Cornwall and West Devon Mining Landscape

• Resumption of mining activities
• Harbour development

On 30 January 2013, the State Party submitted a state of conservation report, including further details on the resumption of mining at South Crofty and the development proposal for Hayle Harbour.

a)  The resumption of mining at South Crofty

The State Party reiterated its view that the resumption of mining at the South Crofty site, which would relocate mining activities from outside the property to just inside the boundaries, would not have any negative impact on the Outstanding Universal Value (OUV) of the property, noting that the OUV of the property is linked to the long tradition of mining present at the property. It further pointed out that while the South Crofty mine ceased operations in 1998, it has retained its classification as an active mine and that the current proposal should therefore, in its view, be seen not as a new proposal, but the resumption of an already existing activity. It further noted that the management plan submitted at the time of inscription recognized the possibility of restarting mining activities where they do not have an adverse impact on the OUV of the property.

The State Party stated that a full Environmental Impact Assessment (EIA) has been carried out for the proposed resumption of mining, including an assessment of the impact of the development on the OUV of the property. It also reported on discussions between the developer, Cornwall Council, and English Heritage leading to a considerable redesign of the new mine building, which is now considered by English Heritage not to have an adverse impact on the OUV of the property. The State Party further stated that there would be no new waste tips above ground. Rock waste would be used as secondary aggregate or stored in the mine voids underground and fine tailings would be treated and transported or pumped back underground into the mine voids.

In regard to the recommendation by the Committee that the State Party consider a significant boundary modification to exclude the proposed mining activities from the property, the State Party is of the opinion that such a modification would not protect the OUV in regard to important views or other impacts. It considers as well that a significant boundary modification would correspond to a new nomination and that the preparation would be excessively costly.

The World Heritage Centre and the Advisory Bodies wish to point out that the property was inscribed for its exceptional contribution to the mining industry for the period 1700 to 1914 and the attributes have been identified accordingly. It is thus inscribed as a relict cultural landscape, in spite of the designation of the South Crofty component as an ‘active’ mining site at national level. The continuing evolution of the cultural landscape and mining traditions is not, therefore, part of the justification for the criteria. Any mining activity needs to be looked at from the point of view of its impacts on the attributes from the period of 1700 to 1914 that have been identified as contributing to the OUV, the authenticity and integrity of the property and its setting. They further note that the boundary of the property was carefully drawn to exclude the South Crofty mine that had only recently been closed and was still technically a working mine.

The World Heritage Centre and the Advisory Bodies further point out that the Committee at the time of inscription, recognized the vulnerability of the property to any future mining activities and therefore specifically requested that any proposals concerning the re-opening of mines in the property be forwarded to the World Heritage Committee for debate and scrutiny (30 COM 8B.50, paragraph 4). They also note that this vulnerability has also been recognized in the retrospectively adopted Statement of OUV in 2010 (34 COM 8E). According to the conditions of authenticity, the features expressing the property’s OUV that are located in the areas of Redruth and Camborne are particularly vulnerable to developments.

The World Heritage Centre and the Advisory Bodies note that an EIA has been carried out, assessing the impact on the component part of the property near the mine, but not assessing the impact on the OUV of the serial property as a whole. The EIA, although considering World Heritage status, does not consider in detail the reasons for inscription nor the attributes of OUV of the serial property. More attention is given to considering the impact of the new building on important views but no details are provided on the way the area around the mine contributes to the OUV of the serial property. The EIA also notes that the effects of the past mining operations have not been completely mitigated and are detrimental to the character of the wider area. It considers that the “South Crofty Mine site can be said to be a poorexample of the Cornish Killas and Redruth, Camborne and Gwennap landscape character areas”. These current conditions could be further exacerbated by resuming mining operations. The EIA has thus been technically carried out but falls short of a thorough cultural Heritage Impact Assessment.

b)  Development Proposal for Hayle Harbour

In its report, the State Party recalled that on 14 March 2012 the Secretary of State decided not to call in the application. The decision to grant planning permission therefore remained with the Cornwall Council which can now confirm permission.

English Heritage has maintained its objection. The Cornwall Council is reported to consider the supermarket development as the only viable solution for sustainable development and use of the South Quay at HayleHarbour. It is found that funds made available as a result of the project will allow reinstituting the traditional system of dredging the harbour on a regular basis. Restarting the traditional dredging system would allow the continuing functioning of the harbour, avoid the worst effects of flooding, and also avoid the need to build a sea wall which would also impact on the OUV of the property. The State Party further pointed out that the proposed supermarket development would occupy approximately 24% of the land which roughly corresponds to the historical land coverage in that part of HayleHarbour. The State Party concluded that the proposed development at Hayle Harbour would help preserve the property as a whole, for the sake of which it may be necessary to accept a degree of adverse impact.

