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Liverpool Waters
Heritage ImpactAssessment
Non-Technical SummaryNovember 2011
www.liverpoolwaters.com
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Liverpool Waters
Heritage Impact Assessment Non-Technical Summary November 2011
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1.0 NON-TECHNICALSUMMARY
1.1 INTRODUCTION
1.1.1 An outline planning application was submitted in October 2010 by Peel Land and Property (Ports)
Ltd for development involving the regeneration of a sixty hectare historic dockland site at
Liverpool Waters. Following detailed consultation, the development proposals were substantially
amended. This report provides an assessment of the potential impact of the revised development
proposals on the Liverpool World Heritage Site (WHS).
1.1.2 The Heritage Impact Assessment (HIA) has been carried out in strict accordance with the
International Council on Monuments and Sites (ICOMOS) Guidance on Heritage Impact
Assessments for Cultural World Heritage Properties(2011), a methodology which was prepared at
the request of the World Heritage Committee. The report focuses solely on heritage issues, and
does not take account of wider benefits, which are addressed in other planning application
documents.
1.1.3 The assessment has been undertaken by Peter de Figueiredo, architect and historic environment
consultant, with over thirty five years experience of conservation and regeneration in the public
and private sectors. As Historic Buildings Inspector for English Heritage, he was involved in
securing the inscription of the Liverpool Maritime Mercantile City World Heritage Site, and served
on the Liverpool World Heritage Site Steering Committee. His publications include books and
articles onLiverpools historic architecture, and he serves as a member of the NW Design Review
Panel.
1.1.4 The assessment relies on the understanding of heritage significance set out in the Baseline
Archaeological and Cultural Heritage report on the Liverpool Waters site and its setting. The
Baseline report was subsequently developed in more detail in the Cultural Heritage and
Archaeology Chapter of the Environmental Statement and in the preparation of an Archaeological
Deposit Model for the site. These technical reports are included as appendices to the HIA.
1.1.5 World Heritage Sites are recognised under the World Heritage Convention to be of Outstanding
Universal Value (OUV) through inscription on the World Heritage List. The concept of OUV is
encapsulated at the time of inscription in a Statement of OUV, which clearly defines its
international value. Applications for consent within a WHS or its Buffer Zone are assessed for
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their potential impact on OUV, as well as the aspects of integrity and authenticity which are also
defined in the Statement of OUV.
1.2 SCOPE AND METHOD OF ASSESSMENT
1.2.1 The ICOMOS methodology used in this report states that assessments should provide the
evidence on which decisions can be made in a clear, transparent and practicable way, and states
that the assessment process is in essence very simple:
1. What is the heritage at risk and why is it important how does it contribute to OUV?
2. How will change or a development proposal impact on OUV?
3. How can these effects be avoided, reduced, rehabilitated or compensated?
1.2.2 In order to reach such decisions, the potential impact of development on aspects of the historic
environment that convey OUV has been assessed under the following six categories:
Direct impacts on a schedule of heritage assets identified as reflecting OUV
Impact on key views of and from the Liverpool Waters site identified in pre-application
discussions
Impact on views and setting of strategic landmark buildings within the WHS and buffer
zone
Impact on townscape characteristics and setting of the six defined Character Areas that
make up the WHS
Compliance with guidance in Liverpool City Councils WHS Supplementary Planning
Document (which sets out detailed policy and design guidance for protecting the OUV of
the Liverpool WHS)
Cumulative Impact Assessment on OUV
1.2.3 In the methodology used, heritage resources are evaluated in accordance with statutory
designations, and assessed for their contribution to OUV. The assessment draws on the English
Heritage Conservation Principles, 2008 for guidance on evaluation of significance, and the English
Heritage guidance Seeing the History in the View, 2011 for views analysis.
1.2.4 The scale or severity of impacts are judged taking account of both direct and indirect effects and
then weighted in accordance with the value ascribed to the heritage asset or view. In evaluating
the overall impact on OUV, careful consideration has been give to the balance of benefits and
disbenefits, and in order to reach a balanced judgement consideration has also been given to who
will benefit.
