icomos iaeg-sdg consultation submission dec 15

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The attached document represents the comment that was submitted by ICOMOS as part of the IAEG-SDG open consultation on the proposed United Nations Sustainable Development Goals Indicators coded ‘grey’. One of these grey Indicators is the Indicator for Target 11.4, which relates the safeguarding of natural and cultural heritage. You can read more about the consultation here: https://www.surveymonkey.com/r/YZKHPKN.IAEG-SDG.


  • Consultation on Grey Indicators Proposed by IAEG-SDGs

    Submission by ICOMOS

    December 15, 2015

    The International Council on Monuments and Sites (ICOMOS) is a Paris-based

    international Non-Governmental Organization. We are pleased to provide this comment on the

    proposed indicator for Target 11.4. These comments expand upon the comment we submitted in

    the spring of 2015 during the earlier UN Non-Governmental Liaison Services online Indicator consultation.

    ICOMOS believes there are four key tests against which any proposed indicator for Target

    11.4 should be measured:

    (1) Is the Indicator based on sound methodology and is the methodology behind the indicator (data sources, method of computation, treatment of missing values,

    regional estimates, etc.) well documented and readily available? Is the indicator

    recommended by a well-established and recognized peer review mechanism or

    through international mechanisms?

    (2) Does the indicator expressly correlate to the broader aims of SDG Goal 11, to make cities and human settlements inclusive, safe, resilient and sustainable?

    (3) Does it recognize the inter-linkages of natural and cultural heritage, implicit in the text of Target 11.4 and explicit in contemporary heritage policy and philosophy?

    (4) Does it operate at a landscape or regional scale, recognizing the pervasive and multifaceted nature of heritage, including tangible and intangible, movable and

    immovable, natural and cultural.

    The current proposal is Share of national (or municipal) budget which is dedicated to preservation, protection and conservation of national cultural natural heritage including World

    Heritage sites. As we wrote in the UN-NGLS consultation in March, we believe a different approach would better address the four key tests we have outlined. Also, ICOMOS notes the

  • current draft seems to have a typographical error. Presumably, it was intended to read protection and conservation of national cultural and natural heritage.

    ICOMOS writes in support of the following Indicator for Target 11.4:

    the percentage of urban areas supported by development and financing governance frameworks that include the safeguarding of natural and cultural heritage.

    Such an Indicator would use existing methodologies to establish a baseline definition for

    inclusion of the safeguarding of natural and cultural heritage into metropolitan or urban regulatory

    and legal development and financing governance frameworks. These reflect an assessment of the

    effectiveness of governance tools, as community engagement, knowledge and planning regulatory

    systems and financial tools on the safeguarding of heritage. Progress towards Target 11.4 would

    then be measured in terms of increases in the number (measured by means of population covered,

    square miles covered or another suitable metric) of urban areas supported by an effective

    development governance framework, that is to say, ones that meant the baseline definition of being

    inclusive of the safeguarding of heritage.

    The ICOMOS proposal focuses on spatial and process variables, versus economic/financial

    ones. ICOMOS believes this is justified in view of the multi-dimensional manner in which heritage

    safeguarding supports Goal 11. This approach also creates more synergy with the other Targets of

    Goal 11 and the New Urban Agenda expected to be adopted as part of the UN Habitat III process.

    Financial expenditure is a reducing tool of heterogeneity/complexity/multidimensionality, because

    it transforms all aspects into one dimension. While ICOMOS prefers an approach that is more

    multi-dimensional, ICOMOS does agree that financial mechanisms are extremely important. The

    ICOMOS proposal recognizes this by including as a baseline requirement the incorporation of

    incentives for heritage safeguarding within broader development governance tools. Thus, key to

    our proposal is the reference to development and financing governance frameworks.

    What follows is an explanation of the ICOMOS proposal with reference to each of the four

    key tests outlined above.

    (1) Methodology

    The ICOMOS proposal is based on research collected by UN Habitat and others and on

    national and sub-national assessment tools already in use and being developed by the World Bank

    and the Asian Development Bank. For example, the approach draws on the concept of country

    environmental analysis (CEA) found in the Asian Development Bank's 2003 Environmental

    Assessment Guidelines. (Available online at http://www.adb.org/sites/default/files/institutional-

    document/32635/files/environmental-assessment-guidelines.pdf). The CEA assesses, at a policy

    level, a country's Regulatory and Institutional Framework that includes a review of its

    environmental standards, regulations, enforcement, mechanism and instruments. It makes this

    assessment against identified environmental issues that are most important to a country's

    development strategy. The ICOMOS proposal utilizes this approach to assess existing governance

    frameworks against the issue of the safeguarding of natural and cultural heritage.

    One finds similarities in the World Bank's draft Environmental and Social Procedure,

    which requires the Bank, as part of its due diligence, to evaluate countries' Environmental and

  • Social Frameworks, that is those aspects of the countrys policy, legal and institutional framework, including its national, subnational, or sectoral implementing institutions and applicable laws,

    regulations, rules and procedures, and implementation capacity, which are relevant to the

    environmental and social risks and impacts of development. (Available online at




    The review requires an assessment of the Country's overall legal framework in service of

    determining the extent to which that framework addresses the risks and impacts of development

    and enables the project to achieve objectives materially consistent with World Bank's

    Environmental and Social Safeguards (ESSs), including the World Bank policy on the

    safeguarding of cultural heritage.

    The starting point for application of the proposed Indicator would be a determination by

    national authorities of the urban development and finance framework (national, regional, sub-

    regional) relevant to its urban areas. Five elements could be used as part of a baseline for

    establishing whether heritage safeguarding had been included in the relevant framework:

    Inclusion of natural and cultural heritage safeguarding elements in development standards, regulations, enforcement, mechanism and instruments.

    Existence of financing tools for heritage safeguarding as part of broader schemes of development finance.

    Existence of heritage capacity and capability within development and development finance agencies.

    Existence of mechanisms for cross-sectoral coordination of heritage policies and actions with other development and finance functions.

    Opportuinty for public consultation in heritage-related decision-making.

    The following references support these elements:





    Good governance should preserve the urban environment and the cultural and historical heritage of cities

    Identify and protect the commons

    Conservation offices

    Conservation policies

    SOCIAL: related to democracy, human rights and civic participation in decision-making processes


    with the growth of Cultural Heritage Tourism, more cities in developing countries were investing in the conservation of old historic buildings and thus tapping into their cultural capital

    Culturally driven models of redevelopment

    ECONOMIC: Cultural heritage sites are playing notable roles in the symbolic economy


    Law on Spatial Planning that followed is based on the overarching principle of protecting the public over individual interest

    Integration of heritage conservation on urban planning

    SOCIAL AND ECONOMIC: a more rational use of land, greater equity in the provision of basic infrastructure and services, the protection of the environment and the preservation of cultural heritage.


    cultural heritage, sense of place and memory and the complex set of social and symbolic relationships that give cities meaning

    Adopt policies to protect intangible assets, and create social spaces that contribute to humanizing cities

    SOCIAL: these intangible assets represent the soul of the city and are as important for harmonious urban development as tangible assets

  • 2010-2011

    A number of cities today are using culture as a transformational tool to integrate ethnic minorities, preserve regional values, safeguard linguistic and religious diversity, resolve conflicts, protect the heritage in the built environment, and in the process promote economic development.:

    An inclusive city promotes of creative artistic expression and heritage activities

    SOCIAL AND ECONOMIC: Beyond the sole cultural sphere, these policies together can go a long way towards bridging the urban divide in its other social, political and economic dimensi