Improving heritage impact assessment: an analytical critique of the ICOMOS guidelines

ABSTRACT

In 2011, ICOMOS published its Guidance on Heritage Impact Assessment for Cultural World Heritage Properties. By 2016, over 100 Heritage Impact Assessments (HIAs) had been requested by UNESCO. This paper provides an analytical critique of the HIA Guidelines focusing on their implicit assumptions. We argue that the assumptions in the HIA Guidelines derive from the ‘preservation’ discourse in heritage management, rather than from the ‘conservation’ or ‘heritage planning’ discourses. This is important because the discourse affects the way impacts and their severity are assessed within HIAs, thereby potentially affecting the conclusions reached. We also argue that this framing results in miscommunication and misunderstanding amongst the different stakeholders, about: (1) their perceptions of the nature of heritage value; (2) the perceived purpose of HIA; (3) the way impacts are assessed; and (4) the differing agendas of stakeholders. We recommend that HIA practitioners acknowledge the existence of the various discourses. This could make HIA a more effective heritage management tool. We also consider that for HIAs to be more robust that they be conducted by a multidisciplinary group and with a peer-review mechanism.

KEYWORDS:

• Heritage Impact Assessment (HIA)
• cultural heritage
• heritage discourses
• Outstanding Universal Value (OUV)
• world heritage

Introduction

In January 2011, ICOMOS published the Guidance on Heritage Impact Assessment for Cultural World Heritage Properties (henceforth the ‘HIA Guidelines’). The HIA Guidelines were developed to ensure the protection of the Outstanding Universal Value (OUV) of World Heritage sites, especially in the face of the negative impacts of planned developments (ICOMOS 2011). Planned developments (for example, the construction of high-rise buildings, major infrastructure projects) are considered to be the largest threat to World Heritage sites (ICOMOS 2005a; UNESCO 2013). The scope of the HIA Guidelines is all cultural heritage properties on the World Heritage List (ICOMOS 2011). In this paper, we focus primarily on built heritage and historic urban landscapes, because most of the HIAs that have been conducted to date focused on these types of heritage.

The impacts of planned developments on heritage have typically been assessed within the framework of Environmental Impact Assessment (EIA) (CEU 1997; Bond et al. 2004) and/or Social Impact Assessment (Vanclay et al. 2015). In EU legislation, Directive 85/337/EEC specifically mentions the impact on cultural heritage as one of the factors that should be assessed within an EIA (CEU 1997). However, the adequacy of the coverage of heritage within EIA has been strongly criticized by both practitioners and academics (for example, Bond et al. 2004; Jones and Slinn 2008; Jerpåsen and Larsen 2011). Their criticisms have predominantly focused on four points: (1) heritage was often not included in the impact analyses being undertaken, even where it was highly evident that it should have been (King 2000; Fleming 2008; Jones and Slinn 2008; Antonson, Gustafsson, and Angelstam 2010); (2) the impact assessment tended to occur too late in the planning process for any meaningful action to be taken to address the impacts (Bond et al. 2004); (3) impact assessment practitioners were not sufficiently familiar with heritage management insights (Langstaff and Bond 2002; Teller and Bond 2002; Jerpåsen and Larsen 2011); and (4) the methods used to determine the impacts of developments on cultural heritage were inadequate (Teller and Bond 2002; Bond et al. 2004; Masser 2006; Antonson, Gustafsson, and Angelstam 2010; Lindblom 2012).

The tensions between heritage protection and planned development within World Heritage sites became particularly prominent with the delisting of the Dresden Elbe Valley from the World Heritage List in 2009 as a direct result of the impact of the then newly-constructed Waldschlösschen Bridge (Ringbeck and Rössler 2011). Dresden’s delisting indicates that planned developments can negatively impact the value of a World Heritage site to such an extent that UNESCO withdraws the World Heritage status (Albrecht and Gaillard 2015). To assist other World Heritage sites in not being delisted because of the impacts of planned developments, ICOMOS developed a guidance document to enable an effective assessment of potential threats to heritage values (ICOMOS 2011). To date, UNESCO has requested over 100 HIAs (for example, Kloos et al. 2013; LandID 2013, 2014) thereby firmly establishing the HIA framework into the management of World Heritage sites. However, the HIA Guidelines have not yet been debated or critically reflected upon within the leading heritage journals.

