State of Conservation
Liverpool – Maritime Mercantile City
(United Kingdom of Great Britain and Northern Ireland)
Factors affecting the property in 2019*
- Commercial development
- High impact research / monitoring activities
- Interpretative and visitation facilities
- Legal framework
- Management systems/ management plan
- Society's valuing of heritage
Factors* affecting the property identified in previous reports
- Governance: Lack of overall management of new developments
- High impact research/monitoring activities: Lack of analysis and description of the townscape characteristics relevant to the Outstanding Universal Value of the property and important views related to the property and its buffer zone
- Legal framework: Lack of established maximum heights for new developments along the waterfront and for the backdrops of the World Heritage property
- Social/cultural uses of heritage
- Buildings and development: Commercial development, housing, interpretative and visitor facilities
- Lack of adequate management system/management plan
Threats for which the property was inscribed on the List of World Heritage in Danger
The proposed development of "Liverpool Waters" project
Desired state of conservation for the removal of the property from the List of World Heritage in Danger
Corrective Measures for the property
Timeframe for the implementation of the corrective measures
International Assistance: requests for the property until 2019
Requests approved: 0
Total amount approved : 0 USD
Missions to the property until 2019**
October 2006: joint World Heritage Centre / ICOMOS Reactive Monitoring mission; November 2011: joint World Heritage Centre / ICOMOS Reactive Monitoring mission; February 2015: joint World Heritage Centre/ICOMOS Advisory mission
Conservation issues presented to the World Heritage Committee in 2019
On 11 February 2019, the State Party submitted a state of conservation report, which is available at https://whc.unesco.org/en/list/1150/documents/, as well as a further revised and updated proposed Desired state of conservation for the removal of the property from the List of World Heritage in Danger (DSOCR), providing the following information:
- Additional documents on which the DSCOR relies, are not finalized owing to national statutory processes. The timeframe for developing these documents in the draft DSOCR has been rescheduled to later dates.
- The draft Local Plan is currently under public examination; Liverpool City Council (LCC) will consider its adoption by November/December 2019. The Supplementary Planning Document of 2008 will be updated in parallel with the Liverpool Local Plan;
- LCC has also commissioned the preparation of Supplementary Framework Documents for the Baltic Triangle, the Central Business District, The Knowledge Quarter Gateway and the Williamson Square/ Cavern Quarter District. Their adoption by LCC is foreseen for 2019;
- Masterplans for each of the five neighbourhoods of Liverpool Waters will be developed, before any development takes place in these areas. The Princes Dock Neighbourhood Masterplan has already been submitted and approved by LCC in June 2018, while amendments were approved in October 2018. The Central Docks Masterplan is scheduled to be reviewed and approved by LCC in March/April 2019;
- A Tall Buildings Policy is being developed and will form part of the Liverpool Local Plan and a Tall Buildings Panel has recently been appointed;
- There is continued commitment of all stakeholders to raise awareness of the values of the property and increase engagement with civil society. A short summary was provided on works undertaken to improve the condition of buildings within the property.
The State Party reiterates its opinion that developments within Liverpool Waters to date have not adversely impacted on the Outstanding Universal Value (OUV) of the property, and that the set of corrective measures, proposed in the draft DSOCR, will prevent potential harm. In the view of the State Party, the existing governance system is adequate to protect the OUV of the property. The State Party does not consider it either desirable or practical, to impose a moratorium for new buildings within the property and its buffer zone, as the current planning regime is sufficient to protect the OUV, the authenticity and integrity of the property.
In November 2018, the State Party provided new information to the World Heritage Centre that the old Bramley-Moore Dock and Nelson Dock neighbourhood has been identified as a possible site for a new football stadium. Negotiations between Everton Football Club, LCC and Peel Holdings have started and the Club has initiated and conducted a public consultation regarding the principle of developing a stadium in the above-mentioned area.
Analysis and Conclusion by World Heritage Centre and the Advisory Bodies in 2019
The state of conservation report and DSOCR reflect continuing focus on individual planning documents, which are part of internal national statutory processes, whereas the Decision of the Committee to provide substantive commitments to limitations on the quantity, location and size of allowable built forms has not been followed.
