Report of the Joint World Heritage Centre/ICOMOS/IUCN Reactive

MISSION REPORT

Joint World Heritage Centre / ICOMOS / IUCN Reactive Monitoring mission to the World Heritage property

Natural and Cultural Heritage of the Ohrid region (North Macedonia / Albania)

27 - 31 January 2020

TABLE OF CONTENTS

ACKNOWLEDGMENTS ...... 4 1. EXECUTIVE SUMMARY AND LIST OF RECOMMENDATIONS ...... 4 Background ...... 4 Mission methodology ...... 5 Overall state of conservation and factors affecting the Outstanding Universal Value (OUV), integrity and authenticity of the property ...... 5 Major construction and development projects within the property and its setting ...... 7 Railway Kichevoe – Lin Pan European corridor VIII ...... 7 New development plans and projects ...... 9 Progress on previous World Heritage Committee decisions and Reactive Monitoring Missions’ recommendations ...... 10 Mission’s Conclusions and Recommendations ...... 12 2. BACKGROUND TO THE MISSION ...... 22 Inscription history ...... 22 Extension ...... 23 Statement of Outstanding Universal Value ...... 23 Examination of the state of conservation by the World Heritage Committee ...... 24 Justification of the Mission ...... 25 3. NATIONAL POLICIES AND TRANSBOUNDARY ARRANGEMENTS FOR THE PRESERVATION AND MANAGEMENT OF THE PROPERTY ...... 26 Albania ...... 26 Legal protection ...... 26 General Local Plan for Pogradec Municipality ...... 27 Management Plan for the Pogradec Terrestrial / Aquatic Protected Landscape ...... 32 World Heritage Supplement to the Management Plan for the Pogradec Terrestrial / Aquatic Protected Landscape 2017 - 2027 ...... 33 Management arrangements at the national level ...... 34 North Macedonia...... 35 Legal protection ...... 35 Planning framework ...... 35 Management Plan for the Natural and Cultural Heritage of the Ohrid Region (2020 – 2029) ...... 37 Management arrangements at the national level (North Macedonia) ...... 39 Transboundary management arrangements ...... 40 Community participation ...... 42 4. BOUNDARIES ...... 43 5. IDENTIFICATION AND ASSESSMENT OF ISSUES AND THREATS ...... 44 Insufficient management effectiveness ...... 44 Type and extent of the threats to the property ...... 44 Environmental threats...... 44 Urban sprawl and illegal buildings ...... 55 Delay and weakness of the moratorium on any new construction ...... 59

Proposed Development Projects ...... 60 Tourism pressures ...... 66 Use and artificialization of the lakeshore...... 67 Lack of a Tourism Tax ...... 72 Large Infrastructure Projects ...... 73 Projects for the conservation of cultural heritage monuments and historic urban fabric ...... 78 Projects for the conservation of natural heritage ...... 80 6. ASSESSMENT OF THE STATE OF CONSERVATION OF THE PROPERTY ...... 80 Current state of conservation of the property and trends ...... 80 Progress made in addressing the threats and in responding to previous Reactive Monitoring Missions’ recommendations and World Heritage Committee decisions .. 86 7. CONCLUSIONS AND RECOMMENDATIONS ...... 93 8. LIST OF RECEIVED AND CONSULTED DOCUMENTS AND PUBLICATIONS...... 104 ANNEX 1. TERMS OF REFERENCE, PROGRAMME AND COMPOSITION OF THE 2020 REACTIVE MONITORING MISSION ...... 107 ANNEX 2. LIST OF ADDITIONAL INFORMATION REQUESTED BY THE MISSION .... 116 ANNEX 3. STATEMENT OF OUTSTANDING UNIVERSAL VALUE OF THE PROPERTY ...... 120 ANNEX 4. MINUTES OF THE FIRST MEETING OF THE TRANSBOUNDARY WATERSHED MANAGEMENT COMMITTEE FOR OHRID LAKE ...... 124

ACKNOWLEDGMENTS The Mission would like to sincerely thank the Albanian and North Macedonia authorities for their hospitality and assistance in the preparation and implementation of this Reactive Monitoring Mission. In Albania, we wish to express our gratitude to Mr. Sokol Gjoka, Secretary General of the National Commission for UNESCO for the successful preparation of the mission as well as Ms. Marsela Plyku Demaj and Ms. Nerxhana Tallushi from the Ministry of Culture. Special thanks go to all officials and specialists met of the following institutions at national and local levels: Ministry of Tourism and Environment; Ministry of Culture; Ministry of Europe and Foreign Affairs; Regional Directorate of Cultural Heritage, Korçë; Regional Agency of Protected Areas, Korçë; Regional Directorate of Territorial Regulation, Korçë; National Institute of Cultural Heritage; Pogradec Wastewater Treatment Plant; Museum of Pogradec; Institute of Archaeology, Academy of Albanian Studies; UNESCO National Commission; for providing valuable information concerning natural and cultural heritage issues in the Albanian side of the property. In North Macedonia, we wish to express our gratitude to Mr. Hristijan Gjorgievski, Adviser to the Prime Minister, Ms. Ana Petrovska, State Secretary, Ministry of Environment and Physical Planning, and Mr. Zoran Pavlov, Department Head, Directorate for Protection of Cultural Heritage, Ministry of Culture, for the successful preparation of the mission as well as for their continued support throughout the same. Special thanks go to all officials and specialists met of the following institutions at national and local levels: Ministry of Environment and Physical Planning; Ministry of Culture; Ministry of Transport; Directorate for Protection of Cultural Heritage; Galičica National Park, Hydrobiological Institute - Ohrid; Public Enterprise Kolekstorski Sistem; Public Enterprise for State Roads; Public Enterprise for Macedonian Rail-Infrastructure; Nezlobinski Museum - Struga; Institute for Protection of Cultural Monuments and Museum – Ohrid; UNESCO National Commission; for providing valuable information concerning natural and cultural heritage issues in the side of the property of North Macedonia. Likewise, the Mission wishes to express its gratitude to Mr. Ilir Xhakolli, Mayor of Pogradec and Mr. Konstantin Georgievski, Mayor of Ohrid, as well as their respective cabinets and the officials met from Struga, for the warm welcome to their municipalities and useful exchanges on the management and conservation of the property. Sincere thanks are also due to the representatives of the non-governmental organizations and private citizens of Podradec and Ohrid who met with the Mission, for sharing their views and submitting useful information on a number of critical issues, as well as for their willingness to participate in the conservation of the Ohrid Lake region. Finally, the Mission wishes to express its appreciation to the World Heritage Centre, ICOMOS and IUCN for their support throughout the mission and the drafting of this report.

1. EXECUTIVE SUMMARY AND LIST OF RECOMMENDATIONS

Background

As requested by the World Heritage Committee at its 43rd session (Baku, 2019), a joint World Heritage Centre/ICOMOS/IUCN Reactive Monitoring mission (RMM) was invited by the

States Parties of Albania and North Macedonia to visit the transboundary property Natural and Cultural Heritage of the Ohrid region from 27 to 31 January 2020. The objective of the mission was to review the overall state of conservation of the property as well as the progress in the implementation of the previous World Heritage Committee and missions’ recommendations, including the recommendations made by the World Heritage Committee in its Decision 43COM 8B.9. The Mission’s terms of reference, programme and team composition are added to this report as Annex 1.

Mission methodology

The mission had several meetings and consultations with national, regional and local authorities, site managers and non-governmental organisations. The Mission undertook onsite visits to many key places however, due to the size of the property, the various issues to be addressed, weather conditions and limited daylight hours, and the duration of the Mission (only 3 days at the property, whilst 1.5 days at both capitals’ governmental offices) not all sites presenting issues could be visited. Two ad-hoc meetings were held with civil society organisations in Albania and North Macedonia. The mission listened to the concerns expressed by civil society on several issues regarding the state of conservation of the property and their view of the insufficient level of communication between authorities and civil society. The Mission consulted several documents, including the 2020 State of Conservation reports and their annexes prepared by the States Parties, additional information requested by the mission, reports prepared by civil society organisations, previous State of Conservation reports, RMM and Advisory mission reports, as well as documents independently found on the web. Given the scope of the issues facing the property, it has been necessary to carry out a detailed analysis, hence the report is longer than usual.