This paper provides an analytical critique of the HIA Guidelines by focusing on its implicit assumptions. We discuss how these assumptions derive from a specific heritage discourse (the ‘preservation’ discourse) and we discuss the possible influences of this on the HIA process. These assumptions can lead to miscommunication and misunderstanding amongst actors, which can negatively influence the HIA process. To augment and illustrate our arguments, we draw on semi-structured interviews with HIA practitioners and heritage management experts, and we discuss the example of the Liverpool Waters development project and its assessed impact on the Maritime Mercantile City of Liverpool. We consider four interrelated issues that can result in misunderstanding amongst heritage management stakeholders: (1) the nature of heritage values; (2) the perceived purpose of HIA; (3) the practice of HIA; and (4) the differing agendas of various stakeholders.

Competing heritage discourses

Many authors have reflected on different conceptualizations of heritage and heritage management, differentiating between what they call paradigms (e.g. Ashworth 1994a; Pendlebury 2013; Lixinski 2015; Wells 2015) or discourses (e.g. Hall 2005; Smith 2006; Wu and Hou 2015). Paradigms can be defined as ‘the universally recognized scientific achievements that, for a time, provide model problems and solutions to a community of practitioners’ (Kuhn 1970, x). In other words, a paradigm determines ontological, epistemological and methodological perspectives (Denzin and Lincoln 2008); consequently it is a way of thinking and doing within a particular field of research or practice. Discourse can be defined as ‘a system of statements made about aspects of our world which carry a set of assumptions, prejudices, and insights – all of which are historically based and limit the consideration of other alternatively valid statements’ (Allen 2016, 23–24). It is generally seen as consisting of two layers (Gee 2005; Wu and Hou 2015): (1) the way ‘language is used “on site” to enact activities and identities’; and (2) the way language is used ‘to recognize yourself and others as meaning and meaningful in certain ways’ (Gee 2005, 7). This second layer to discourse seems to partly overlap with the conceptualization of paradigms. Indeed, as Allen (2016, 23) describes, paradigms are ‘built up, reinforced, and changed by the discourses flowing in a given society’, indicating the interrelation between the two concepts.

In the field of Heritage Studies, a number of binary classifications of heritage discourses/paradigms have emerged (for example, Smith 2006; Pendlebury 2013; Lixinski 2015). These binary classifications differentiate the discourses according to various characteristics, including old-new, expert-participatory, and protectionist-utilitarian. Smith (2006) described different philosophical positions and practices about heritage by identifying an ‘Authorized Heritage Discourse’ (AHD), as opposed to a ‘heritage-as-process’ discursive practice. Heritage-as-process regards heritage as a dynamic cultural and social process, and is prevalent in the current academic field of Critical Heritage Studies (Harrison 2013; Waterton and Watson 2015). Pendlebury (2013) followed up on the idea of the AHD, by exploring ‘the way that, in England, relationships have developed between the policy spheres of conservation planning, regeneration and economic development. In doing so, it is argued that conservation has largely successfully repositioned itself from being regarded as a barrier to development to being regarded as an active agent of change.’ In this way, heritage resembles a constantly evolving assemblage of ‘institutional organisations, norms and objects […] and normalised practices’ (Pendlebury 2013, 710). Lixinski (2015) proposed a comparable binary classification, contrasting between what he labelled the ‘orthodox’ and the ‘heterodox’ heritage paradigms. He emphasized that a general paradigm shift in science and society from positivism to one comprising constructivism, critical theory and postcolonialism has induced a corresponding shift in heritage management.

Ashworth (1994a, 1994b, 2011) proposed a ternary classification consisting of heritage paradigms that have emerged over time – ‘preservation’, ‘conservation’ and ‘heritage planning’. He argued that a key difference between these co-existing paradigms is their varying understandings of the nature of heritage values. These varying understandings mean that the paradigms result in different approaches to the objects of attention, the criteria used to assess heritage, which actors have authority in decision-making, and towards the objectives held by those actors (Ashworth 1994a). Ashworth’s main point was that the paradigm shifts in the practice of heritage management had been incomplete (see Figure 1). Thus, in Ashworth’s view, the three paradigms continue to exist, which means that stakeholders within one paradigm must interact with stakeholders in the other paradigms. This co-existence was caused by the inherent interdisciplinary nature of heritage management, with some disciplines shifting to new paradigms while others did not. One consequence of the different views on heritage management has been the ‘emergence of a number of misunderstandings and even contradictions, with important impacts upon the uses of the past in the present’ (Ashworth 2011, 1). This may also be the case in relation to the application of the HIA Guidelines.

