of the street silhouettes of Nessebar is ongoing with a view to recover the traditional skyline;
• Removal of illegal buildings is ongoing (12 in 2015 and 3 more in 2016);
• The Ministry of Transport, Information Technologies and Communications is aware of the prohibition of port infrastructure and the ban on future construction or development of the harbour; no project proposal related to the Concession of the Nessebar Port Terminal has been received, a proposal by the concessionaire includes the development of a car park;
• The project for Reconstruction and Modernization of Fishing harbour – Northern dike – Nessebar will not be commenced without the result of a Heritage Impact Assessment (HIA) and a positive advice in its regard by ICOMOS and decision by the Committee.

On 3 May 2017, the State Party informed the World Heritage Centre that the Municipality of Nessebar clarified that the reconstruction plan, namely the enlargement of the existing fishing port “Severna Buna-Nessebar”, has been abandoned. Only its modernisation will be carried out in order to preserve the fishery as the traditional local livelihood. Such a modernisation project will include public works, rehabilitation and modernisation of the existing fishing port infrastructure as stipulated by the new European Union (EU) regulations regarding the implementation of the goals and objectives of the revised EU Common Fisheries Policy.

Despite some progress in implementing the Committee’s decisions, several crucial measures are not yet implemented, namely the protection regimes and conservation prescriptions, the development of a detailed Master- and Conservation Plans for the property and its buffer zone, the approval of the Management Plan – or even not initiated, e.g. sustainable mobility plan, technical guidelines for the vernacular architecture, instruments for careful arrangements of monuments’ setting. Moreover, an ill-conceived development approach based on mass tourism is continuing a pattern that has already caused irreversible changes along the coast near and brought excessive pressures on Nessebar. The conservation approach is still piecemeal: safeguarding measures are not part of a comprehensive proactive strategy combining law enforcement, conservation and promotion within one integrated Outstanding Universal Value (OUV)-based vision for the future of the property. 

The lack of structural and strategic planning and the sectorial approach of the different branches of the state administration, which limit their consideration to their strict jurisdiction, hinders the efforts being made and some decisions, e.g. the concession given for the Port Terminal, may lead to negatively impacting proposals.

The proposed infrastructure projects are incompatible with the OUV, attributes and vulnerabilities of Nessebar. Envisaging Nessebar Port Terminal as a gateway for ships as large as 35,000 Gross Registered Tonnage (GRT) and 180m long, as reported by the Ministry of Culture in its letter of 17 April 2015, points towards unsustainable forms of development and indicates a preoccupying misunderstanding of sustainable development and World Heritage status. A concession issued for use of the Port Terminal for large-scale ships is very alarming and represents a potential danger (e.g. negative impacts from modified sea currents and water movements caused by approaching and departing ships); however, careful and light intervention to recover the terminal area is needed, based on a different, more compatible strategy. 

It is noted that the reconstruction/enlargement plan of the existing fishing port “Severna Buna-Nessebar” has been abandoned and only its modernisation will be carried out. Taking into account that an intense tourism-oriented use of the fishing harbour is expected, with increased traffic, it is recommended that the Committee request the State Party to halt any works until a HIA for the modernization of the existing fishing port is carried out in conformity with the ICOMOS Guidelines.

The conservation of the property requires a much stronger inter-sectorial approach, a shared vision for the future of Nessebar as a World Heritage property, as well as a strong cooperation among different branches of the public administration and the private sector to achieve shared benefits compatible with World Heritage status. Such a vision and cooperation are missing.

Taking into account a substantial systemic difficulty in establishing priorities for the property and coordinated collaboration among all stakeholders concerned, it is recommended that the Committee invite the State Party to strengthen the property’s management system, and in particular to reinforce the existing institutional framework by establishing all relevant decision-making bodies and groups that develop and adopt a vision for the future of the property and a strategic programme for its implementation. It is also recommended that the Committee encourage the State Party to finalize and adopt the Management Plan of the property, as well as to implement all relevant measures and plans to support the appropriate implementation of its decisions in order to prevent any threats to its  (OUV).

While progress has been made, essential legal instruments and management documents are not yet finalized and approved. It is recommended that the Committee request the State Party to explore possibilities to amend or integrate national legislation with provisions that favour mechanisms for the streamlining of funding for heritage conservation and maintenance based on an updated comparative study on the legal frameworks of other countries, particularly within the EU, with a particular focus on the legal framework concerning taxation, fiscal incentives or exemption, VAT application, reduction, etc. as a means to support cultural heritage conservation, management and promotion, in line with international policies and best practices.  

If an OUV-based policy and appropriate regulations are not immediately introduced by the national and municipal authorities to prevent inappropriate developments, existing infrastructure projects and inappropriate development could jeopardize the property’s OUV and could represent potential danger, in conformity with Paragraph 179 of the Operational Guidelines.

While taking note that the State Party proposed to invite an Advisory mission to the property to review the infrastructure project proposals, however, it is rather recommended that the Committee request the State Party to invite a joint World Heritage Centre/ICOMOS Reactive Monitoring mission to the property to assess its state of conservation and the implementation of its Decisions. 

It is recommended that the Committee provide the State Party with an opportunity to address these longstanding concerns and to implement its Decisions; but if these actions are not completed promptly, then consideration of the inscription of the property on the List of World Heritage in Danger would be warranted.