Overall state of conservation and factors affecting the Outstanding Universal Value (OUV), integrity and authenticity of the property

The mission found that the conclusions of the 2017 RMM on the state of conservation of the property still hold valid after three years, due to the slow or insufficient progress made in implementing the recommendations of previous World Heritage Committee decisions and RMMs. Ohrid Lake is still in an oligotrophic state but eutrophication is in progress, being most evident near the rivers’ mouths of Sateska, Koselska, Velgoška and Čerava in the part of the lake in North Macedonia. These are also the areas where reduced species diversity of macrophyte vegetation and macroinvertebrate fauna was detected, even though endemic benthic macroinvertebrates seem to be in a stable condition (Lorenschat et al. 2014, Trajanovski 2016, GIZ 2016). Stocks of the endemic Ohrid trout (Salmo letnica) have been consistently decreasing over the last decades despite annual repopulation efforts (Jordanova et al. 2016), mainly due to overfishing and lack of enforcement of fisheries regulations. However, consistent species population data is lacking, making a more thorough assessment of the situation challenging. A positive correlation between water quality disturbance and the presence of invasive species, especially in lake tributaries, was also established (Trajanovski 2019). Invasive species are considered one of the reasons for some native species being endangered, with fish farms in the Albanian part of the lake, which breed exotic species, contributing to invasive species introduction as well as to water

pollution. Hydrology of the lake has been affected by uncontrolled discharges of lake water into Crn Drim River in the part of the lake in North Macedonia as well as by climate change, with prolonged dry periods without heavy rains, decreasing the water level. Sedimentation is evident near the Sateska River mouth, ultimately altering flora and fauna composition in this part of the lake. In the long-term, this can pose serious threats to the entire ecosystem but steps have been undertaken for returning the Sateska to its old riverbed, which, if implemented, should reduce sedimentation and discharges of lake water. Furthermore, unmanaged, contaminated areas from former mining activity (e.g. iron, nickel, chromium) in Albania are already leading to highly toxic pollution and will further impact the whole region if left unchecked. Heavy metal contamination in the Memëlisht dumpsite, with toxic levels of nickel, chromium, cobalt and lead, is threatening local fauna and flora, as well as human health (Bolles + Wilson & IDRA & S. Guri 2015). Dumpsite removal has been initiated but there are other areas that need urgent closure and remediation. Waterbirds are especially abundant in parts of the lake where reed beds are still present. In the winter of 1989, as many as 79.000 waterbirds were recorded on the lake in North Macedonia, while in 2010 and 2011 only 10.000 and 17.000 individuals were counted, respectively (Wetlands International 2006, Velevski et al. 2010). With growing tourism, alteration of the lakeshore (destruction of reeds and marshes), ongoing eutrophication and poaching, waterbird populations appear to be in decline. The status of species in Galičica National Park appears to be stable, although timber extraction, modifications in land use and tourism pressures, including illegal construction, are changing the landscape thus impacting species habitat. No visitor management plan for the park is in place but a new Management Plan for Galičica is currently being drafted, offering the opportunity to strengthen protection and tourism management measures. In terms of cultural values, in North Macedonia, the historic urban fabric in Ohrid reflects numerous interventions on traditional buildings, infills of empty plots or the substitution of dilapidated old buildings by new ones carried out without the necessary design and implementation skills. Many recent buildings are rehabilitated, reconstructed or constructed using inappropriate building techniques and unsympathetic building materials, such as structures in reinforced concrete, walls in hollow bricks and wooden planks applied to hide concrete beams. The traditional horizontal and vertical wooden supporting structures are often mimicked by simply painting in dark brown the corners and the inter-floor lintels, the upper lintels are often much thicker than the traditional ones due to change in building techniques (concrete slabs instead of wooden structures), and the proportion of windows and doors are also different from traditional ones. This type of intervention has already begun to impact on the integrity and authenticity of the property and if it continues, it could rapidly lead to the diminution of the authenticity and integrity of the traditional historic fabric of the old town and its harmonious relationships with the monumental complexes. Along the lakeshore in the historic town, restaurants and bars encroach upon the lake and removal of these structures has only slowly begun. In Albania, the terrestrial part of the property includes Lin village, with its peninsula and the remains of an early Christian church, which represents one of the last well-preserved stretches of the Ohrid Lake coast, despite some cases of negatively-impacting buildings, and the Drilon Springs, which are among the most important systems of springs feeding the lake.

The construction of tall buildings close to the water, the poor architectural quality of the built environment especially in the main towns, Ohrid and Struga in North Macedonia and Pogradec in Albania (part of the buffer zone), but also along the coast outside urban centres, and the inappropriate and excessive use of the coast for tourism exploitation all have a negative impact on the property, and undermine the possibility to appreciate “the convergence of well-conserved natural values with the quality and diversity of its cultural, material and spiritual heritage [which] makes this region truly unique” (Statement of OUV). Existing proposals for large infrastructure and construction projects that could lead to irreversible transformations of the overall relationship between the historic settlements, archaeological remains, natural values and setting were already identified in the 2017 RMM. Some of the threats to the property have been removed since 2017, notably the plans for the Galičica Ski Centre, the A3 road (sub-sections (a) and (e)) and the tourism development at Ljubaništa 3. Notwithstanding these positive actions, the mission found that actual threats already acknowledged by the World Heritage Committee in Decisions 43 COM 7B.36, 41 COM 7B.34 and 40 COM 7B.68 still persist within the property and new ones have emerged during the 2020 RMM. These are listed in the following paragraph. In summary, since the inscription of the property in North Macedonia over the last three decades and in Albania since 2019, above-mentioned inappropriate interventions have created a highly vulnerable situation due to considerable accumulated transformations; ongoing and planned modifications and developments are exacerbating this already vulnerable situation towards a point of no-return. Increased urbanization and infrastructure development along the coast have progressively interfered with natural resources, causing higher water and timber consumption, increased pollution from untreated wastewater and solid waste, and fragmentation and destruction of native habitats. Based on the findings gathered during the visit to the property, the mission considers that the property is facing both actual and potential threats to its OUV according to paragraphs 179 and 180 of the Operational Guidelines for the Implementation of the World Heritage Convention (OG): i.e. actual threats - namely deterioration of architectural and town-planning coherence; of urban or rural space, and of the natural environment; of the natural beauty and scientific value of the property by pollution and mining – and potential danger – namely lack of adequate implementation of protection and conservation policies; threatening effects of town planning and large scale development and infrastructure projects; planned development projects within the property; the management system is lacking and not fully implemented.

Major construction and development projects within the property and its setting

Railway Kichevoe – Lin Pan European corridor VIII The Mission visited the area in North Macedonia where the railway will run until the border with Albania, as well as the area in Albania where the railway would run up to the existing tunnel exit near Lin. Project documentation submitted in State of Conservation reports by

the States Parties illustrates only standard sections of proposed tracks and does not show where and how the railway will be sited in the landscape. Representatives of the railway agency explained that in North Macedonia the railway will run higher than the lakeshore, possibly through semi-tunnels to avoid rockfalls. However, the existing tunnel exit near Lin is at a much lower level, therefore the railway will need to reach the same level. No profiles of the gradient of the railway were shown. The Mission was informed that the design of the project is proceeding, although no analysis of alternatives, including the tunnel recommended by the ICOMOS expert in the 2017 RMM report, and as requested by the World Heritage Committee, has been prepared.