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1.3 DESCRIPTION OF THE LIVERPOOL WATERS SITE
1.3.1 The Liverpool Waters development proposes regeneration of 60 hectares of mostly redundant
former dockland to the north of the Pier Head and south of the operational docks. The site is
bounded by the River Mersey to the west, and the dock boundary wall to the east. Virtually all the
land was reclaimed from the river in order to create the docks, and over one third consists of
open water spaces. Most of the docks were historically surrounded by single storey transit sheds
of varying dates, all but one of which have been cleared. A number of docks were infilled in the
mid to late 20th century, including the Clarence Dock, which was used for construction of a coal-
fired power station (demolished in the 1990s). Immediately to the west of that area, a canal
acting as an extension of the Leeds and Liverpool Canal has recently been constructed.
1.3.2 As well as the area of obsolete docklands from West Waterloo Dock north to Bramley-Moore Dock
which consists of wholly infilled docks, partially infilled docks, graving docks and water-filled
docks, the site also includes Princes Dock, which has been partly developed since the late 1990s,
and King Edward Industrial Estate, which consists of single storey industrial units from the late
20th century.
1.4 HERITAGE SIGNIFICANCE OF THE SITE
1.4.1 40% of the Liverpool Waters site is within the Liverpool Maritime Mercantile City World Heritage
Site, and makes up about 22% of the whole inscribed Site. It is of special value for the group of
surviving historic docks, the dock boundary wall and the general dockland landscape. As well as
the dock basins, within the site there are historic buildings and structures including the Victoria
Clock Tower and the Dock Masters Office, as well as original dockyard surfaces incorporating
capstans, bollards and rail tracks. Just outside the development site are important structures such
as the Stanley Dock with its massive Tobacco Warehouse, the Leeds and Liverpool Canal, and the
Waterloo Warehouse.
1.4.2 The Liverpool World Heritage Site was designated as the supreme example of a commercial port
at the time of Britains greatest global influence. Its outstanding universal value stems from
three factors:
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Liverpool played a leading role in the development of dock construction, port
management and international trading systems in the 18 th and 19th centuries;
Buildings and structures of the port and the city are an exceptional representation of
mercantile culture;
The city had a major influence on the worldwide movement of population and change in
the 18th and 19th centuries through its involvement in the transatlantic slave trade, and as
the leading port of mass European immigration to the New World.
1.4.3 The Liverpool WHS therefore represents the mercantile and maritime history of Liverpool. The
Liverpool Waters site lies within one of six areas of distinct character which together comprise the
WHS, each reflecting different patterns of historic growth.
1.5 DESCRIPTION OF THE PROPOSED DEVELOPMENT
1.5.1 The Liverpool Waters site is in need of economic and environmental regeneration, and the
development is intended to create a high quality mixed-use waterfront quarter in the city centre.
This will allow for substantial growth of the citys economy and residential numbers based on a 30
year development programme.
1.5.2 The purpose of the outline planning application is to allow Liverpool City Council to make a
decision on the general principles of how the site can be developed acceptably. Such an
application allows for agreement to be reached on the amount and nature of development that
can take place on the site prior to preparing detailed proposals.
1.5.3 The master plan creates a number of distinct neighbourhoods each with its own character,
related to the existing pattern of dock water spaces and land form, with its own grain, network of
public spaces, and connecting pedestrian and vehicular routes. It will provide ease of movement
and connections between Northshore, its hinterland and the city centre. It is intended to
accommodate new and existing residents, attract national and international businesses and
encourage a significant increase in the number of visitors to the city.
1.5.4 The application sets parameters (measurable factors that together define the development in
principle) for the height of buildings, floor areas and the amount of each proposed land use. At
the south east corner of the site, it is proposed to reinforce the existing cluster of tall buildings in
the commercial district, including the Shanghai Tower, which would occupy a site on the eastern
side of Princes Dock, with a new public space linking the building across the dock to the
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waterfront. To the north of Princes Dock it is proposed to introduce a new cruise ship facility and
a cultural venue. A secondary cluster of tall buildings is proposed in the area of the former
Clarence Dock power station, set between a central public space and the existing canal link. The
area north of the Clarence Graving Docks is proposed to be developed with medium rise blocks
occupying the sites of former transit sheds around the perimeter of the large water spaces.
1.5.5 The application includes a programme for the repair, refurbishment and reuse of all the historic
structures on the site in accordance with a conservation management plan. The movement
strategy has been developed to take advantage of existing openings through the dock wall and
proposes one new vehicular opening opposite Dublin Street, to the south of the Stanley Dock,
and one pedestrian opening at Princes Dock to provide direct connectivity between the site of the
Shanghai Tower and the existing commercial district.