The approach of the proposed DSOCR relies heavily on individual planning documents, namely the updated Local Plan and Supplementary Planning Document, the five Neighbourhood Masterplans of the Liverpool Waters development and the Tall Building Policy. Progress is reported with development of these documents, but they seem to be developed separately and according to longer timeframes than previously indicated and without an overall strategic vision on the desired outcome and long-term preservation of OUV. This approach will not allow the World Heritage Centre and the Advisory Bodies to review and endorse these documents together with the proposed DSOCR in a comprehensive manner. The State Party concedes that because these additional documents are not finalized, the DSOCR document is not ready to be assessed.
Changes to the Liverpool Waters Masterplan were formally approved by LCC on 16 November 2018. The Princes Dock Neighbourhood Masterplan was transmitted to the World Heritage Centre and ICOMOS only after approval by LCC, and at the time of preparing this document, the draft of the Central Docks Masterplan has not been sent to the World Heritage Centre for consultation prior to its foreshadowed approval in March/April 2019. The content of these documents are also cause for concern, as they reflect inadequate mitigation measures on the potential threats, which were originally put forward by the Reactive Monitoring Mission of 2011, and were the basis for inscribing the property on the List of World Heritage in Danger.
The integrity and authenticity of the property is also threatened by a new project, the potential construction of a new stadium for the Everton Football Club on the site of the historic Bramley-Moore Dock, within the property. The public consultation program within the city has received a very strong response supporting this location as the construction site for a new stadium. Plans have also received wide media publication in early 2019. This proposal is against the previous Committee Decisions for further developments, and it is regrettable that the consultation process did not adequately address potential impacts on the OUV of the property nor alternative locations, and the public was not informed about the potential negative consequences of an additional factor adding to the already recognised threats to the OUV of the property, which led to potential delisting as per Decisions 36 COM 7B.93, 37 COM 7A.35, 38 COM 7A.19, 40 COM 7A.31, 41 COM 7A.22 and 42 COM 7A.7. This provides further evidence of a process that is systemically excluding heritage concerns and conservation outcomes from incremental overdevelopment.
The State Party’s advice, repeated by Peel Holdings (Liverpool Waters developer), that there is no likelihood of the scheme coming forward in the same form as in the Outline Planning Consent (OPC) is reassuring. However, the assurances that developments shall not take place prior to the completion of the Neighbourhood Masterplans does not align with information provided to the World Heritage Centre by the State Party, in conformity with Paragraph 172 of the Operational Guidelines, relating to developments within the area of the Liverpool Waters development by different developers in West Waterloo Dock (part of Central Docks), where no Neighbourhood Masterplan has been reviewed. According to information received from the State Party, developments can be brought forward because of flexibility in the OPC, and applications have already been submitted for developments, which could already be in a construction phase. In previous years, planning proposals were approved by LCC and some are currently under construction, despite the Committee’s regret due to their negative impact on OUV. The current planning regime is not adequate to protect the OUV of the property. It would therefore be appropriate for the Committee to recall its Decision for a moratorium on new constructions within the property and its buffer zone, until the DSOCR is completely finalized and approved by the Committee.
The requests of the Committee at its 41st and 42nd sessions have not been satisfactorily addressed. There is no demonstrable commitment to limit the quality, location and size of allowable built form. Despite assurances to the contrary, the ongoing incremental approval and construction of individual new developments continue to erode the integrity of the property.There are no mechanisms in place to prevent the implementation of the Liverpool Waters scheme from having a major negative impact on the OUV of the property. The planned potential new football stadium in Bramley-Dock would add ascertained threat of the property’s OUV. The property should therefore remain on the List of World Heritage in Danger, with a view to considering its deletion from the World Heritage List at the 44th session of the Committee, in line with Paragraph 192 of the Operational Guidelines.