Highway A2 stretch Trebeništa - Struga The mission visited the site of Highway A2 stretch Trebeništa - Struga and ascertained that no work is ongoing, although the design has been almost completed. The Public Enterprise of State Roads informed the World Heritage Centre that no funds for construction have been secured nor has a construction timeframe been decided. Alternative routes further away from Ohrid Lake should be studied for the sections not yet planned, such as section 3 of the highway (Struga-Kjafasan), and possibly also for section A2, given that funds for its construction have not been secured yet, and its current location is less than ideal (see also the Advisory mission report 2019) and does not facilitate alignment with other linear infrastructure (railway, electricity transmission line and gas pipeline). This alignment is of utmost importance to reduce the physical fragmentation of the rural plain landscape, which is within the property and which contributes to the perception and to the understanding of the “convergence of well-conserved natural values with the quality and diversity of its cultural, material and spiritual heritage makes this region truly unique” (Statement of OUV). The Mission considers that there is an opportunity to study the possibility of aligning the railway, the highway and two further infrastructure projects the mission was informed of onsite – the 400kV transmission line Bitola - Elbasan and a new gas pipeline – particularly in the Struga plain. This alignment would reduce the fragmentation of the landscape and the creation of pockets of land not suitable for cultivation, and therefore facilitating conditions favourable to urban sprawl and inappropriate developments, with likely progressive erosion of the rural character of the Struga plain. However, the line of the road would need to be agreed first, since this development is considered to be the most invasive.

Tourism development at Drilon Springs The draft design for this major tourism development project was chosen in 2019 and the project is now being further developed into a design scheme which is expected by July 2020. The mission noted that, although natural restoration of the springs would be welcome if done appropriately, the project envisages building development that appears to be excessive and planned in areas which should remain undeveloped, in order to maintain the integrity of the rural plain which is still cultivated and free from construction, and to avoid future proliferation of construction. The development plan in its current form represents, in the Mission’s view, a potential danger to the OUV of the property according to paragraphs 179 and 180 of the Operational Guidelines, especially given that the Drilon Springs are one of the most important systems of springs feeding into Ohrid Lake and contributing to its oligotrophic status.

Reconstruction of Quay Macedonia – Ohrid

The site and the project were examined by the mission. Whilst the quay appears to be in need of repair work, the Mission considers that the current project envisages a massive

concrete structure and an unwarranted expansion of the quay by some 1.2m, which would further encroach upon the lake. The Mission considers that the current project would cause further hardening of the lake edge and have a strong negative impact on the property. It should be modified in order to repair the quay without any expansion.

Ljubaništa 1 and 2 tourism development zones The sites of the tourism developments at Ljubaništa 1 and 2 - which still hold valid as no cancellations were reported by the State Party of North Macedonia - were not visited by the 2017 mission. No update or project documentation has been provided, and as the sites could not be visited by the 2020 mission, their potential negative impact and current state of advancement are not known.1

The threats deriving from the above-mentioned projects have been only partly addressed by the States Parties, and meanwhile additional threats were identified during the 2020 mission, some of which were already under development, or at advanced design and approval stages. These out outlined below.

New development plans and projects Additional previously unreported infrastructure development projects that cross the Struga plain and the property at various points and cause similar potential threats are: ● the 400kV transmission line Bitola - Elbasan, which is planned to cross Struga Plain and for which a EIA has been conducted; ● the gas pipeline connecting Skopje to the Albanian border via Ohrid and Struga; ● prospects for Ohrid airport traffic expansion. Further projects and planning provisions that could represent potential threats according to paragraphs 179 and 180 of the Operational Guidelines include: ● concept proposal for a large marina at Studenčišča Marsh in North Macedonia; ● building development possibilities along Lin lakeshore and on top of the peninsula, one of the last almost unspoiled stretches of the lakeshore in Albania; ● development and regeneration project for Drilon Springs, including the construction of tourism facilities and buildings; ● projects for regeneration of the waterfronts of Pogradec, Tushemisht and Lin in Albania, including potential new construction.

Meanwhile, the development of a free economic zone – essentially zones for development managed at the central government level through an ad-hoc agency – near the Ohrid airport is underway, without any prior information or documentation being shared with the World Heritage Centre, and the construction of a massive promenade along the lakeside of the Studenčišča Marsh has already been completed, although information about the project was not transmitted to the World Heritage Centre nor was the site visited by the 2017 mission.

These additional plans and proposals as well as the existing ones could lead to the severe deterioration of attributes of OUV, and thus, in addition to actual threats mentioned above,

1 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the “zone” Ljubaništa 2 does not exists and there are no plans for its development. A site had been considered in the period 2015-2016 but has since been abandoned. No legal or administrative measures have been taken for its creation. .

represent potential dangers to the property according to paragraphs 179 and 180 of the Operational Guidelines.

Progress on previous World Heritage Committee decisions and Reactive Monitoring missions’ recommendations

The Mission found that, despite the States Parties’ efforts in the last months, only some of the World Heritage Committee decisions and recommendations of previous RMMs have been fulfilled, whilst several have only been partly or insufficiently implemented, and a number of them not addressed at all, as the detailed analysis presented in the Conclusion section of this report indicates. A summary of the state of implementation of previous decisions and recommendations is provided below as a list, for ease of reference.

The three recommendations that have been implemented are listed below:

● Cooperate towards a transboundary extension of the property to include the Albanian part of Lake Ohrid and its watershed (32 COM 8B.49, 2008) ● Halt the construction projects of the sub-sections (a) and (e) of the A3 road and the Galičica ski resort within the property (41 COM 7B.34, 2017) ● Finalise the Management Plan for the property (North Macedonia) (43 COM 7B.36, 2019) (draft finalised)

However, several recommendations have been only partially implemented:

● Fully implement the Management Plan (Albania) (43 COM 8B.9, 2019) ● Approve and operationalise the Municipal Development Plan (Albania) (43 COM 8B.9, 2019) ● Increase human and financial resources to support the management of the property (43 COM 8B.9, 2019) ● Introduce a monitoring regime for cultural assets; prepare an inventory of the cultural sites in the buffer zone and introduce a conservation approach for these and the buffer zone landscape (Albania) (43 COM 8B.9, 2019) ● Reduce motorised traffic in Ohrid old town (RMM 2017)2 ● Explore options to re-divert the Sateska river back into the Crn Drim river (RMM 2017)

A number of recommendations have been insufficiently addressed:

2 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the recommendation has been implemented and that the traffic in Ohrid old town is regulated by ramps and electronic key cards on all three entrances to the Ohrid old town, and this access is limited to inhabitants of the old town only. The road parallel to the Quay Macedonia is closed for traffic.

● Assess the cumulative impacts of the railway and highway A2 on the OUV of the property, and justify the choice of not pairing them, or not changing their alignments in order to bring them closer in the northern part of the property. (RMM 2017; 43 COM 7B.36, 2019) ● Strengthen transboundary cooperation (RMM 2017) ● Strengthen protection at Lin church and appoint designated personnel for the management of Lin church, Lin village and Lin peninsula (43 COM 8B.9, 2019) ● Continue to remove illegal buildings along the lakeshore and re-align part of the road away from the lake (Albania) (43 COM 8B.9, 2019) ● Put in place a moratorium on any coastal and urban transformation within the property (North Macedonia) (RMM 2017; 43 COM 7B.36, 2019) ● Inventory illegal constructions, assessing their impacts on the OUV of the property, and proceed to demolishing all those which represent a threat to the property (North Macedonia) (43 COM 7B.36, 2019) ● Improve the central wastewater treatment system for all settlements in the Lake Ohrid basin (RMM 2017; 43 COM 8B.9, 2019) ● Close and clean up the Bukovo landfill and all illegal waste dumping sites within the property, and establish a functional communal waste collection system (RMM 2017) ● Take all necessary measures to control invasive species in Lake Ohrid and ensure the regular implementation of a biodiversity monitoring programme (RMM 2017) ● Undertake a thorough assessment in view of defining and establishing a buffer zone for the property, which should ideally include Prespa Lake as well as the remaining part of Galičica National Park (RMM 2017) ● Increase community participation (43 COM 8B.9, 2019) ● Improve collection facilities at Pogradec museum and the conservation of waterlogged material from the pile dwelling sites (Albania) (43 COM 8B.9, 2019) ● Finalize the detailed urban plans for each of the 19 complexes which are part of the monumental ensemble in Ohrid (North Macedonia) (40 COM 8B.68, 2016)