1.6 SUMMARY OF FINDINGS OF THE ASSESSMENT
Summary of Direct and Indirect Impacts on Heritage Assets
1.6.1 Assessment of the revised proposals shows that the impact on the physical fabric and the setting of
heritage assets (scored on a 1:1 basis) will be as follows
Verylargebeneficial
Largebeneficial
Moderatebeneficial
Slightbeneficial
Neutral
Slightadverse
Moderateadverse
Largeadverse
Verylargeadverse
1 13 9 17 1 1
1.6.2 The assessment demonstrates overwhelming benefits for OUV in terms of impacts on fabric and
setting of heritage assets. The application provides a commitment to a programme of conservation
to all above-ground heritage assets, which will halt their continued decline and restore them to
beneficial use. The impact on below-ground remains will be neutral, although the programme of
archaeological evaluation/mitigation has the capacity to provide slight/moderate benefits in terms
of the archaeological resource and understanding of the history of the docks.
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1.6.3 Any adverse impacts identified in the assessment will be due to changes in the setting of heritage
assets arising from the proximity of new development. Such impacts, which are generally assessed
as minor, are inevitable since the existing setting is artificially open and uncontained. The one case
of moderate adverse impact to the West Waterloo Dock is as a result of partially building over
the 1949 river entrance, and partial infilling the water body for the construction of the cruise liner
terminal. Mitigation as proposed would reduce the impact to slight adverse .
Summary of Impacts on Key Views
1.6.4 Assessment of the revised proposals shows that the impact on key views will be as follows
Verylargebeneficial
Largebeneficial
Moderatebeneficial
Slightbeneficial
Neutral
Slightadverse
Moderateadverse
Largeadverse
Verylargeadverse
1 4 5 35 7 5
1.6.5 The assessment finds that adverse and beneficial impacts are evenly balanced. Where negative
impacts have been identified, there are three principal causes:
The effect of tall buildings in the commercial district cluster on the silhouette of
the Three Graces when seen from the Albert Dock and Hartley Quay. In these
views, the tall buildings appear behind the towers of the Liver Building and the dome of
the Port of Liverpool Building. Foreground and skyline buildings have been added to this
view in recent years but the Three Graces remain prominent by virtue of their colour,
position and composition as a group. Liverpool Waters will add to the skyline views in line
with Council guidance in the WHS SPD.
The effect of the riverfront blocks on visibility of the Stanley Dock Tobacco
warehouse and the Waterloo warehouse when viewed from Wallasey Town Hall.
This, however, is a consequence of the location of these warehouses several blocks back
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from the riverfront, and mitigation comes in the form of kinetic views from the Wirral
promenade, where the Stanley Dock will be gradually revealed, and will be more effective
as a conveyor of OUV, than the present largely featureless prospect.
The change in long views of the site from the Victoria Clock Tower and Regent
Road as a result of development on the site of the Clarence Dock. The change in
these views will be considerable, but largely as a result of the current artificial openness of
the site. Public access to the site and the waterfront views is a crucial mitigating factor.
1.6.6 Beneficial impacts are identified in kinetic views from the Wirral Promenade, and significantly along
the Canal Corridor, passing through the Stanley Dock Conservation Area, where the transformation
from an abandoned dockland site to a place of activity and vibrancy will recall the past history of
busy quayside activity that characterised the docks until their closure in the 20 th century. Positive
effects will also result in views from a number of locations due to the additional tall buildings in the
central commercial district, which will enhance the citys identity as a global maritime mercantile
centre.
Summary of Impacts on Views and Settings of the Landmark Buildings of the World
Heritage Site and Buffer Zone
1.6.7 Assessment of the revised proposals shows that the impacts on views and settings of landmark
buildings of the Liverpool WHS and Buffer Zone will be as follows:
Verylar
gebeneficial
Largebeneficial
Moderatebeneficial
Slightbeneficial
Neutral
Slightadverse
Moderateadverse
Largeadverse
Verylar
geadverse
14 2 1
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1.6.8 The majority of landmark buildings will remain unaffected by development. The three that are
affected are the Stanley Dock complex, where the impact is assessed as moderate adverse, the
Pier Head complex and the Waterloo warehouse, where impact will be slight adverse.
