Trang An Landscape Complex

• Management systems / management plan (Need to revise the management and zoning plans, including tourism planning and consideration of the adequacy of permissible activities and developments; Lack of an appropriate buffer zone)
• Impacts of tourism / visitor / recreation (Developments and urbanization stemming from tourism and recreation; Localized, seasonal overcrowding and lack of clarity in terms of planning of tourism infrastructure and services; Need to reinforce full accountability for private tourism actors with respect to the protection of features of possible Outstanding Universal Value)

On 6 December 2017, the State Party submitted a state of conservation report, which is available at http://whc.unesco.org/en/list/1438/documents and includes two Action Plans for visitor management and archaeological heritage management, respectively. The report provides an update on the previous Committee decision, as follows:

• The revised Management Plan, dated 2015, was reviewed focussing on archaeological heritage and visitation, leading to the above-mentioned Action Plans;
• Visitor numbers reached some 2.4 m in 2016, 11% increase over the previous year. The estimate of 2 m visitors by 2020 had to be substantially revised to 3.5 m. The State Party reports “no observable undesirable environmental or social impacts” in this context. A replica movie set of the movie “Kong: Skull Island” has been established to promote the property;
• Several provisions in response to increased visitation are in place or planned, e.g. an increase in the number of boats from currently 2,650 to 3,865 (by 2020) and eventually 4,360 (by 2030), more daily trips per boat and the opening of a new boat route;
• Actions and provisions concerning archaeological heritage management are consistent with the objectives laid out in the revised Management Plan and include protection of pre-historic archaeological sites, research, conservation, capacity-building and training. The large international research SUNDASIA project with Queen's University Belfast is contributing to the understanding of the adaptation of prehistoric communities to changing environmental conditions. An ad hoc Management and Scientific Advisory Committee on archaeological heritage management was formalized;
• High and increasing visitation is reported to not have caused visibly detrimental impact on the state of biodiversity within the property. Strengthened conservation efforts in collaboration with other stakeholders include inter alia biodiversity surveys under the SUNDASIA project;
• A possible re-introduction of the critically endangered Delacour’s Langur (Trachypithecus delacouri) is mentioned;
• Brief reference is made to education, training, promotion and administrative reform in Ninh Binh Province. The property’s Management Board was transferred to the newly established Department of Tourism, which supervises and controls all activities;
• The provincial Tourism Master Plan continues to mention the possibility of a new urban university area within the buffer zone of the property, although the State Party notes that the likelihood of project implementation is extremely low, and the project would be subject to rigorous assessment procedures, fully considering World Heritage status. A Strategic Environmental Assessment (SEA) is not considered required at this stage.

In March 2018, national media reported on the illegal construction by Trang An Tourism Company of a 1 km long concrete walkway at Cai Ha Mountain within the property, despite repeated warnings from Ninh Binh Tourism Department. On 22 March 2018, the World Heritage Centre requested the State Party to provide clarification on this issue. On 11 May 2018, the State Party provided further information on the construction and the measures taken to dismantle it. Dismantling of the structure started on 30 March 2018 and are expected to take three months..

The State Party’s commitment to refine management is fully acknowledged. The shifting of management authority under the provincial Tourism Department confirms that tourism is a primary management objective. While fully legitimate, the coincidence of a comparatively small property and enormous visitor numbers - increasing beyond expectations - call for responsive, strong and decisive management responses. It should be noted in that regard that the establishment of a replica film set cannot be considered an appropriate heritage promotion strategy for a World Heritage property, misses the opportunity to raise awareness of the cultural and natural significance of the property and has clear adverse impacts on its authenticity. It is advisable that management authorities focus instead on raising awareness of its Outstanding Universal Value (OUV).

The rapid increase of already-high tourism numbers will most likely change the property’s rural and social setting, creating significant direct and indirect impacts in terms of traffic, parking infrastructure, disturbance, sewage and waste management, etc. For example, the State Party mentions a need for additional parking lots in the buffer zone without further elaboration. The sharply increased visitor numbers and substantially revised future estimates add weight to the acute necessity of adequate management capacity and may swamp even improved management efforts. It should be recalled that the ICOMOS evaluation noted that “the management system for the property does not appear to be robust enough to meet the challenges affecting it in terms of tourism development”.

The measures suggested to address overcrowding and carrying capacity appear to be an attempt to accommodate growing visitation only, rather than enhancing understanding of impacts and necessary enforcement of acceptable limits to carrying capacity, for example the substantial increase in the number of boats to 3,865 by 2020 beyond the cap of 3,000 determined in the Management Plan. The report makes no reference to criteria, methodological approaches, let alone measurements of impacts beyond visual observations and visitor feedback. The current approaches of the State Party to address environmental and social impacts should be strengthened by providing concrete scientific data to ensure that tourism growth is adequately controlled in light of the primary concern of conserving the property’s OUV. 

While the specifically recognized natural World Heritage values refer to landscape beauty and the extraordinary karst geology, the biodiversity setting is also a key part of this aesthetic. The interpretation plan should be clearly developed to provide visitors with information beyond just scenic beauty of the property. Systematic terrestrial and freshwater biodiversity conservation should become an integral element of management planning, including monitoring. This needs to be facilitated by adequate mandates and capacities in the management structure, which currently appears to focus on tourism development. Uncontrolled tourism use of this small property may jeopardize the very reasons why tourists are attracted to the place.

The above-described illegal construction of a concrete staircase at the property emphasizes the Advisory Bodies’ concerns, noted in their 2014 Evaluation reports that “the greatest threat to the nominated property is from inadequately planned and managed tourism along with its associated infrastructure support and service provision developments” (IUCN), and that one of the main threats to the property was the “lack of adequate regulation for development of facilities for tourism” (ICOMOS). The case also highlights the need for an appropriate mechanism of consultation within the Management Board and among all stakeholders to address various issues in considering multiple needs for a sound preservation and promotion of the property as well as a clearer protocol concerning any new and major developments, stronger regulation and control of tourism developments, wider understanding of heritage value by stakeholders and enhanced tourism management.

While there is no indication that the proposed university in Bai Dinh will develop into a project in the immediate future, the State Party should keep the Committee updated on possible changes of the project status. While the State Party does not perceive a current need for an SEA in this regard, the Committee’s previous recommendation for an SEA had the objective to encourage comprehensive planning in the buffer zone beyond this particular project and is thus still considered valid. In that regard, it should be recalled that the IUCN Evaluation had noted that “protection of the nominated property must have primacy in considering any permissible activities and developments”.  Furthermore, it appears that there are no clear mechanisms in place to fulfil the need for impact studies within the property and its buffer zone before the construction of new buildings and amenities.

The State Party’s report highlights a number of developments and construction of infrastructures such as the visitor centre at Tam Coc wharf, private tourism facilities, the car park and the small temple, while leaving it unclear whether measures are in place to ascertain that these developments are carried out after proper study of potential heritage loss and their impact on OUV. Therefore, a clear process needs to be elaborated for Environmental and Heritage Impact Assessments (EIAs and HIAs) to be carried out prior to any developments within the property and its buffer zone. The information provided on the planned reintroduction of the Delacour’s Langur is limited. Should the State Party wish to proceed, engagement with IUCN’s Species Survival Commission is strongly encouraged.

In light of the abovementioned concerns related to tourism and visitor management, and unregulated tourism development, it is recommended that the Committee request the State Party to invite a joint World Heritage Centre/ICOMOS/IUCN Reactive Monitoring mission to the property, in order to assess its current state of conservation, and to provide further technical advice on these issues.