The World Heritage Centre and the Advisory Bodies note that the State Party itself has acknowledged that there will be adverse impact if the supermarket development was implemented as designed. The problem with the development as currently proposed is the intensity of construction and in particular the massing, scale, and design of the supermarket, rather than the percentage of the footprint. The World Heritage Centre and the Advisory Bodies consider that the supermarket will have a high adverse impact on the ability of Hayle Harbour to display its role as the port through which much of the copper and tin was exported, and which has been the primary reason for including it in the serial property. The proposals would therefore impact adversely on the integrity and authenticity of this component part of the property. The World Heritage Centre and the Advisory Bodies consider that there may be design solutions of a less intense nature which could be compatible with the OUV of the property.

The World Heritage Centre and Advisory Bodies are in full agreement with the State Party that the traditional dredging system for the harbour would be the best way to ensure that it continues its good functioning and reduces the risks of flooding. They do not, however, see an inextricable link between the traditional dredging system and the current supermarket proposal. It may be possible through different design solutions, or other sources of funding, to allow for maintaining the traditional dredging system.

Finally, the World Heritage Centre and the Advisory Bodies note that consent for the development has been granted and that according to the State Party no other regulatory or administrative obstacles would halt the development from going forward. The World Heritage Centre and the Advisory Bodies nevertheless consider that in order to maintain the relevance of this component to the series, other options must be explored.

c)  Other Issues

Waste Management Facility at the Gwennap Mining District

The State Party reported that this facility is not located within the World Heritage property, although it is located within its setting. It further stated that its proximity to the World Heritage property was considered when the scheme was examined and that the State Party’s statutory advisors have found no adverse impacts on the World Heritage property.

Robinson’s Shaft Site in Pool and Consolidated Mines near Crofthandy

The State Party reported that it has obtained funds from various sources to carry out conservation and interpretation work at the two mentioned components of the property.

Reporting on other Developments in Conformance with Paragraph 172 of the Operational Guidelines

The State Party reported that it is aware of a proposal for exploratory drilling at the Redmoor Mine (which closed around 1908) in the Tamar Valley area of the property, as well as of a proposal for a mixed use development on land adjacent to Callington Road, Tavistock, Devon, including housing, commercial buildings, open space, educational and health care facilities, and the reinstatement of a railway line. The majority of this latter project will be located outside the World Heritage property but it may impact on its setting.

The World Heritage Centre and the Advisory Bodies underline the importance of the Committee’s request, at the time of inscription, that any proposals for mining within the property be referred to the World Heritage Committee for debate and scrutiny. Acknowledging the report of the State Party that an EIA has been carried out (although this is limited to impacts on the setting of the mine), that modifications have been made to the design of the main building (although no new plans have been submitted) and that the issue of management of the mine waste has been addressed, the World Heritage Centre and the Advisory Bodies would recommend to request that comprehensive latest information be forwarded to the World Heritage Centre so that it can be evaluated by the Advisory Bodies. They do not consider, at this time, that sufficient information has been provided by the State Party to demonstrate that the resumption of mining at South Crofty will not have a negative impact on the OUV of the serial property, and hence that the resumption of mining cannot be justified on the basis of the arguments brought forward by the State Party. The requested further information is necessary to evaluate the potential impacts of mining activities on the setting of the property. While appreciating the information provided by the State Party, the World Heritage Centre and the Advisory Bodies are of the view that a more in-depth assessment of the proposed project is necessary, including visual documentation (plans, elevations, landscape views and other photographs and drawings which show the design and its relationship with the property and its surroundings), in order to establish its impact on the attributes expressing the property’s OUV, including underground attributes. It would be important to be able to evaluate the most current state of the development proposal. They also consider that the issue as to whether mining might impact adversely on OUV needs to be set into the context of the Committee’s past decisions on mining in World Heritage properties, and of the ICMM Position Statement not to explore or mine in World Heritage properties. Finally, the World Heritage Centre and the Advisory Bodies point out that consideration of the Management Plan at the time of inscription as an adequate system does not mean approval of every part of the document. As a planning tool, provisions made at the time of inscription need to be revised to respond to diverse emerging conditions, always in relation to the need to sustain OUV.

The World Heritage Centre and the Advisory Bodies also note that exploratory drilling is being undertaken at the Redmoor mine within the property in the Tamar Valley, and that this might lead to further applications to re-instate mining activities. They consider that it is essential that applications for new mining activities do not overlap with the property and do not impact adversely on OUV.

In regard to the proposed supermarket development at Hayle Harbour, the World Heritage Centre and the Advisory Bodies consider that the current supermarket development proposal would have a potential negative impact on the authenticity and integrity of Hayle as a port and harbour and thus on the OUV of the serial property, and recall the Committee’s request to the State Party at its 36th session to consider a smaller-scale heritage-led regeneration. As the supermarket development project has not been altered and as there are apparently no regulatory or administrative mechanisms remaining to halt or alter the design, the World Heritage Centre and the Advisory Bodies would advise the Committee to consider placing the property on the List of World Heritage in Danger in 2014, should the development project be implemented as currently planned.

Based on the above, the World Heritage Centre and the Advisory Bodies propose that the World Heritage Committee request the State Party to invite a joint World Heritage Centre/ICOMOS/ICCROM reactive monitoring mission to the property in order to assess the overall state of conservation of the property and the strategies in place to deal with mining exploration and sustainable development within the whole serial property.