Decisions adopted by the Committee in 2019
Draft Decision: 43 COM 7A.47
The World Heritage Committee,
- Having examined Document WHC/19/43.COM/7A,
- Recalling Decision 36 COM 7B.93, 37 COM 7A.35, 38 COM 7A.19, 39 COM 7A.43, 40 COM 7A.31, 41 COM 7A.22 and 42 COM 7A.7 adopted at its 36th (Saint Petersburg, 2012), 37th (Phnom Penh, 2013), 38th (Doha, 2014), 39th (Bonn, 2015), 40th (Istanbul/UNESCO, 2016), 41st (Krakow, 2017) and 42nd (Manama, 2018) sessions respectively;
- Acknowledges the increasing engagement of civil society in the care of the property and its World Heritage status;
- Recalls its repeated serious concerns over the impact of the proposed Liverpool Waters developments in the form presented in the approved Outline Planning Consent (2013-2042) which constitutes an ascertained threat in conformity with paragraph 179 of the Operational Guidelines;
- Although noting that the State Party has submitted an updated and revised draft Desired state of conservation for the removal of the property from the List of World Heritage in Danger (DSOCR), notes that comprehensive assessment of the proposed DSOCR by the World Heritage Centre and the Advisory Bodies is still not feasible, as the approval of the DSOCR relies on the content of additional documents, which are yet to be prepared or finalized, including the Local Plan, the revised Supplementary Planning Document, the majority of the Neighbourhood Masterplans, and the Tall Building (skyline) Policy;
- Reiterates that the submission of a further draft of the DSOCR by the State Party and its adoption by the Committee should come prior to the finalization and approval of the necessary planning tools and regulatory framework and regrets that the alternative proposal of the Committee, expressed in Decision 42 COM 7A.7, for substantive commitments to limitation on the quantity, location and size of allowable built form, has not been followed;
- Although also noting that Peel Holdings (Liverpool Waters developer) reiterated its confirmation to Liverpool City Council (LCC) that there is no likelihood of the Liverpool Waters development scheme coming forward in the same form of the Outline Planning Consent, strongly requests the commitment of the State Party that the approved Outline Planning Consent (2013-2042) will not be implemented by Peel Holdings or other developers, and its revised version will not propose interventions that will impact adversely on the Outstanding Universal Value (OUV) of the property, including its authenticity and integrity;
- Expresses its extreme concern that the State Party has not complied with the Committee’s request to adopt a moratorium for new buildings within the property and its buffer zone, until the Local Plan, the revised Supplementary Planning Document, the Neighbourhood Masterplans, and the Tall Building (skyline) Policy are reviewed and endorsed by the World Heritage Centre and the Advisory Bodies, and the DSOCR is completely finalized and adopted by the World Heritage Committee, and urges the State Party to comply with this request;
- Also regrets that the submission of Princes Dock Masterplan and changes to the Liverpool Water scheme to the World Heritage Centre took place after their adoption by the LCC, and expresses its utmost concern that these documents are putting forward plans, which does not ensure the adequate mitigation of the potential threats for which the property was inscribed on the List of World Heritage in Danger;
- Also reiterates its consideration that the recent planning permissions issued for the Liverpool Waters scheme and elsewhere within the property and its buffer zone, and the stated inability of the State Party to control further developments, clearly reflect inadequate governance systems and planning mechanisms that will not allow the State Party to comply with Committee Decisions and will result in ascertained threat on the OUV of the property;
- Finally requests the State Party to submit to the World Heritage Centre, by 1 February 2020, an updated report on the state of conservation of the property and on the implementation of the above, for examination by the World Heritage Committee at its 44th session in 2020, as well as a DSOCR and corrective measures that could be considered for adoption by the Committee;
- Decides to retain Liverpool – Maritime Mercantile City (United Kingdom of Great Britain and Northern Ireland) on the List of World Heritage in Danger, with a view to considering its deletion from the World Heritage List at its 44th session in 2020, if the Committee Decisions related to the adoption of the DSOCR and the moratorium for new buildings are not met.
The threats indicated are listed in alphabetical order; their order does not constitute a classification according to the importance of their impact on the property.
Furthermore, they are presented irrespective of the type of threat faced by the property, i.e. with specific and proven imminent danger (“ascertained danger”) or with threats which could have deleterious effects on the property’s Outstanding Universal Value (“potential danger”).