Some key recommendations, reiterated in the last years, have not been addressed:

● Prepare an overall Strategic Environmental Assessment (SEA) and Heritage Impact Assessment (HIA) that assess comprehensively the potential cumulative impacts of all proposed infrastructure plans and other major projects on the property’s OUV (North Macedonia) (40 COM 8B.68, 2016; 41 COM 7B.34, 2017) ● Undertake a comprehensive comparative study of alternative routes for the railway of the Pan European Corridor VIII, including those that do not pass in close vicinity of the lakeshore, and in particular avoiding one of the last well-preserved stretches of the lakeshore on the Albanian-Macedonian border (41 COM 7B.34, 2017; 43 COM 8B.9, 2019)

Mission’s Conclusions and Recommendations

The Mission noted the remarkable efforts deployed by the States Parties, and particularly by the Ministry of Tourism and Environment and the Ministry of Culture in Albania and by the Ministry of Environment and Physical Planning and the Ministry of Culture in North Macedonia, and their subordinated institutions, to address the World Heritage Committee decisions and missions’ recommendations. Nevertheless, the mission found that the property continues to suffer from an accumulation of negative changes and uncoordinated developments occurring throughout the decades which have not been adequately addressed and have led the property’s integrity and authenticity to become vulnerable. The property is currently impacted by a number of factors, which represent actual and potential danger to its OUV in accordance with paragraphs 179 and 180 of the Operational Guidelines.

Progress has been achieved with the finalization of the Management Plan for the property in North Macedonia; however, further improvements and modifications to this plan are necessary, particularly regarding zoning, based on the findings of the SEA report and of the Advisory Bodies’ recommendations: for instance the possibility of development at Studenčišča Marsh has to be reconsidered. Likewise, the Management Plan for the Pogradec Protected Landscape (PPL) in Albania was approved in 2014, however its Management Committee was not created, nor was the enlarged Management Committee envisaged by the World Heritage Supplement to the Management Plan. The mission recognizes the considerable efforts being deployed to return the Sateska River to its old riverbed. A study has been completed and funding secured for its implementation, which should start soon.

The draft General Local Plan (GLP) for Pogradec has been finalized. Whilst this is a good advancement, a number of zoning areas envisaged for development threaten the maintenance of the OUV and represent potential danger for the property according to paragraphs 179 and 180 of the Operational Guidelines, and are not in line with the aims of the World Heritage Supplement to the Management Plan. However, a number of crucial decisions and recommendations have not proceeded with the required pace. These are detailed below. A transboundary coordinated management structure has been constituted – based on the Transboundary Agreement signed in 2004, which established a Watershed Committee – with one meeting held in January 2020. The Agreement remains a forward-looking document for international cooperation. While recognising the recent efforts being deployed by both States Parties on this matter, it is apparent that the proposed implementation is progressing slowly and, in the Mission’s view, is not adequate to address the urgency and gravity of the current situation of the property, which requires rapid, proactive and high-level response. The Mission also found that the

membership level of the Transboundary Committee is not sufficiently high, in terms of decision-making powers and in relation to its mandate as envisaged in the 2004 Agreement, to guarantee its effectiveness. The Secretariat of the Committee appears not adequately resourced to respond to the wide mandate envisaged by the 2004 Agreement. The draft Rules of Procedures would need to be further detailed to provide adequate guidance to the operationalisation of the Transboundary Committee. The inventory of the illegal constructions in the property is also a step forward, however the demolition of illegal buildings is proceeding far too slowly, especially in North Macedonia. At the time of the mission only a few structures had been partially demolished.

The moratorium on any coastal and urban transformation in the property recommended in 2017 was established in August 2019, after a two year delay, by the municipalities of Ohrid, Struga and Debrca in North Macedonia. However, the municipal decisions include several exceptions for a number of building activities, thus voiding the provision. The Mission considers that the moratorium should be reinforced and exceptions significantly limited. Ideally, only ordinary maintenance and works related to wastewater and solid waste management should be considered for exception and allowed to continue, any others should be stopped until the requested assessment is completed. The Mission observes that the Committee decision cannot be considered fulfilled and it is likely that missing the opportunity to enforce a serious moratorium will result in further negative impacts in the future.

The proposed revised law on the Management of the Natural and Cultural Heritage of Ohrid Region has been withdrawn by the government of North Macedonia, due to political issues, and there is no timeframe for its re-submission to parliamentary debate before the political elections, originally scheduled for April 2020.

No joint comparative study of alternative routes for the proposed railway from Kičevohe in North Macedonia to Albania (Corridor VIII), including those that do not pass through the property, has been presented by the States Parties. Likewise, no overall Strategic Environmental Assessment (SEA) and Heritage Impact Assessment (HIA) that assess comprehensively the potential cumulative impacts of all proposed infrastructure plans and other major projects on the property’s OUV has been presented by North Macedonia.

In Albania, the necessary protection of the buffer zone implied by its designation as a protected landscape is not sufficiently implemented, additionally the property lacks sufficient legal protection from a cultural heritage perspective. The ideal way to strengthen protection would require the designation of Lin village as an historic centre, according to the new Law on Cultural Heritage and Museums (2018), as well as the designation of the whole Lin peninsula and the stretch of coastal landscape until the border with North Macedonia as cultural landscape as per the above-mentioned law. However, a discussion on this topic does not appear to have begun and no timeframe has been presented for a protective designation of Lin. The presence in Tushemisht of several springs would suggest extending the monument of nature designation of Drilon to also include these springs or, at least given the intermingling with human use and presence, designating Tushemisht and its spring system as cultural landscape as per the above-mentioned law.

last, intact and fully functioning examples of a marshland habitat on the lakeshore, but its survival is threatened by high coastal development pressure. Furthermore, Ohrid Lake’s hydrology and biodiversity are exposed to serious impacts and threats to the entire lake ecosystem. Despite projects to improve and enlarge the wastewater management systems, shut down irregular landfills, and establish communal waste collection systems being proposed or initiated by both States Parties, these still lack funding for complete implementation, and thus the Mission considers that more should have been done to address such priority recommendations. The recommendation to control invasive species in the lake has been partially addressed, with local authorities in Albania having dismantled some fish farms during the removal of illegal constructions along the lakeshore in 2017-2018, but many others are still active today. The recommendation to strengthen transboundary cooperation on monitoring biodiversity and water quality, and establish common management actions such as jointly agreed fishing quota has not been addressed by the States Parties. This is especially worrying given the impacts of overfishing and evident eutrophication in certain parts of the lake, which should be monitored and controlled. The Mission is concerned that this situation will worsen with the current trend of growing tourist numbers and infrastructure development along the lakeshore. Hence, progress in implementing World Heritage Committee decisions remains too slow and weak due to the insufficient shared understanding of the values of the property by all actors, conflicting visions and priorities for the area among different branches of national institutions and agencies and local administrations, insufficient communication and coordination among central administrations, their regional branches and local administrations, and little involvement of civil society. This has resulted in large scale development and infrastructure projects, often funded or supported by international donors, without adequate evaluation of their impacts on the OUV of the property; in inappropriate planning provisions which cause threats and potential dangers for the property; and in excessive and gradual developments further exacerbated by unregulated constructions and activities. Steps undertaken to strengthen the transboundary management framework are to be encouraged yet remain insufficient: major, strategic and more proactive efforts in transboundary cooperation between Albanian and North Macedonia authorities remain crucial for ensuring appropriate integrative conservation measures not only for the protection of Ohrid Lake, but also for the wider region including Lake Prespa. There are a number of transboundary agreements, strategic plans, bodies, and designations that the property benefits from, the success of which depend on the commitment and the implementation of concrete monitoring and management actions by the two States Parties for the protection of the Ohrid Lake region. The Mission therefore concludes that the actions requested since 2017 have not been completed to address the vulnerabilities and threats then identified, with the result that the gradual erosion of attributes has not been halted, threatening projects and plans are still evolving, and further new threats have been brought to the attention of the Mission. It is therefore evident that the property is highly vulnerable due to significant management issues and poor implementation of the legal framework. These have led to inappropriate interventions, negative effects of town planning, and large scale project proposals, all of which have resulted in severe deterioration of its urban, rural and natural landscapes, and the key attributes of its OUV,

thus causing the property to meet the conditions for inscription on the List of World Heritage in Danger. On the basis of the information gathered and discussions during several meetings with national and local authorities, as well as of the analysis of the state of conservation of the property and the additional documentation made available by the States Parties, the mission has proposed several recommendations to address the actual threats which have negatively impacted the property’s OUV and the potential threats that could increase those impacts. These recommendations are presented in the relevant sections of this report and are summarised below. They have been articulated by area of action and prioritised according to immediate, short- and mid-term timeframes.