Figure 1. The co-existing heritage management discourses. (Adapted from Ashworth 1994a, 2011).

In this paper, we follow Ashworth’s ternary conceptualization of heritage management, because we argue that his inclusion of the category of ‘conservation’ adds to understanding the position of the HIA Guidelines in the field of Heritage Studies as well as to understanding its practical implications for heritage management. However, we argue that, although Ashworth uses ‘paradigm’ in his ternary conceptualization of heritage management, ‘discourse’ might be more appropriate, because Ashworth’s conceptualization strongly focuses on co-existence, which seems conceptually closer to ‘discourse’ rather than ‘paradigm’. We follow Smith (2006, 4) in her statement that a ‘discourse not only organizes the way concepts like heritage are understood, but the way we act, the social and technical practices we act out, and the way knowledge is constructed and reproduced’. We argue that this conceptualization of discourse fits Ashworth’s ternary conceptualization of heritage management. Therefore, together with analytical utility, we will refer to Ashworth’s classification as the three heritage discourses in the remainder of this paper.

The preservation discourse

In the preservation discourse, heritage is regarded as individual monuments that have intrinsic, universal and immutable values that need to be protected from spatial development (Ashworth 2011). This conceptualization resonates with Smith’s (2006, 11) Authorized Heritage Discourse, which ‘privileges monumentality and grand-scale, artefact/site significance tied to time depth, scientific/aesthetic expert judgment, social consensus and nation building’. It is also close to Lixinski’s (2015) orthodox heritage paradigm. The consequence of the preservation discourse on heritage management is to focus on maintaining the material integrity of a heritage site. This not only makes heritage management predominantly expert driven, it also makes saving a heritage object more important than finding a societal re-use for it.

The conservation discourse

Although the terms ‘preservation’ and ‘conservation’ are often used as synonyms, in Ashworth’s view they are not the same (Ashworth 2013). The conservation discourse differs from the preservation discourse in two main ways: (1) the focus is widened from single monuments to ‘heritage ensembles’ (Ashworth 2011); and (2) the goal of heritage management is to ‘preserve purposefully’ rather than just preserve (Burke 1976; Larkham 1996; Ashworth 2011; Ashworth 2013). Preserving purposefully is described as ‘not merely continued existence but continued useful existence, which often implies retaining or restoring the traditional appearance of buildings […], but adapting the interior to modern uses’ (Burke 1976, 117). The inclusion of function to form in heritage management through preserving purposefully resulted in ‘adaptive reuse’ becoming the dominant view of heritage planners in Europe and North America (Ashworth 2011). The inclusion of contemporary urban objectives, such as, urban regeneration, alongside protection in heritage management has brought urban planners into the decision-making processes of heritage sites alongside heritage experts from the preservation discourse.

The heritage planning discourse

A key aspect in the heritage planning discourse is the conceptualization of heritage as ‘the contemporary usage of a past [which] is consciously shaped from history, its survivals and memories, in response to current needs for it’ (Ashworth and Tunbridge 1999, 105). In other words, meaning is ascribed to a heritage site or object in the present (Tunbridge and Ashworth 1996; Timothy and Boyd 2003). This indicates that heritage is not about historical accuracy or intrinsic authenticity (Graham, Ashworth, and Tunbridge 2000), but about the contemporary extrinsic narrative attached to it (Smith 2006). This not only makes the meaning of heritage subjective, dynamic, and polysemic (Timothy and Boyd 2003; Ashworth 2011), it also means that ‘all heritage is intangible’ (Smith 2006, 3). Heritage sites are selected for protection according to (potential) consumer demand and are managed to satisfy those consumers (Ashworth 2011). This further reveals how heritage management is inherently political (Lixinski 2015; L. Smith 2015). The contextual understanding of heritage within the heritage planning discourse often clashes with the positivistic character of heritage legislation on which heritage management depends (Lixinski 2015). Therefore, there is a need for national and international agencies to reconceptualise heritage, for the role of heritage professional to change from expert to facilitator, and to enable local communities to be more involved in heritage management and decision making (Ashworth 1994b; Ashworth 2011; L. Smith 2006, 2015).

