7. Clear policies for putting the Plan into effect are critical. All key stakeholders must be involved in the management process through a Stakeholders Steering Group to articulate a balance between conservation, access, sustainable use, including tourism, and the interests of the local community. The living culture is the most vulnerable OUV and preventive management strategies must be crafted to ensure that all facets of the intangible values of the Site are not eroded, especially through small scale changes. These over time have a strong accumulative effect which is irreversible.

8. A buffer zone has been created to surround the World Heritage Site to give it an added layer of protection, with complementary legal and planning restrictions placed on its use and development. It is of great concern that the purpose of a buffer zone has not been fully understood. Recently, there have been approvals for high-rise projects within the buffer zone. Was it clearly indicated to the councillors that these are in the buffer zone and that they contradict the objectives of the World Heritage Convention?

Specifically, The UNESCO World Heritage Committee have asked to be informed by national governments of proposals for major restorations or interventions (i.e. new buildings) which may affect the OUV’s of the Site or have an adverse impact on views to and from the Site. They even recommend that Heritage Impact Assessments (HIA) be carried out. BWM has been engaged to undertake several of these assessments in the past. Currently this is not a practice in Malaysia.

9. The present WHSMP is a preliminary document which outlines an organisational framework, broad issues, policies, threats and challenges. In order to operationalise it, many other steps are involved:-

a. Prepare a detailed work programme and Plan outlining the steps to be taken by all respective parties identified in the framework, with key milestones established for the deliverables assigned to each party e.g. at Federal, State and Local Government levels.

b. Establish priorities to ensure that the main features of the Plan are in place as soon as possible, even before the detail plan has been fully developed.

c. Develop the detail Plan. At this stage, all stakeholders must be consulted to develop consensus on the policies that are to be established.

d. Review all development plans proposed and approved within the Core Area and Buffer Zone to ascertain if they compromise the OUV’s.

e. Initiate public consultation as the last phase of this stage.

f. Publish the agreed Plan and broker its adoption by all the key stakeholders, with an agreed vision and direction.

g. Implement the Plan and convert it into a management system, to be managed by a World Heritage Site Coordinator.

10. In parallel with the development of the detail plan, the State’s statutory plans have to be amended to take cognisance of a major difference in Penang. The pending Local Plan for Penang Island should be redrafted with the World Heritage Site as a key feature, together with the policies and guidelines for management embedded within the planning document.

11. Cultural mapping must now be extensively conducted to identify all facets of the living culture that has to be protected. Even as we speak, many of our traditional trades are being threatened by eviction and the presence of illegal swiftlet houses.

12. Enforcement has to be more diligent and stringent in relation to conservation guidelines, illegal and inappropriate renovations and incompatible signboards and advertising boards. Good design and maintenance must be practised, focused on barrier-free access, cleanliness and general health and safety issues.

13. Create a grant system to encourage building owners to conserve their buildings and lobby the federal government to create heritage tax incentives. BWM has consistently submitted proposals to the Ministry of Finance through the years and is still pursuing the matter. Now that there are cultural sites listed the government should recognise the urgency of the need to drive the practice of conservation.

14. The World Heritage Convention does not focus on economic development and sustainable growth. Nonetheless, the WHSMP must address this subject with equal emphasis. This must be dovetailed into the State’s Strategic Economic Plans.

15. It was announced that the State is setting up a State Heritage Steering Committee. This is a step in the right direction. This committee must work very closely with the Ministry of Culture, Art, Heritage and Unity. It members must include technical experts with connections to the Advisory bodies named in the World Heritage Convention, especially ICOMOS (International Council on Monuments and Sites), ICCROM (International Centre for the Study of the Preservation and Conservation of Cultural Property) and IUCN (International Union for Conservation of Nature) and key stakeholders of the Site. One of the key committees created within the Management framework is a DESIGN/TECHNICAL REVIEW PANEL which will be called upon to vet all major building designs submitted within the CORE AREA and BUFFER ZONE.

16. The WHSMP was prepared in broad accordance with the general procedures and requirements published in 1998 and revised in 2005 by ICCROM, ICOMOS and UNESCO as Management Guidelines for World Cultural Heritage Sites, as well as having reference to other Best Practice Models.

Ar. Laurence Loh Kwong Yu, AA Dipl, LAM, APAM, RIBA, ICOMOS,

Deputy-President, Badan Warisan Malaysia