Recommendations Timeframe 1. Recommendations concerning potential threats according to paragraphs 179 and 180 of the Operational Guidelines: 1.a Permanently abandon plans for a marina at Studenčišča Marsh and remove from any planning instruments, zoning provisions allowing Immediate any form of development, including leisure zones, at Studenčišča Marsh; 1.b Permanently abandon plans for building developments along the Lin lakeshore and on top of Lin Peninsula, including the completion of a church building near the archaeological remains of the early Christian church, as well as between Pogradec town and Tushemisht. This Immediate implies to: i) Remove from the Pogradec General Local Plan the development zoning areas along the Lin lakeshore and on the top of the Lin Peninsula (PG/HU63 and PG/HU70); ii) Remove from the Pogradec General Local Plan the development zoning area between Pogradec and Tushemisht (PG/BU111). 1.c Permanently remove from the tourism development project at Drilon springs all provisions for fish farming, building options in the agricultural plains along the springs, construction of the Lake Museum or any other building on top of the hill, and significantly reduce the areas eligible for building development, by excluding construction in the plain near the water course linking Tushemisht Immediate and Drilon spring main water body, explore options to relocate part of the proposed development in the hinterland of Tushemisht or in Gurras, where development already occurred; 1.d Modify the project to repair Quay Macedonia without any further enlargement of the quay into the lake; Immediate 1.e Halt all approval procedures and implementation of Ljubaništa 1 and 2 tourism development projects, and transmit the project documentation to the World Heritage Centre for examination by the Advisory Bodies, including details of the planned wastewater Immediate management system and updated visual documentation of the areas3;

3 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the “zone” Ljubaništa 2 does not exists and there are no plans for its development. A site had been considered in the period 2015-2016 but has since been abandoned. No legal or administrative measures have been taken for its creation.

1.f Urgently undertake a joint comprehensive comparative study of alternative routes for the railway of Pan European Corridor VIII, including those that do not pass in close vicinity to the lakeshore, and Immediate in particular avoiding one of the last well-preserved stretches of the lakeshore on the border of Albania and North Macedonia, and taking into account the alternative suggested by the 2017 Reactive Monitoring mission; 1.g Reinstate as a matter of urgency the construction moratorium which is expected to expire in 2020 and revise the Ohrid, Struga and Debrca municipal decisions on the construction moratorium to significantly Immediate reduce its exceptions, limiting authorised interventions to ordinary maintenance but excluding from the moratorium the installations of transmission lines up to 35kV and substations up to 10kV, fire protection installations, local water supply and upgrade of the existing sewerage treatment system. 1.h Take advantage of the uncertainty regarding fund availability and the Immediate consequent pending implementation timeframe of highway A2 and: i. verify the possibilities of combining all planned energy (electricity transmission line and gas pipeline) and transportation infrastructure within the North Macedonia side of the property in one single corridor in the Struga plain, in order to avoid the fragmentation of the landscape in the plain, which contributes to the integrity and understanding of the OUV of the property; ii. explore the possibility to combine highway A2 and the railway in one tunnel, if upgrade of the existing road from Qafe Thane to Struga is not possible, to take advantage of the construction of the tunnel.

2. Recommendations for the remediation of already implemented and negatively-impacting activities / interventions: 2.a Ensure the closure of fish farms4 and rehabilitation of affected areas in all water bodies connected with the lake, especially in the Drilon Immediate and Tushemisht springs; 2.b Close all irregular landfills such as Bukovo, Maucker and Struga, as Three years well as any illegal waste dumping sites within the property, and rehabilitate the affected areas; 2.c Complete the demolition of the structures supporting the terraces Immediate along the lakeshore in Ohrid town, which at the time of the Mission was only partially carried out; 2.d Speed up the process of demolishing negatively-impacting illegal buildings/structures both in North Macedonia and Albania by Immediate preparing an action plan with identified priorities and timeframes for demolition with a three-year time horizon. This implies: i. prioritizing for demolition the priorities identified by Galičica Immediate National Park and within Ohrid Municipality; ii. drafting a list of demolition priorities also for Struga and Debrca Immediate municipalities;

4 In a letter dated 15 January 2021 in which the State Party of Albania provided comments on factual errors in the draft mission report, the State Party informed that all trout fish has been removed. According to the State Party, there is only one construction left, which will be removed when the Water Park Project is implemented. Monitoring is done regularly.

iii. compiling an inventory for Pogradec Municipality similar to the one prepared for Ohrid Municipality and proceeding with an Immediate assessment of the negative impacts on the OUV of the property, its attributes and its setting to determine the priorities for demolition; iv. considering the demolition of the negatively impacting structures Three years and unfinished buildings in Lin village; v. speeding up the administrative procedures to achieve the Three years demolition of the unfinished Lagadin Hotel near Ohrid; vi. preparing an updated map with demolished illegal buildings and Immediate those for which demolition has been proposed. 2.e Urgently complete the removal of the tailings dam and the mining dumpsite at Memëlisht, as well as the area’s rehabilitation and the Three years monitoring of heavy metal contamination in soil, water and locally caught fish; 2.f Evaluate the impacts of former and active mining activity in the surroundings of the property on its OUV and attributes and ensure Immediate the permanent closure and remediation of any mining activities proven to have negative impacts; 2.g Mitigate the impacts of the highway Qafe Thane - Pogradec by: i) removing the service road built to facilitate traffic during Immediate construction; ii) rehabilitating through environmental engineering interventions Five years the cut of the Falaise near Pogradec to build the ‘panoramic (completion) tunnel’; iii) re-designing the landscaping of the highway, prioritising visual Immediate alignment with the natural landscape instead of tree-lines, and (design) native tree species instead of conifers and palms. Five years (execution) iv) preventing any type of edification on the stretches of land between Immediate the lakeshore and the highway;

2.h Restore ecologically sensitive sections of the lakeshore that have Immediate been degraded such as the Studenčišča Marsh and ensure their

connection to the lake, including removing seasonal tourism

facilities and moving them to less sensitive sections of the coast;

2.i Prevent the construction of permanent structures along the beach Immediate adjacent to the new promenade being built at Studenčišča Marsh and

that temporary ones are strictly regulated in terms of material used,

ease of dismantling, shape, size.

2.j Carry out within an 18-month timeframe the revision of the uses of

the lakeshore in all existing or draft plans taking into account the 18 months OUV of the property and its attributes and avoid further degradation (completion) of the integrity of the lakeshore, also ensuring that temporary legal structures are dismantled at the end of the tourist season.