Positioning ICOMOS into the discourses

The position of ICOMOS can be inferred by analysis of its international charters and website. ICOMOS states that its ‘work is based on the principles enshrined in the 1964 International Charter for Conservation and Restoration of Monuments and Sites (the Venice Charter)’ (ICOMOS 2017). Although augmented periodically, this canonical text for heritage management (Starn 2002; Petzet 2014) still defines the nature of heritage and provides guidelines on how to manage it (Smith 2006). One example of how the preservation discourse is revealed in this document is the statement that monuments are ‘imbued with a message from the past’ (ICOMOS 1964, 1), which reflects an assumption of intrinsic value (Smith 2006). The Venice Charter also states that the societal use of historic monuments is ‘desirable, but it must not change the lay-out or decoration of the building. It is within these limits only that modifications demanded by a change of function should be envisaged and may be permitted’ (ICOMOS 1964, 2). These statements reflect the preservation discourse by positioning the protection of a monument above any potential re-use. The assumptions within the Venice Charter are also generally implicit in subsequent charters of ICOMOS and UNESCO, including the World Heritage Convention and the Burra Charter (Smith 2006).

Statements by leading figures in ICOMOS also reflect the preservation discourse. For example, Michael Petzet, former president of ICOMOS, stated that ‘conservation does not mean “managing change”, but preserving’ (Petzet 2009, 101). Petzet (2014, 269) also stated that the Venice Charter ‘still remains an outstanding testimony reminding us time and again of our moral duty to hand on historic monuments in the full richness of their authenticity’ (emphasis in the original).

Recent documents by ICOMOS and UNESCO show signs of a shift towards the conservation and heritage planning discourses. For example, the Historic Urban Landscape (HUL) approach (see UNESCO 2005, 2011) redefines urban heritage areas by including ‘the broader urban context and its geographical setting’ (UNESCO 2011, 3). This geographical setting is defined in the Xi’an Declaration as ‘the immediate and extended environment that is part of, or contributes to, its significance and distinctive character’ (ICOMOS 2005b, 2). The Xi’an Declaration also stated that ‘co-operation and engagement with associated and local communities is essential’ (ICOMOS 2005b, 4). The ICOMOS Statutes (2014) also focus on ‘management’ and ‘enhancement’ in Article 3, which are key phrases of the conservation and heritage planning discourses. However, despite these signs of a shift, the dominant impression given by ICOMOS is still one of being firmly in the preservation discourse.

Methodology for an analytical critique

This paper is an analytical critique of the HIA Guidelines that draws from specific aspects of discourse analysis. We follow McStotts (2007) in our approach to conducting an analytical critique. She envisioned an analytical critique to be ‘mainly critical’ through systematic analysis, raising questions and sharing experiences. We argue that McStotts’s vision connects with the core of discourse analysis described by Van Dijk (2007, xxiii) as ‘the systematic and explicit analysis of the various structures and strategies of different levels of text and talk’.

Despite being mostly positioned in the heritage planning discourse and seeing the ascribed narrative as the value of a heritage site, we did not want to denigrate other ways of thinking about heritage management. We believed that in our analytical critique, we should identify the implicit assumptions and discourses without making normative judgments about them. We argue that the first step to analysing the HIA Guidelines and their applicability in practice is to identify whether the existence of multiple discourses negatively affects the robustness and legitimacy of HIA practice. As such, the aim of this paper is to show whether the heritage management discourses as defined by Ashworth (1994a, 1994b, 2011) are implicit in the HIA Guidelines and, if so, illustrate how these discourses can cause confusion amongst HIA practitioners.

For the analytical critique, the HIA Guidelines document was carefully reviewed to identify the implicit assumptions about the conceptualization of heritage and its management. The document was coded using a priori and emergent coding methods. We specifically used the characteristics of Ashworth’s ternary conceptualization of heritage management as a priori codes to identify possible implicit assumptions of the HIA Guidelines (see Table 1). For example, we focused on reference to the temporal nature of heritage values as ‘static’, ‘metastable’ or ‘dynamic’ to identify whether this characteristic was implicit in the HIA Guidelines. As such, we focused on identifying the second layer to discourse as described by Gee (2005) by reviewing what the HIA Guidelines implicitly and explicitly stated about the characteristics as indicated in Table 1.

