Heritage Impact Assessment-Non Technical

8/2/2019 Heritage Impact Assessment-Non Technical

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Liverpool Waters

Heritage ImpactAssessment

Non-Technical SummaryNovember 2011

www.liverpoolwaters.com


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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.

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