Ancient City of Nessebar

• Lack of a Management Plan 
• Urban development pressure 
• Lack of an urban master plan and of a conservation master plan of monuments and archaeological sites 
• Illegal constructions 
• Housing
• Impacts of tourism/visitor/recreation
• Management Systems/Management plan
• Marine transport infrastructure

N/A

On 30 November 2022, the State Party submitted a state of conservation report which is available at https://whc.unesco.org/fr/list/217/documents/. Progress on a number of conservation issues addressed by the Committee at previous sessions is presented in that report, as follows:

• In March 2022, the Council of Ministers established a permanent high-level Inter-Institutional Commission, assisted by a working group, which met in October 2022;
• Following underwater archaeological investigations, research necessary to request a Minor Boundary Modification has been completed;
• The ‘General Plan for the Organisation of the Traffic’ was adopted in January 2022;
• In September 2022, the Municipality of Nessebar commissioned the preparation of a ‘Strategy for Cultural Heritage in the Municipality’;
• The terms of reference for the development of the Conservation and Management Plan (CMP) were prepared and approved. The National Institute for Immovable Cultural Heritage (NIICH) along with external experts will prepare the plan;
• The draft General Development Master Plan (GDMP) requires thorough revision or re-procurement, as it was referred by the Ministry of Environment in October 2021 for the third time following the outcomes of the Impact Assessment Report;
• As per national legislation on spatial planning, no Detailed Development Plan (DDP) can be prepared until a GDMP is in force. Therefore, the DDP for the Ancient City of Nessebar and its buffer zone is delayed;
• The Integrated Development Plan for Nessebar Municipality 2021-2027 was adopted in August 2021, and a municipal tourism programme was added as per national legal requirements;
• Urban design guidelines are provided in the Prescriptions for Preservation of the Regimes, approved in 2015 and supplemented by a Municipal resolution in 2019 and an ordinance in 2021;
• Monitoring has been carried out in Nessebar as part of a regional programme. Aerial surveys were conducted in 2021-2022 and the outcomes are currently being compiled;
• An inventory of the building permits issued by Nessebar Municipality between March 2011 and October 2022 for all projects within the property or its vicinity has been compiled;
• Funding has been secured for underwater archaeology, rescue archaeology, conservation of a windmill and exhibitions on the natural and cultural heritage of the property;
• Conservation works were carried out on immovable and movable heritage objects;
• A report entitled ‘Heritage Impact Assessment for Investment Intent for a New Development in the Territorial Scope of the Ancient Necropolis of Mesambria, in the Security Area of the World Cultural Heritage Ancient City of Nessebar’ was sent to the World Heritage Centre in October 2022, in accordance with Paragraph 172 of the Operational Guidelines.

A joint World Heritage Centre/ICOMOS Reactive Monitoring mission to the property took place from 16 to 20 January 2023. Its main purpose was to ascertain the progress made by the State Party in implementing the Committee’s Decision 44 COM 7B.154 and the recommendations of the 2018 joint WHC/ICOMOS Reactive Monitoring mission to the property, as well as to assess the overall state of conservation of the property and whether it met the criteria for inscription on the List of World Heritage in Danger, in accordance with Paragraph 179 of the Operational Guidelines. The report of the mission is available at https://whc.unesco.org/en/list/217/documents.

Following the mission, the State Party submitted to the World Heritage Centre, on 31 January 2023, a Minor Boundary Modification request to include all the underwater archaeological remains of the ancient town, for consideration by the extended 45th session of the World Heritage Committee. The State Party also shared with the World Heritage Centre the final draft of the Cultural Heritage Strategy of Nessebar Municipality.

On 5 June 2023, the State Party provided to the World Heritage Centre its comments in response to its request for notification of factual errors in the Reactive Monitoring mission report. In this correspondence, the State Party also provided additional updates on the state of conservation of the property and on the implementation of the Committee Decision 44 COM 7B.154, concerning in particular: (i) the imminent launch of a procedure to draft an ordinance to assist the residents of the Ancient city of Nessebar in preserving immovable cultural properties; (ii) urgent measures taken by the NIICH to increase its administrative capacity by creating a new department with 17 full-time staff; (iii) the completion in 2023 of the largest project in Bulgaria to digitise the Ancient City of Nessebar, carried out by the teams from the NIICH and the company Vekom Geo Bulgaria, creating a 3D copy of the Ancient City with 120 digitised single immovable cultural properties; (iv) a meeting of the high-level Inter-Institutional Commission and its expert working group on 5 June 2023 to discuss the report of the joint World Heritage Centre/ICOMOS Reactive Monitoring mission.

The State Party has made some progress in addressing previous Committee’s recommendations. However, the most important requests (notably, to submit to the World Heritage Centre for review by the Advisory Bodies, the Conservation Management Plan, the DDP and the GDMP for examination by the World Heritage Committee at its 46th session), remain unfulfilled and no clear timeframe for progress has been provided.