Table 1. Characteristics of the heritage management discourses. (Based on Ashworth 1994a; Ashworth 2011).

	Discourses
	Preservation	Conservation	Heritage Planning
Focus	Object	Ensemble	Narrative(s)
Goal	Protection	Adaptive reuse	Use
Justification	Value	Value/Re-use	Utility
Criteria/values	Intrinsic	Preserve purposefully	Extrinsic
Authenticity of …	Object	Compromise	Experience
Change	Immutable	Adaptable	Flexible
Temporal nature of value	Static	Metastable	Dynamic
Actors (who has authority)	Experts	Policy makers/Planners	Users

To augment and illustrate our arguments, nine in-depth interviews were conducted with key European HIA practitioners and heritage management experts to validate the ideas arising from our analytical critique. The criteria for selecting participants to interview included that they had been involved in conducting HIAs for World Heritage sites and/or had published about HIA in academic journals. The interview guide that was used during the interview contained a list of themes based on the review of the HIA Guidelines.

The case of the Maritime Mercantile City of Liverpool, a World Heritage site placed on the List of World Heritage Sites in Danger at the moment of writing, was used to further explore the ideas in this paper. We selected this case because three HIAs had been conducted to assess the potential impact of the Liverpool Waters project on the Outstanding Universal Value of the World Heritage site. These HIAs had different conclusions, with two concluding the project would have a positive impact on the heritage site, and one concluding it would have a negative impact. These different conclusions have been attributed to different understandings of the meaning of Outstanding Universal Value within these HIAs (Rodwell 2015), and we argue that these different understandings arise from the different heritage management discourses.

Implicit assumptions in the HIA guidelines and their consequences for HIA practice

As elaborated below, reviewing the HIA Guidelines using the characteristics of the three heritage discourses (as outlined in Table 1) revealed a number of implicit assumptions. The interviews with HIA practitioners and experts augmented our consideration of the HIA Guidelines. One recurring issue in these interviews related to the varying influence of the stakeholders involved in the HIA process, and their different agendas. Below, we use the Liverpool Waters case to provide an illustration of the consequences of these implicit assumptions in terms of: (1) different views on the nature of heritage values; (2) the perceived purpose of HIA; (3) the actual practice of the assessment process; and (4) the role of the stakeholders involved in the process and their differing agendas.

The nature of heritage values

We argue that the HIA Guidelines are rooted in the preservation discourse. Paragraph 4–6 of the HIA Guidelines states that the Outstanding Universal Value (OUV) of a site is used as baseline data, meaning that the potential impacts of proposed spatial developments must be measured against the values that were recorded by UNESCO at the time the site was inscribed on the World Heritage list. The HIA Guidelines also state that ‘OUV needs to be sustained over time through the protection of attributes that are seen to convey OUV’ (ICOMOS 2011, i). The HIA Guidelines themselves lack a definition of OUV, but refer to the World Heritage Convention and the way this document conceptualizes OUV. The World Heritage Convention describes OUV as ‘cultural and/or natural significance which is so exceptional as to transcend national boundaries and to be of common importance for present and future generations of all humanity’ (UNESCO 2015, 11). Previous research has positioned the World Heritage Convention in the AHD based on its conceptualization of the nature of heritage (Smith 2006; Harrison 2013), which means that it would be positioned in Ashworth’s preservation and/or conservation discourse.

The concept of OUV has been criticized extensively (see for example, Pocock 1997; Meskell 2002; Musitelli 2002; Strasser 2002; Frey and Steiner 2011; A. Smith 2015; L. Smith 2015). The nature of heritage often connects it to the past of one (cultural) group, questioning its universal character (van der Aa 2005; L. Smith 2015). In fact, heritage sites are primarily nominated for solely national reasons, such as economic development, expected prestige, and publicity, largely ignoring whether their value transcends national boundaries and is important to all humanity (Strasser 2002; Frey and Steiner 2011). This corresponds with the argument by Pocock (1997) that the World Heritage List is not a list of global heritage but of national heritage, because of the way the nomination process is structured. Heritage sites are nominated by individual states and then endorsed by the World Heritage Committee. Having a high number of World Heritage sites may not necessarily reflect having much heritage that transcends national boundaries, but rather the willingness and ability of a state to get its heritage sites through the selection procedures (Pocock 1997).