Recommendations to strengthen the management framework and its effectiveness at the transboundary and national levels: 3.a Raise the profile of the members of the Transboundary Watershed Management Committee to include top-level decision makers to guarantee they are empowered to take high-level decisions and, Immediate proportionally, of the members of the Watershed Management Committee Secretariat; guarantee its functionality by involving further human resources from national and local offices; and

strengthen and detail the Rules of Procedure of the Committee in order to guarantee its effective functioning; 3.b Establish and guarantee the effective functioning of the extended Management Committee for Pogradec Protected Landscape (PPL) envisaged by the World Heritage Supplement to the Management Plan Immediate of the PPL, and implement fully the Management Plan and its Supplement ensuring formal endorsement of the latter by all relevant stakeholders; 3.c Give the extended Management Committee for PPL the mandate to prepare an action plan to address the Mission’s and World Heritage Immediate Committee’s recommendations; 3.d Ensure the full operationality of the Management Commission for the Ohrid Region in North Macedonia and guarantee that their decisions Immediate are communicated to all interested parties; 3.e Ensure that development provisions and zoning proposals that are likely to impact negatively on the OUV of the property and its Immediate attributes, including modifications to the zoning of Galičica National Park, are redressed and removed from the revised draft of the Management Plan for the Natural and Cultural Heritage of the Ohrid Region 2020 - 2029 (North Macedonia); 3.f Approve the Management Plan 2020-2029, enforce it, by, first of all, modifying planning provisions in other plans allowing for Immediate developments that may have negative impacts on the property, its OUV and attributes, and implement it and support its implementation by allocating adequate human and financial resources and guaranteeing high-level commitment5; 3.g Ensure that the ongoing development of the new Management Plan for Galičica National Park halts timber extraction activities within its Immediate territory and reinforces the protection of its forested areas while regulating sustainable tourism activities, and send it to the World Heritage Centre and the Advisory Bodies for review; 3.h Prepare both at the national and transboundary levels an action plan and an implementation calendar of short-, medium- and long-term measures to address all previous World Heritage Committee and Immediate Reactive Monitoring Missions’ recommendations and integrate this action plan into the respective management plans for the property; 3.i Increase the RAPA and the RDCH staff dedicated to Pogradec and reinforce the dialogue and cooperation among RAPA and RDCH Immediate dedicated staff, and municipal technical staff, including the Museum staff; 3.j Establish long-term transboundary cooperation on monitoring the lake’s biodiversity and water quality, and establishing common Three years management actions such as jointly agreed fishing quota. 3.l Ensure that all institutions and administrations involved implement the management activities they are responsible for through Two years appropriate monitoring and accountability mechanisms 3.m Consider the introduction for both countries of a tourism tax, its amount being proportional to the hotel class rather than a flat rate, Three years

5 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the Management Plan was approved by the Government of the Republic of North Macedonia in January 2020 (“Official Gazette of RNM” No. 45/20). Aligning of plans, new DUPs and proposals has been going on since February 2020.

where it does not exist, to be managed locally and to provide municipalities with additional revenue to cover the costs deriving from environmental pressures caused by tourism; 3.n Dedicate the revenue of the tourism tax to the improvement of the Five years wastewater and waste management systems as a matter of priority.

4. Recommendations to fully align planning provisions to the OUV of the property and its attributes: 4.a Assess the negative impacts on the OUV of the property of implemented development provisions of expired General Urban Plans Immediate (GUP) for Ohrid, Struga and Debrca, as well as of all other spatial or development plans covering the property or parts of it; 4.b Assess the potential negative impacts on the OUV of the property of the yet to be implemented provisions of the GUPs, as well as of other Immediate existing spatial or development plans, and verify the possibility to cancel or reduce them, on the basis of the considerations and recommendations of all Reactive Monitoring Missions and of the World Heritage Committee; 4.c Revise / update the GUPs for the municipalities in North Macedonia and the draft General Local Plan (GLP) for Pogradec making them Immediate consistent with the aim of preserving the OUV of the property and its attributes; approve and implement them. This includes: i. Establish stricter criteria for the development of area PG/HU64 in Pogradec GLP in order to guarantee that any proposal improves the current conditions, characterised by low quality architecture, inappropriate landscaping and non-native vegetation, and excessive tourism structures on the lakeshore; ii. Preserve the rare rural areas along the lakeshore, which contribute to the appreciation of the OUV of the property and adapt planning objectives and provisions accordingly, the only exception being the former mining dumpsite of Guri i Kuq (Albania) that can be considered for redevelopment.

5. Recommendations to strengthen protection of the property: 5.a Proceed urgently to designate Studenčišča Marsh as a protected area Immediate at the national and at the international level, through Ramsar designation; 5.b Implement expeditiously the provisions of the new Law on Cultural Heritage and Museums (Albania), particularly those related to the Immediate automatic protection provided to landscape categories such as coastal zones, rivers, forests and mountains; 5.c Proceed urgently to designate the whole Lin peninsula as a protected cultural landscape according to the provisions of the Law on Cultural Immediate Heritage and Museums; 5.d Enforce fully the existing legal framework, in particular the current Law on Managing the World Cultural and Natural Heritage of Ohrid Region and proceed with the approval of the new law on the Immediate Management of the Natural and Cultural Heritage of the Ohrid Region as soon as possible; 5.e Elaborate a plan for inventorying additional immovable cultural Three years heritage objects, including archaeological sites, and implement it;

5.f Monitor and control the discharge of lake waters into the Crn Drim Immediate River by North Macedonia power plants company ESM and ensure implementation of best practices in transboundary water management; 5.g Enforce legal provisions to protect native forests, including restoring degraded areas, and take all necessary measures to regulate and Immediate reduce timber harvesting as well as to introduce alternative fuel and power sources; 5.h Use the Transboundary Watershed Management Committee meetings Five years as an opportunity to discuss the potential creation/expansion of the buffer zone of the property; 5.i Remove the material deposited in the narthex of St. Sophia Church and make the narthex accessible to the public, and check the state of Immediate conservation of the narthex and of its mural paintings by certified restorers assessing priorities for intervention; 5.j Provide the local inhabitant monitoring the archaeological remains of Lin Church with forms for monitoring the state of conservation of the Immediate remains and its surrounding area, as well as visitor monitoring for statistics purposes.

6. Elaborate Strategic, Environmental and Heritage Impact Assessments according to the ICOMOS Guidance and IUCN World Heritage Advice Note to assess the cumulative impacts of plans and projects and submit them Immediate to the World Heritage Centre before any final decision is taken. These (beginning) should include: 6.a All plans and planned infrastructure projects (e.g. highway A2, all envisaged stretches, railway corridor VIII Kichevoe – Lin) that may impact on the property, its OUV and attributes, before proceeding with their implementation, including the alternatives that combine the routes of linear infrastructure planned for the Struga plain, as requested by the World Heritage Committee; 6.b High Voltage transmission line focusing on the overhead and underground alternatives; 6.c Gas pipeline project.

7. Recommendations concerning projects to enhance the conservation conditions of the property: 7.a Improve the existing wastewater treatment system for all settlements Immediate in the lake’s basin, ensuring the connection of the lacking rural areas (beginning)/ to the main system or the creation of smaller treatment plants where Five years (completion) needed;

7.b Ensure the allocation of sufficient financial and human resources for Immediate the continuous and efficient running of the Pogradec Wastewater

Treatment Plant; Immediate 7.c Implement a long-term, transboundary water quality monitoring (beginning)/ programme, including the exchange of relevant scientific data and Three years technical support, and in close collaboration with local environmental (completion) authorities. 7.d Establish a functional system for communal waste collection, Immediate separation and treatment, including the rural areas outside the main (beginning)/ towns; Three years (completion)

7.e Proceed with implementing plans to re-divert the Sateska River back into the Crn Drim River as soon as possible, and ensure complete Two years restoration of the Sateska; (beginning) 7.f Provide updated information on the detailed urban plans for the 19 complexes of the Old Nucleus of Ohrid and their level of Immediate implementation; 7.g Implement a transboundary invasive species monitoring programme for Ohrid Lake, and take all necessary measures to control invasive species in the lake and its tributaries, including implementing control Three years and/or eradication programs if needed; 7.h Ensure that reintroduction of red deer in Galičica National Park is only carried out according to expert opinion, and the most recent scientific Three years data and best practices available; 7.i Carry out an impact assessment of the off-road vehicle tourism activities currently permitted in Galičica National Park on its protected habitats and species, and develop and enforce regulations to manage Immediate these activities within the National Park; 7.l Provide detailed information to the World Heritage Centre and the Advisory Bodies on passenger transportation of the already operating passenger boats on both sides of the lake as well as on the propelling Immediate system of the ferry boats and potential pollutants, if any, which can be dispersed into the lake.