The high-level Inter-Institutional Commission was established in March 2022 and held two meetings in 2022 and one meeting in 2023.

The proposal for a Minor Boundary Modification to include underwater archaeology within the boundaries of the property was submitted for examination by the Committee at the present session. Progress on underwater archaeological investigations, inventory of cultural heritage and building permits, prevention of new development, traffic regulation, and conservation of the churches is acknowledged.

The Integrated Development Strategy for Nessebar 2021-2027 was approved in August 2021. However, it should be noted that its vision for Nessebar’s future revolves entirely around tourism, with the property identified as the key attraction for a more visitors and a longer tourist season. Excessive focus on tourism, combined with a lack of adequate spatial planning tools including on visitors’ management, will only exacerbate the threats already identified in previous missions and state of conservation reports.

The draft ‘Strategy for Cultural Heritage of Nessebar Municipality’ is a positive step towards improving the positioning of cultural heritage in the development of Nessebar but requires considerable revision and further work to become the requested strategy based on the Outstanding Universal Value (OUV) of the property for the future of Nessebar. An ICOMOS Technical Review of the draft Strategy was transmitted to the State Party on 17 August 2023. The Review observes that the Strategy covers the entirety of the Nessebar Municipality and there is no clear distinction in the vision established for the municipality of what is needed for the World Heritage property. The identification of the attributes underlying the OUV needs to be strengthened, the threats in the SWOT analysis will need to be revised and better understood – i.e., the potential inscription of the property in the List of World Heritage in Danger cannot be considered as a threat, but rather all activities and transformations that have jeopardised the attributes of OUV should be enumerated – and a clarification of the links between specific objectives and the sustenance of Nessebar’s OUV and of implementing actors would be needed. An action plan, with priorities based on the gravity and urgency of issues to be tackled, with timeframes, actors and responsibilities for implementation, a budget to support the implementation of actions and an adequate monitoring system will have to be elaborated.

Key management and planning instruments, such as the property’s CMP, requested by the Committee since 2010, the GDMP for Nessebar municipality and the DDP, have not been completed and it remains unclear when they will be developed and enforced. Their finalisation, entry into force and implementation are of the utmost urgency, as noted in previous Committee’s decisions.

Meanwhile, the state of conservation has not improved. The January 2023 Reactive Monitoring mission confirmed the findings of the 2018 Reactive Monitoring mission, that the property is impacted by several negative factors and its integrity and authenticity are extremely vulnerable. In particular, the attributes that conveyed the OUV of the property at the time of inscription have deteriorated and some are eroded beyond recovery. The vernacular architecture has been severely undermined, and the urban fabric has lost its coherence and authenticity. The tangible traces of numerous civilisations are barely discernible, superseded by inappropriate, out-of-scale development and suffering from a lack of care for the archaeological vestiges. The relationship between the homogenous ensemble that harmoniously fits the property into its natural setting has suffered from the progressive erosion of its link with the outstanding configuration of the rocky peninsular. The dominance of the medieval churches over the vernacular urban ensemble is no longer distinguishable, and the vibrant urban organism has been severely affected by a tourism-based mono-economy that has turned the ancient city into a crowded tourist attraction in summer and an almost empty place in winter. These factors represent both ascertained and potential dangers to the OUV of the property, according to Paragraph 179 of the Operational Guidelines, due to a serious deterioration of the main attributes (notably vernacular architecture, archaeological vestiges, and surrounding sea coastline), and the lack of coherence of the town planning and the urban space, a significant loss of historic authenticity and of cultural significance, the lack of a conservation policy and the threatening effects of town planning to the extent that the property meets the conditions for inscription on the List of World Heritage in Danger.

It is to be noted that several threats had been identified and reported to the Committee in previous years, leading to Decisions 41 COM 7B.43, 43 COM 7B.81 and 44 7B.154, all of which foreshadowed that the Committee would examine the state of conservation of the property, with a view to considering, in the absence of substantial progress, its possible inscription on the List of World Heritage in Danger.

Although the State Party has made some progress, it is insufficient and too slow to redress the ongoing deterioration of the OUV of the property. A vision for the future of Nessebar has been proposed in the draft Strategy, but it remains rather general and not tied to the OUV of the property. The analysis on which it is based does not reflect the extreme vulnerability of the property and the emphasis on ‘balanced’ development remains focused on tourism, which has been the major cause of the erosion of the property’s attributes, even though diversification of the tourist audience is mentioned. Therefore, since there has not been substantial progress, and the property continues to face ascertained and potential dangers to its OUV, the World Heritage Centre and the Advisory Bodies recommend its inscription on the List of World Heritage in Danger, in accordance with Paragraph 179 of the Operational Guidelines.