The HIA Guidelines also state in paragraph 4–8 that ‘OUV is defined at the time a World Heritage property is inscribed on the World Heritage list and cannot be changed without a re-nomination which goes through a full evaluation process’ (ICOMOS 2011, 7). Based on the characteristics of the different heritage discourses (see Table 1), this static form of OUV goes directly against the dynamic, polysemic and potentially dissonant characteristics of heritage from the heritage planning discourse. A static OUV also does not acknowledge the debate within ICOMOS about the conceptualization of heritage, which is illustrated by a discussion between Gustavo Araoz, President of ICOMOS since 2008, and Michael Petzet, President of ICOMOS from 1999 to 2008. Araoz acknowledged that heritage values change over time and space, which makes the conceptualization and use of OUV questionable (Araoz 2009). However, strong opposition to his view was voiced by other members of ICOMOS at the May 2010 meeting of the Scientific Committee for the Theory and Philosophy of Conservation and Restoration (Bandarin and van Oers 2012), and the statement by Araoz was removed from the ICOMOS website (Williams 2010).

Authenticity and integrity of the site are seen by ICOMOS as being essential components of the OUV of a World Heritage site (Jokilehto 2006; Albert and Hazen 2010; UNESCO 2015). The importance of authenticity and integrity is operationalized within paragraph 5–12, which states that changes caused by planned developments:

must also be assessed for their impact on integrity and authenticity. […] Authenticity relates to the way attributes convey OUV and integrity relates to whether all the attributes that convey OUV are extant within the property and not eroded or under threat. (ICOMOS 2011, 10)

The importance of authenticity and integrity is based on the intrinsic nature of heritage values as perceived within the preservation and conservation discourses. Within these two discourses, the intrinsic authenticity and integrity of the heritage object is used as the self-explanatory justification for listing a site as heritage (Tunbridge and Ashworth 1996).

In the heritage planning discourse, however, authenticity does not stem from the object, but from the experience of the consumer (see Table 1). It is therefore contingent on the meaning-giving actor (Lowenthal 1998; Stovel 2007; Pendlebury, Short, and While 2009; Waterton and Smith 2009). The interpretation of the past, and of heritage, occurs through interpretation (Hall 1997) in the present (Shanks and Tilley 1987). This conceptualization of meaning can be found in the role of shared systems of meaning and interpretation in the conceptualizations of place (Vanclay 2008); material culture (Hodder 2000); and heritage (Ashworth and Tunbridge 1999).

The misunderstanding created by different views on the nature of heritage values can be illustrated by the ambiguity about the impact of the development project known as Liverpool Waters (see Figures 2 and 3) on the Maritime Mercantile City of Liverpool (henceforth Mercantile City). An HIA commissioned by English Heritage (see Bond 2011), the executive non-departmental public body responsible for heritage management in the UK, concluded that this development project would negatively impact the Mercantile City both morphologically and visually (Rodwell 2015). In 2012, UNESCO placed the Mercantile City on the List of World Heritage in Danger based on this HIA (UNESCO 2012). However, two other HIAs were conducted that both concluded Liverpool Waters would have a positive impact on the Mercantile City, one by the developer Liverpool Waters and owner of the development site, and one by the City Council of Liverpool.

Figure 2. The Liverpool Waters development project: Before (Rust Studio 2016).

Figure 3. The Liverpool Waters development project: After (Rust Studio 2016).

Different views on the nature of heritage values contributed in at least two ways to the ambiguity of the potential impact of Liverpool Waters on the Mercantile City: (1) differences in the categorization of the site; and (2) different views on whether OUV is static or dynamic. The Mercantile City is categorized on the World Heritage list as a ‘group of buildings’ (ICOMOS 2004, 127), but ICOMOS treats it as an ‘urban landscape’ (Gaillard and Rodwell 2015). This difference influenced to what extent the setting of the site was taken into account when assessing the impact of a proposed development project, resulting in the different outcomes of the three HIAs that were conducted.

The problem of a static versus dynamic nature of OUV is illustrated in the Liverpool case through the concept of ‘historic layering’. UNESCO (2011, 1) defines historic layering as ‘values that have been produced by successive and existing cultures and an accumulation of traditions and experiences, recognized as such in their diversity’. Liverpool Waters can then be seen as a new layer that will be added to the Mercantile City (Rodwell 2015). Following this reasoning, historic layering could provide a way to make OUV more dynamic, and consequently, include the conservation and heritage planning discourses into the decision-making of UNESCO.