8. Recommendations concerning raising awareness of the values of the property and community participation: 8.a Increase community participation in the management, conservation and monitoring of the property by promoting active collaboration Immediate between authorities and civil society and by ensuring that management meetings are open to the public, as well as facilitating access to official information regarding management and the implementation of the World Heritage Committee’s

recommendations ; Immediate 8.b Develop environmental awareness and education programmes in (preparation) close collaboration with local citizens’ groups, targeting especially implementation children and visitors during the summer season. extended in the mid- and long 8.c Continiously communicate the World Heritage Supplement to the term Management Plan of the PPL and its content to all national and local institutions and agencies, and promote the objectives and actions of Immediate the Supplement among local communities through leaflets and meetings.

9. Provide updated information and documentation on all project and plan proposals according to paragraph 172 of the Operational Guidelines and submit the most updated project documentation to the World Heritage Immediate Centre for examination by the Advisory Bodies before any decision is (for all taken, particularly on the following projects: projects) ● Ljubaništa 1 and 26;

6 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the “zone” Ljubaništa 2 does not exists and there are no plans for its development. A site had been considered in the period 2015-2016 but has since been abandoned. No legal or administrative measures have been taken for its creation.

● One hundred villages initiative: Lin, Tushemisht, Gurras; ● Waterscape Park Design of Drilon-Tushemisht; ● Draft masterplan for the Pogradec waterfront and subsequent implementation operational plans and projects; ● Pan European VIII railway; ● Free economic zone near Ohrid airport; ● Ohrid airport expansion7; ● Architectural design for the Quay Macedonia in Ohrid, including the finishing, urban furniture, illumination system and vegetation arrangements; ● Ohrid ring road8.

BACKGROUND TO THE MISSION

Inscription history

The part of North Macedonia (at that time the Former Yugoslav Republic of Macedonia) of the “Natural and Cultural Heritage of the Ohrid region”, a mixed World Heritage property was inscribed for its natural values in 1979 and for its cultural values a year later. In 1979, the Committee decided to inscribe the North Macedonia part of Ohrid Lake on the World Heritage List under what was then natural criterion (iii) (equivalent to current criterion (vii)). In 1980, this property was extended to include the cultural and historical area, and cultural criteria (i) (iii) (iv) were added. Minor boundary modifications were referred back in 2008 (Decision 32 COM 8B.49) and subsequently approved by the Committee in 2009 (Decision 33 COM 8B.40). The 1979 IUCN evaluation noted that the boundaries of the property proposed in the nomination did not meet the criteria of integrity from a natural sciences perspective as it did not include the Lake’s watershed, while the 1980 ICOMOS evaluation highlighted that specific efforts should be devoted to housing which is generally in a poor state of preservation. In 2012, the pilot project “Natural and Cultural Heritage of the Ohrid region” was proposed by the States Parties of the Republic of Albania and Republic of North Macedonia (at that time the former Yugoslav Republic of Macedonia) in the framework of the Upstream Process, endorsed by the World Heritage Committee at its 36th session (St. Petersburg, 2012). One of the main objectives of this project was the extension of the already inscribed mixed site in North Macedonia to the Albanian part of the Ohrid Lake Region to strengthen the property’s integrity in particular in terms of the natural attributes. The project was backed up by European Union funds within a larger three-year project aimed at strengthening the shared governance of the Ohrid Lake Region.

7 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that there are no plans for an airport extension. 8 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that there are no plans for the construction of a ring road in Ohrid.

Extension In 2018, the State Party of Albania submitted the nomination dossier for the extension of the “Natural and Cultural Heritage of the Ohrid Region” which was approved by the World Heritage Committee at its 43rd session (Baku, 2019). The 2019 IUCN evaluation noted that the nominated property did not fully meet the management requirements but, in the situation of the proposed extension of an existing property, these shortcomings could best be addressed via the ongoing State of Conservation process. Lack of sustained collaboration between the different national and transboundary authorities; lack of enforcement of land use restrictions; and lack of long-term funding commitments for management of the area were the identified shortcomings. The ICOMOS evaluation “noted that the nominated terrestrial area and the buffer zone are facing a wide range of threats”, including excessive and uncontrolled development, high rise buildings which are severing the links between the lake and its setting, lack of legal protection and active management of the Lin Peninsula and Drilon Springs. The Committee approved the extension of the property on the Albanian side, but noted with concerns the threats facing the natural and cultural attributes, and the setting on the Albanian side of the property, and provided several recommendations to be fulfilled with a view to inscribe the property on the List of World Heritage in Danger, in case of confirmation of the potential or ascertained danger to its OUV.

Statement of Outstanding Universal Value The Retrospective Statement of OUV for the property was adopted by the World Heritage Committee at its 29th session. With the approval of the extension, the Statement of OUV has incorporated reference to the whole inscribed property. The Statement of OUV is presented in Annex 2. In the report, only some excerpts of the Section on protection and management requirements, that highlight the further work needed to reach an adequate level of protection and management, are quoted: Protection and management requirements […] Legal instruments need to be kept updated and implemented to protect the property. […] These plans need to be effectively implemented and updated regularly. Deficiencies have been noted in the general implementation of urban and protected area planning regulations and plans in both States Parties, which need to be addressed in full. […] Integrated management of natural and cultural heritage through a joint coordinating body and joint management planning are urgently needed to ensure that both the natural and cultural values of the property are conserved in a fully integrated manner. Given the vulnerabilities of the property related to the development and impacts of tourism, the management requirements for the property need strengthening and new cooperation mechanisms and management practices must be put into place. This may include re-evaluating the existing protected areas and ensuring adequate financial and human resources for management as well as effective management planning and proper law enforcement. Whilst transboundary management mechanisms are set up on paper, these need to be actively and fully operational, on an ongoing basis, in order to ensure the transboundary cooperation required to secure the long-term future for Lake Ohrid. Adequate budgets also need to be provided, beyond the aspirations set out in the management documents for the property. Effective integration and implementation of planning processes at various levels, cross-sectoral cooperation, community participation and transboundary conservation are all preconditions for the successful long-term management of Lake Ohrid.

A range of serious protection and management issues require strong and effective action by the States Parties, acting jointly for the whole of the property as well as within each of their territories. These include the urgent need to protect the water quality of the Lake and therefore maintain its oligotrophic ecological function; to tackle tourism and associated legal and illegal development and the impacts of development on habitats and species throughout the property, including on the lake shores. Resource extraction also needs to be effectively regulated, and enforced, including in relation to fisheries and timber harvesting; and action is required to protect against the introduction of alien invasive species. There is also evidence of climate change impacting the property, such as through the warming of the lake, which requires international attention as such issues cannot be tackled at the local level.

Examination of the state of conservation by the World Heritage Committee The World Heritage Committee examined the state of conservation of this property several times between 1998 and 2019. A joint UNESCO / ICOMOS / IUCN Reactive Monitoring mission (RMM) was carried out in September 1998 for the first time since inscription of the site on the World Heritage List in 1979. Already in 1998 the mission noted a highly significant increase of constructions and settlements compared to the time of inscription, when the Old towns of Ohrid and Struga were set in an almost untouched natural environment on the shores of Ohrid Lake: this increase was found to have seriously altered the original balance between built-up and non- built-up areas. At that time only the North Macedonia side of the lake and its ancient settlements and monuments were inscribed on the World Heritage List. The mission report included a set of recommendations calling for a special legal framework for the property (integrating culture and nature), strengthening of the management, preparation of the Spatial Plan for the area and the towns, and extension of the site to include the whole of Galičica National Park. The Bureau of the World Heritage Committee at its 22nd extraordinary session (1998) further recommended the State Party of North Macedonia to consider the recommendations of the mission carefully, particularly with regard to integrated planning and legal protection of the natural and cultural heritage. It also requested the authorities to review the definition of cultural heritage, to define and propose revised boundaries, if appropriate, and to establish adequate buffer zones. In 2017, a second RMM took place and found that: «Lake Ohrid’s hydrology and biodiversity are exposed to diverse impacts and risks including decreased water levels due to prolonged dry periods, and anthropogenic factors such as uncontrolled discharge, water pollution due to inadequate wastewater treatment systems, and evident eutrophication in certain places. In the long-term, this can pose serious threats to the entire lake ecosystem, with several endemic species of the lake already considered endangered. [Identified threatening factors include:] extensive urban development and inappropriate exploitation of the coastal zones which could contribute to its severe deterioration, if no immediate measures are taken by the authorities; […] developments which have already occurred in the urban settlements, agricultural and coastal zones resulting in water pollution, degradation of habitats, alteration and loss of quality of the lake landscape. Considerable change and development have taken place since the inscription of the property. Increased urbanization along the coast has caused increased interference with natural resources, with higher water consumption, increased pollution, and fragmentation and destruction of habitat. The poor architectural quality of many buildings, inside and outside of urban areas, is also a threat to the visual quality of