Summary of Impacts on Townscape Characteristics and Setting of Character Areas
1.6.9 Assessment of the revised proposals shows that the impacts on the Townscape Characteristics and
Setting of Character Areas will be as follows:
Verylargebe
neficial
Largebeneficial
Moderatebeneficial
Slightbeneficial
Neutral
Slightadvers
e
Moderateadverse
Largeadvers
e
Verylargead
verse
1 1 3 1
1.6.10 The assessment finds that the development will have a beneficial impact on character areas
overall. The most significant positive effects will be to the Stanley Dock Conservation Area, which
will benefit in terms of urban grain, physical fabric, access and permeability, as well as the key
issues that are identified in the SPD. These positive results will be balanced to some degree by
adverse impacts on setting and key views.
Summary of Compliance with Guidance in the Liverpool WHS SPD
1.6.11 Assessment of the revised proposals shows that compliance with the guidance set out in the
Liverpool World Heritage Site SPD is as follows:
Fullcompliance
Mediumcompliance
Low
compliance
Neutral
Low
significance
non-compliance
Mediumsignificance
non-compliance
High
significance
non-compliance
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12 10 2 5 2
1.6.12 The development complies with the SPD in almost all respects. The exceptions are the policies
relating to Impacts on Views, and the policies relating to Building Heights in the WHS.
1.6.13 The views analysis finds a potential for adverse impacts in three instances:
The effect of tall buildings in the commercial district cluster on the silhouette of the Three
Graces when seen from the Albert Dock and Hartley Bridge
The effect of the riverfront blocks on visibility of the Stanley Dock Tobacco warehouse
and the Waterloo warehouse when viewed from Wirral
The change in long views of the site from the Victoria Clock Tower and Regent Road as a
result of development on the site of the Clarence Dock
1.6.14 These have already been commented upon (para 1.6.2). The single factor relating to Building
Heights in the WHS is the effect on visibility of the Stanley Dock and Waterloo warehouse when
viewed from Wirral (also commented upon at para 1.6.2 above).
Summary of Cumulative Impact Assessment on Outstanding Universal Value
1.6.15 Assessment of the revised proposals shows that the cumulative impact on OUV will be as follows:
Verylarge
beneficial
Largeben
eficial
Moderate
beneficial
Slightben
eficial
Neutral
Slightadv
erse
Moderate
adverse
Largeadverse
Verylarge
adverse
7 3 10 1 1
1.6.16 The assessment of cumulative impacts takes into account intangible as well as tangible attributes
of OUV, and also assesses the way in which the development might actively develop the criteria for
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which the WHS was inscribed. It focuses on how aspects of OUV are transmitted and understood.
In this respect the gift of public access to the site which the development will bring offers the
opportunity for the public to experience the heritage assets and attributes for the first time in their
history. As stated in the introduction to this report, transmission of OUV relies not only on visual
receptors, but also on an appreciation of the sense of place. The assessment of cumulative
impacts, which is informed by intangible factors, demonstrates a strongly beneficial outcome.
1.7 Mitigation Measures
1.7.1 The ICOMOS guidance on HIA for Cultural World Heritage Properties states that every reasonable
effort should be made to eliminate or minimise adverse impacts on significant places. Ultimately,
however, it is suggested that it may be necessary to balance the public benefits of the proposed
changes against the harm to the place, and that in the case of WH properties this balance is
crucial.
1.7.2 Impact assessment is an iterative process, and since the planning application was submitted it
has been possible to make a number of changes to the proposals that would avoid potentially
harmful consequences. Nonetheless, a small number of adverse effects have still been identified
in the final assessment, for which mitigating measures are suggested. Where such measures are
proposed, it is intended that they will be secured through appropriate planning conditions.
1.7.3 The potential adverse effects can be summarised as follows, together with mitigating factors:
The effect of tall buildings in the commercial district cluster on the silhouette
of the Three Graces when seen from the Albert Dock and Hartley Quay. In
these views, the tall buildings appear behind the towers of the Liver Building and the
dome of the Port of Liverpool Building. Seen in 3D, however, the effect will be mitigated,
whilst a kinetic treatment of views, which are not restricted to fixed points, will avoid
harmful impact. In other views that include the Pier Head complex, for example from the
Strand and from Woodside on the opposite side of the river, the additional tall buildings
enhance OUV by strengthening the identity of the commercial centre.