The ambiguity surrounding the impact of Liverpool Waters on the Mercantile City made Gaillard and Rodwell (2015) conclude that ‘the State Parties, ICOMOS and the World Heritage Committee evidenced different understandings of the outstanding universal value and integrity and authenticity of the [Mercantile City] and these varied over time’. We argue that these different understandings are examples of the possible influence of the heritage discourses.

The perceived purpose of HIA

Several of the interviewed HIA practitioners and experts expressed the concern that the HIA Guidelines were focused too much on the procedure and not enough on the purpose of HIA. At the very beginning, the document states that the purpose of the HIA Guidelines is ‘to offer guidance on the process of commissioning Heritage Impact Assessments (HIAs) for World Heritage (WH) properties in order to evaluate effectively the impact of potential development on the Outstanding Universal Value (OUV) of properties’ (ICOMOS 2011, i). However, why such an assessment is needed or what the outcome of an assessment should be, or any clear statement of purpose for HIA, are not explicitly given in the document. We argue that the implicit purpose of HIA in the HIA Guidelines is the protection of the ‘intrinsic value’ of World Heritage sites from the negative influence of spatial developments. Paragraph 2–1-6 suggests a related purpose of HIA, namely to assess the threat or risk to the World Heritage status (ICOMOS 2011). With this purpose, the focus is not so much the heritage site itself, but the planned development and to making them ‘UNESCO-proof’ (Boer 2015). That is, that the development plans comply with what UNESCO deems to be tolerable. Thus, a strong focus on procedure might be considered to be a strength of the HIA Guidelines, because following the procedure should result in preventing the loss of World Heritage status.

Based on a reflection of the discourses, we consider that another potential purpose for HIA could be improving heritage management. Within the heritage planning discourse, there is an increasing concern that the growing number of protected heritage sites creates a ‘heritage time-bomb’ (Gilmour 2007), especially in the urban context (Pendlebury, Short, and While 2009). The heritage time-bomb refers to the implications of the growing commitments to maintain, repair and restore an ever-increasing list of protected heritage sites (Ashworth 2011). This includes rising costs of protection and restrictions on the development of sites, which can be especially problematic for cities attempting to be compact and sustainable (Baer 1995). From this perspective, HIA could be used as a tool to balance heritage protection with spatial development rather than simply to protect heritage from spatial development.

The actual practice of the assessment process

Paragraph 5–8 of the HIA Guidelines provides a nine-point scale of severity of the impacts that a planned development could have on the OUV of a World Heritage site. This bi-directional (adverse-beneficial) scale ranges from no change, through negligible change, minor change, moderate change, to major change. Several of the interviewed HIA practitioners and experts complained that the HIA Guidelines do not provide a clear way to differentiate between the different points on the scale, despite the inclusion of an example guide for assessing the magnitude of impact (Appendix 3B of the HIA Guidelines, see Table 2). Table 2 shows, for example, that minor impact is described as being ‘noticeable change’; and moderate impact is described as ‘significant change’. This difference leaves much room for negotiation and interpretation. In the words of one interviewee:

I think one of the issues with [the HIA Guidelines] is the nine point scale from major beneficial impact to major adverse impact, and I think having such a long scale [with a large number of categories] results in considerable potential for people to reach relatively subjective opinions on where you score the various impacts.

Table 2. Example guide for assessing the magnitude of impact on built heritage or Historic Urban Landscape attributes (modified from ICOMOS 2011).

No Change	Negligible change	Minor change	Moderate change	Major change
No change to fabric or setting.	Slight changes to historic building elements or setting that hardly affect it.	Changes to key building elements, such that the asset is slightly different. Change to setting of an historic building, such that it is noticeably changed.	Changes to many key historic building elements, such that the resource is significantly modified. Changes to the setting of an historic building, such that it is significantly modified.	Change to key historic building elements that contribute to OUV, such that the resource is totally altered. Comprehensive changes to the setting.

Whether a planned development results in negligible, minor, moderate or major change to a particular attribute of the OUV is left to the interpretation of the assessor. The subjective nature of the assessment procedure makes the outcome contingent on the discourse in which the assessors operate. Whether a proposed development is assessed to result in noticeable or significant change is influenced by the perceived purpose of an HIA and the view on whether a heritage site has intrinsic or only extrinsic values.

