Heritage agency moves to cancel Sewoon District 4 redevelopment approval to protect Jongmyo Shrine

The Jongmyo Daeje royal ancestral rite is performed at Jeongjeon, the main hall of Jongmyo Shrine in Jongno-gu, Seoul. [Korea Tourism Organization]

South Korea's Cultural Heritage Administration has moved to defend Jongmyo Shrine, a UNESCO World Heritage Site, from a high-rise redevelopment project in central Seoul.

The agency has launched a formal procedure to invoke the Ministry of Land, Infrastructure and Transport minister's authority to cancel approval for the Sewoon District 4 redevelopment project, which would allow buildings as tall as 142 meters. If the procedure is completed, the project faces an effective halt.

Cancellation bid routed through culture and land ministries

Ritual officiants enter Jeongjeon, the main hall of Jongmyo Shrine, during the Jongmyo Daeje royal ancestral rite. [Yonhap]

The Cultural Heritage Administration said Wednesday it had initiated a ministerial cancellation procedure through the Ministry of Culture, Sports and Tourism and the Ministry of Land, Infrastructure and Transport after the Seoul Metropolitan Government rejected its request Monday to rescind the revised implementation plan approval for the Sewoon District 4 project.

The dispute erupted when the outgoing head of Jongno-gu approved a revised implementation plan for the Sewoon District 4 project on June 18, just before his term ended, and published it in the official gazette the following day. The revision's centerpiece was a sharp increase in building heights — from 54.3 meters to 98.7 meters along Jongno and from 71.8 meters to 141.9 meters along the Cheonggyecheon side — with the scale expanded to 38 above-ground floors. The near-doubling of heights compared with the original plan raised serious concerns about irreversible damage to the historic and cultural landscape surrounding Jongmyo Shrine.

The Cultural Heritage Administration determined the revised plan was unlawful and asked the Seoul Metropolitan Government, the supervisory authority over Jongno-gu, to issue a corrective order on June 26. The agency had already issued an administrative order in May under the Framework Act on National Heritage, directing that all permitting procedures be suspended until a Heritage Impact Assessment was completed. The outgoing Jongno-gu chief pressed ahead with the approval in defiance of that order, which the agency said constituted a clear procedural violation.

Seoul rejected the request on legal grounds. Under Article 188 of the Local Autonomy Act, the authority to issue a corrective order rests with the minister of the competent ministry — not the head of the Cultural Heritage Administration — so the city argued the cancellation request lacked the required legal standing. The provision allows a higher authority to issue a corrective order when a local government's decision violates laws or significantly harms the public interest, and empowers the competent minister to cancel the decision by authority if the order is not followed.

A high-stakes gambit as UNESCO delisting looms

Rebuffed by Seoul, the Cultural Heritage Administration chose an alternative route. The agency plans to proceed through the Ministry of Land, Infrastructure and Transport, which oversees implementation plan approvals under the Urban and Residential Environment Improvement Act. Under this approach, the agency will first relay its legal grounds for finding a violation to its parent ministry, the Ministry of Culture, Sports and Tourism, which will then formally request that the land ministry exercise its cancellation authority — leaving the final decision with the land minister.

"We are in ongoing consultation with the Ministry of Land, Infrastructure and Transport on building the legal case," an agency official said. "If the land minister exercises the authority to cancel the approval, Seoul will in effect be unable to proceed with the development."

Democratic Party of Korea lawmaker Kwak Sang-eon holds a press conference at the National Assembly's media center to denounce the approval of the Sewoon District 4 redevelopment project near Jongmyo Shrine. [Yonhap]

Pressure from UNESCO is also driving the agency's aggressive stance. A confidential letter sent by the UNESCO World Heritage Centre in March — made public by Democratic Party of Korea lawmaker Kwak Sang-eon of the National Assembly's Culture, Sports and Tourism Committee — shows that UNESCO urged the South Korean government to conduct a Heritage Impact Assessment before approving the Sewoon District 4 redevelopment. The letter indicated that without a satisfactory response, UNESCO could place Jongmyo on the agenda of the 48th UNESCO World Heritage Committee session, running July 19 to July 29 in Busan, as a candidate for inscription on the List of World Heritage in Danger, and could dispatch expert inspectors.

Under UNESCO operational guidelines, a decision on whether to delist a World Heritage Site is made after a comprehensive review of whether the site's Outstanding Universal Value, authenticity and integrity have been compromised. An official evaluation report by ICOMOS — the advisory body that oversees UNESCO assessments and on-site inspections — published in October 1994, before Jongmyo's formal inscription as a World Heritage Site, explicitly recommended that high-rise development in the surrounding area be strictly restricted to preserve the shrine's visual integrity.

Should Seoul continue to reject the Heritage Impact Assessment and disregard international recommendations, UNESCO could judge South Korea as failing to demonstrate adequate stewardship — a finding that could lead not only to a "in danger" listing but ultimately to removal from the World Heritage List altogether.

"It is true that we received the letter from UNESCO, but no final decision has been made at this point," a Cultural Heritage Administration official said. "We will continue pursuing the cancellation procedure while also working to build consensus through the Heritage Impact Assessment process."

terry@heraldcorp.com