The effect of the riverfront blocks on visibility of the Stanley Dock Tobacco
warehouse and the Waterloo warehouse when viewed from Wallasey Town
Hall. This effect is an inevitable consequence of the location of these warehouses which
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are, unusually, several blocks back from the riverfront. If their all round visibility were to
be maintained, it would sterilise much of the site, and unacceptably reduce the sense of
enclosure to the central docks. Mitigation comes in the form of kinetic views from the
Wirral promenade, where the Stanley Dock will be gradually revealed, and will be an
effective as a conveyor of OUV.
Changes to the setting of heritage assets and visual connectivity across the
site. The change in views across the site will be considerable, particularly in the central
area of the site, where development is most concentrated. It must be understood,
however, that the current openness of the site is wholly artificial, and alien to its
authenticity as a working dockyard. Prior to the clearance of transit sheds, no connecting
views between the docks and the city centre would have existed. The views modelled,
where changes are most acute, are not public views, and public access to the site and
the waterfront views is a crucial mitigating factor.
1.7.4 It is relevant to observe that all three of these changes are inevitable consequences of realising
the development opportunities identified by the Council for the Liverpool Waters site in the
policies and guidance set out in the Liverpool WHS Supplementary Planning Document. All three
also fall to be considered in the context of the overwhelming balance of positive effects of the
Liverpool waters proposals identified in this assessment.
1.7.5 Further measures that will reduce and compensate for the potential adverse impacts of proposed
development on aspects of OUV as identified are numerous and these are listed below.
Archaeology
Whilst the assessment does not identify any potential harm to below ground archaeology,
it is clear that without adequate safeguards, there could be significant risk of damage. As
a result, mitigation measures have been clearly set out. The result of detailedarchaeological evaluation at the reserved matters stages will greatly increase knowledge
of the site and its public dissemination.
Conservation of Heritage Assets
The future monitoring, maintenance and repair of all heritage assets in the ownership of
the applicant will be a major benefit of the project, and will mitigate any adverse effects
on the setting of individual heritage assets.
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Interpretation
The OUV will be actively transmitted through a WHS Interpretation Strategy on which the
applicant is committed to work with the Council and other agencies at the reserved
matters (detailed design) stages. In terms of presenting the outstanding Universal Value
of the World Heritage Site, public access to the Liverpool Waters site will bring huge
benefits in terms of understanding the role of the docks in the history of the city and its
global reach.
Riverside Promenade and Cycle/Pedestrian Routes connecting the City Centre
with the Leeds and Liverpool Canal and the Northshore area
The proposed promenade and cycle routes will open up more of the waterfront and
create improved connections between the different character areas of the WHS.
Active Dockland Uses
The dock water spaces will be reinstated and returned to active use, together with their
lock gates where reasonably feasible, quayside artefacts and historic surfaces; historic
buildings will be restored; and the dock boundary wall will be kept as a symbol of dock
management and operation.
Urban Plan
The proposed grain of the site reinforces the historic urban form to create a new grid of
streets, squares, parks and promenades that will help to transmit understanding of the
dock layout that is a key attribute of OUV. The historic gateways through the dock wall
will be restored and used to enhance the legibility of the dockland estate.
Legibility
Liverpool is a highly legible city, and legibility is acknowledged to be a critical conveyor of
OUV. At present, however, the site is not capable of being easily understood because of
the lack of public access, and nor can the layout and management of the docks be
appreciated from distant viewpoints such as the Wirral. Following development, the
current flatness of the site will be changed, and legibility will rely on new codes to
transmit meaning about the landform, such as the horizontal strip of waterfront
development, drawing on urban references from the Albert Dock. The visibility of the
river wall and the entrances will continue to convey messages about the dockland
beyond, and likewise the dock boundary wall will not be obscured. Loss of visibility of the
warehouses from across the river is an adverse, yet inevitable, consequence of
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waterfront development, but mitigation is offered in the form of kinetic views. The
relationship between the commercial centre and the docks will remain understandable,
and once the concept of the secondary cluster populating the site of the former power
station is grasped as part of the evolving commercial city, the contribution to legibility will
be enhanced and not diminished. Legibility within and throughout the extent of the site
will be enhanced by the creation of an urban grid that follows the form of the existing
and infilled docks, which will lead to a better understanding of the original layout, and act
as an aid to orientation in what is currently a confusing environment.
High Density Development and Tall Buildings
Tall buildings are included in the scheme to create a new international business
destination that will attract investment from around the world. Research confirms that
positive economic impacts can accrue from the development of tall buildings.