The interviewees acknowledged the contingent nature of the HIA procedure and stated that a peer review system would improve the HIA methodology. Many interviewees were unsure whether their own method of assessing impacts was consistent with the HIA Guidelines. Several interviewees indicated that one’s professional background potentially affected the approach used and manner of assessing impacts. A peer review system could potentially improve the quality, or at least consistency of the assessment. Although the HIA Guidelines encourage partnerships and the sharing of experiences, more emphasis should be placed on this.

Different agendas of stakeholders

The contingent nature of the HIA procedure allows for different agendas to play a role in the outcome of an HIA. Although these agendas will be influenced by many factors, they will also be influenced by the heritage discourse of the stakeholder. The three HIAs conducted about the impact of the Liverpool Waters project illustrate the potential influence of different agendas. The HIA commissioned by English Heritage and conducted by Heritage Places (http://www.heritageplaces.co.uk/) concluded that Liverpool Waters would have a ‘significantly damaging negative impact’ (Bond 2011, 5). The HIA conducted for the proponent, Peel Holdings, (consultant not identified in the report) concluded that whilst ‘some limited harmful impacts remain, […] these are greatly outweighed by the benefits offered, and […] overall there is no risk to the inscription of the Liverpool World Heritage property’ (Liverpool Waters 2011, 16). The HIA conducted by Liverpool City Council, which is largely in favour of the project, concluded that the benefits outweigh the adverse impacts, that there is no adverse impact on the World Heritage site, and that the Liverpool Waters projects will ‘ensure the repair, conservation, re-use and interpretation of all of the key heritage assets of the site’ (Liverpool City Council 2012, 216).

The disciplinary background of the practitioners is likely to affect their judgements. This background can influence the perception of the severity of the impact of a proposed development project as well as influence the extent to which this severity is considered acceptable. One interviewee said that, because of the nature of their discipline, architects are more likely than other professions to be accepting of minor impacts on a heritage site, whereas art historians are likely to be more concerned about the integrity and authenticity of the site. Given that the background may influence the assessment, it would be beneficial for HIAs to be conducted by a multidisciplinary group. By providing room in the HIA process for discussion between assessors of different disciplinary backgrounds, this could prevent the discourse of one discipline to determine the outcome of the assessment.

Conclusion

This paper provides an analytical critique on the ICOMOS Guidance on Heritage Impact Assessments for Cultural World Heritage Properties by focusing on its implicit assumptions. We argue that these HIA Guidelines are strongly connected to the preservation discourse with their focus on a static understanding of the Outstanding Universal Value. This has implications for the way HIAs are conducted, because other heritage management discourses (conservation and heritage planning) are also prominent amongst HIA practitioners. This can result is possible miscommunication and misunderstanding about the HIA procedure, the perceived purpose of HIA, and the way impacts are assessed. The implicit purpose of HIA in the HIA Guidelines (as the protection of OUV) limits the potential of HIA because it ignores other potential purposes (such as, improving heritage management in general, or finding a balance between protection and development). Different views on heritage values, the disciplinary background of the HIA practitioners, and the differing agendas of different stakeholders can affect the outcome of an HIA.

The first crucial step in dealing with the influence of the heritage discourses on the outcomes of HIA is acknowledgement of the existence of these discourses. To ensure that the discourses are considered in the HIA process, the HIA Guidelines should require that a multidisciplinary team conducts HIAs and that there be a peer-review mechanism. Although there will still be some confusion and misunderstanding, bringing professionals from different discourses together will likely reveal the discourses and their implicit assumptions, and thereby increase the robustness and legitimacy of the assessment if agreements can be reached beforehand.

Disclosure statement

No potential conflict of interest was reported by the authors.

Additional information

Notes on contributors

Patrick R. Patiwael

Patrick R. Patiwael is a PhD candidate at the University of Groningen. His main areas of research are heritage management and spatial planning with a focus on the Heritage Impact Assessment (HIA) framework. His previous research includes an analysis of active stakeholder perceptions of policy transfer between UNESCO and the national government of Suriname about the management of the colonial heritage in Paramaribo.

Peter Groote

Peter Groote is an associate professor in cultural geography at the University of Groningen. He has published in many fields including which heritage studies.

Frank Vanclay

Frank Vanclay is professor of cultural geography at the University of Groningen. He is a leading scholar in the field of Social Impact Assessment.