Furthermore, central waterfront locations are a finite and scarce resource, and are highly
valued as commercial locations in cities across the world. Therefore, given the difficulties
faced by Liverpool in attracting commercial investment and jobs since the demise of the
old docks, it is crucial to make the most efficient use of the land through high density
development and tall buildings. By using this finite resource carefully, tall buildings also
provide more space for creation of high quality public realm.
1.7.6 The scheme also offers mitigation in terms of intangible attributes identified as essential to
understanding Liverpools genius loci, and which are relevant to the scale and ambition of the
proposal:
Vision and Determination: Liverpools economic success was built on a spirit of
optimism and innovation, and being bold has been a tradition for the city, willing to test
new ideas and pioneer new technology. Liverpool was a pioneer of tall buildings in the
19th and 20th centuries, influencing the use of cast iron for prefabricated construction in
Chicago and New York, and adapting North American building technology in the
construction of buildings such as the White Star Line offices, the Dock Offices, Tower
Buildings and the Royal Liver Building. The further development of tall building
technology is therefore part of Liverpools contribution to planning and an aspect of OUV.
That underlying spirit remains, despite the massive difficulties of economic restructuring
that have had to be faced in recent years, and is central to the Liverpool Waters project.
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Commercial Astuteness:The development of the city was driven by astute commercial
decisions. The process of making use of redundant docks for commercial expansion is
similarly well-established. It was carried out first in 1828 with infilling the Old Dock for a
new Custom House, then the citys tallest building. The redevelopment of the Georges
Dock from 1899 for the prestigious Pier Head offices involved the erection of the UKs
first skyscraper, the tallest commercial building in the country. More recently the partial
infilling of Princes Dock as an extension of the commercial district is part of Liverpools
history of economic growth. The Clarence Dock was used from 1929 as the site for the
citys major coal-fired power station, with three tall chimneys. Re-using the docks as
statements of regeneration is therefore a tradition. Peel similarly has a significant track
record in entrepreneurial success.
Internationalism:The city has looked outwards to Ireland, to America and to the Far
East and continues to do so. It has welcomed migration and is one of the countrys most
cosmopolitan cities with a legacy of buildings that express cultural diversity. Peels current
programme for securing inward investment from China, the Far East and other rising
economies continues that spirit of internationalism.
1.7.7 In addition to the heritage benefits set out above, there are other benefits that should be
considered in accordance with the ICOMOS methodology. These include the delivery of strategic
planning objectives; physical regeneration; socio-economic development; environmental
enhancement; and new leisure and tourism resources.
1.8 Conclusions
1.8.1 Whilst it is difficult to weigh the positive and negative impacts identified in the HIA precisely, it is
clear that the opportunities presented by the scheme for protecting, conserving and promoting
the OUV of the WHS, its integrity and authenticity are very considerable. Amongst the
opportunities and threats identified in the WHS Management Plan were inappropriate new
development and preservation in aspic. These polarities often typify the popular debate about
regeneration of historic areas, and Liverpool Waters is no exception.
1.8.2 On this immense site, however, preservation in aspic is not an option, for without substantial
public funding, the cost of retaining, conserving and maintaining the heritage assets, including
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the water bodies, the sea wall and the dock boundary wall, can only be secured as an integral
element of large scale development. The site is not only of outstanding value in heritage terms,
but as a city centre waterfront location it is a finite resource in global terms. It is therefore vital
that the opportunity is grasped for the benefit of the whole community.
1.8.3 Over the 12 months since the author of this report first assessed the impact on OUV, the scheme
has been substantially amended to address concerns expressed by key heritage consultees, with
the result that a number of harmful impacts have been eliminated or mitigated. Whilst some
adverse effects remain, these are almost wholly concerned with the setting of heritage assets and
attributes of OUV, rather than physical (and therefore irreversible) damage. Seen in the long
term, this is important, since the core values of WHSs are intended to be timeless. The density of
development has been considerably reduced, heights of blocks have been lowered, and the layout
has been amended to improve legibility and mitigate any dominance of new buildings.
Underground structures have been removed or restructured to avoid any conflict with below-
ground remains. There is now a danger that further reductions in the extent of development
could make the scheme unviable and threaten the wider benefits.
1.8.4 Whilst some limited harmful impacts remain, this assessment has demonstrated that these are
greatly outweighed by the benefits offered, and that overall there is no risk to the inscription of
the site as a World Heritage property.