the property, especially in the main towns, Ohrid and Struga, composed of relatively heterogeneous buildings. Tall buildings or any constructions close to the water, have a high visual impact, threatening the integrity of the property. Other identified factors affecting the property include management and planning, economic and demographic developments; buildings and development; ground transport infrastructure; major visitor accommodation and associated infrastructure and impacts of tourism / visitor / recreation». Recently, the World Heritage Committee examined the state of conservation of this property at its 41st and 43rd sessions, in Krakow (2017) and Baku (2019) respectively, in particular due to the number of large development projects that are planned in the Ohrid region. Other identified factors negatively affecting the property include management and planning; urban development and coastal exploitation; transboundary collaboration; wastewater management; community participation; and protection of cultural assets in Albania. In 2017, the World Heritage Committee appreciated the progress being made with the elaboration of the Management Plan for the property but also made several recommendations to the State Party of North Macedonia and requested to halt the construction of two sections of road A3 and of the Galičica ski centre, to carry out a comprehensive strategic assessment of all infrastructures planned in the property, to study alternative routes for European corridor VIII railway and to implement all 2017 RMM recommendations. Further in 2019, the World Heritage Committee addressed the property under Item 7 and Item 8. Under item 7, it reiterated several recommendations which were not yet addressed by the State Party of North Macedonia, again with a view of considering the inscription of the property on the World Heritage List in Danger in case ascertained and potential dangers should be confirmed.

Justification of the Mission

At its 43rd session, the World Heritage Committee requested the States Parties of North Macedonia and Albania to invite a joint World Heritage Centre / ICOMOS / IUCN RMM to the property to discuss the measures to address the Committee’s recommendations. In addition, the agreed terms of reference of the RMM required to assess the overall state of conservation of the property; analyse the planning situation for all major construction projects in the property and its setting; analyse the planning and protection framework of the property and consider progress with developing short and medium term measures and strategies to strengthen the protection and management of the property; assess the current situation in relation to the request for a moratorium on any transformation within the property and for an inventory of illegal buildings and demolition of those negatively impacting on OUV; review the work undertaken by the States Parties to develop a formal adequately resourced and functioning transboundary coordinated management structure and to strengthen collaborative work between cultural and natural agencies and departments; consider progress with strengthening legal protection in Albania, fully implementing the Management Plan and introducing an effective management system; consider the measures taken to improve the protection of Lin church; review progress with preparing an inventory of the cultural sites in the buffer zone in Albania; analyse the impact of the current treatment of sewage around the lake; and review progress with the implementation of previous Committee decisions and recommendations of previous missions. Please refer to Annex 1 for the mission’s terms of reference, programme and composition of mission team.

2. NATIONAL POLICIES AND TRANSBOUNDARY ARRANGEMENTS FOR THE PRESERVATION AND MANAGEMENT OF THE PROPERTY

Albania

Legal protection In Albania, the property and its buffer zone lie within the Pogradec Terrestrial/Aquatic Protected Landscape (PPL), which was legally established in 1999. However, the PPL does not include the built-up areas, therefore neither Pogradec nor the villages are covered by the provisions of the PPL Management Plan (adopted in 2014) and fall under the provisions of the Municipal General Local Plan (GLP) of Pogradec, which has been elaborated between 2016 and 2019 and is yet to be approved. Within the boundaries of the protected landscape, seven monuments of nature can be found, all declared through the same decree in 2002 and a comparable number of cultural monuments are officially protected. However, the village of Lin still awaits being legally protected and, at the time the Mission took place, no steps had been undertaken in this direction yet. The new Law on the Protection of Cultural Heritage and Museums approved in 2018 provides for a larger spectrum of opportunities for designating Lin village and its landscape setting. A number of laws are listed in the dossier for the extension of the property that are considered pertinent with regard to natural heritage protection. They include: ● Law "On protection of biodiversity", No. 9587, 20.07.2006, as amended by law no. 68/2014, of 03.07.2014, to ensure full approximation to the EC Directive 92/43 / EEC, May 22,1992 "On conservation of natural habitats of wild fauna and flora"; ● Law "On protected areas", No. 81/2017, dated 04.05.2017; ● Law "On protection of wild fauna", No. 10006, dated 23.10.2008, as amended; ● Law "On rules and procedures for international trade of endangered species of flora and fauna", No. 9867, dated 31.1.2008, as amended; Law no. 10.253 dated 11.03. 2010 "On hunting", as amended by Law No. 7/2014 "On prohibition of hunting in the Republic of Albania", adopted on 30.01.2014, and Law No. 61/2016 “On the approval of moratorium on hunting”. In line with the provisions of this law, hunting activity in the country is frozen for the period 2016-2021.

Relevant to the purpose of protection and management of the territory included in the property and in the buffer zone are also the Law on Cultural Heritage and Museums, n. 27/2018 and the Law on Territorial Planning and Development, adopted in 2014. The new Law on Cultural Heritage and Museums has removed the time limit for the designation of immovable cultural heritage objects, includes a chapter on cultural landscapes and establishes that sea - and lake - coastal territories are automatically protected by law for 300m from the shoreline, rivers and streams and other water sources, as well as parks, national and local reserves, forest areas and areas of archaeological interest. This means that these categories are already protected by the law and are subject to control and issuance of ‘landscape permits’ by the National Cultural Heritage Institute. The law also envisages the possibility to protect through ad-hoc declarations a range of other immovable properties, thereby widening the legal protection opportunities that were available before the adoption

of this law. The 2020 State of Conservation report informs that in 2019 a number of regulations for implementing the provisions of this new law have been approved and a number of other ones are being prepared for approval in 2020. The Law on Territorial Planning and Development establishes the aims, principles and objectives of planning, the planning authorities, and the levels of planning. The key instrument for planning is represented by the GLP. Recommendations: ● Proceed expeditiously to implement the provisions of the new Law on Cultural Heritage and Museums, particularly those concerning automatic cultural landscape protection of landscape categories such as coastal zones, rivers, forests and mountains; ● Proceed as a matter of urgency to designate the whole Lin peninsula as a protected cultural landscape according to the provisions of the Law on Cultural Heritage and Museums.

General Local Plan for Pogradec Municipality The General Local Plan (GLP) for Pogradec has been elaborated throughout 2016 and has reached its final stages of preparation but it has not been approved yet. The GLP has been submitted as an annex to the 2020 State of Conservation report; since it is in Albanian, its content, provisions and previsions cannot be fully assessed. However, some preliminary observations and recommendations can be presented. The maps included in the GLP provide an insight on the planning provisions and orientation of the Plan. The Mission observed that several areas along the shore near Lin and on the external side of the Lin Peninsula, along the coastal strip of land between the highway connecting Qafe Thane and Pogradec, are earmarked for conversion in Map 2 of the GLP and, subsequently, in Map 3 some of these areas are indicated as industry and economy. Map 26 of the GLP clearly indicates areas which are earmarked for tourism development along the coast of the lake. The Mission considers that the lakeshore is highly sensitive, therefore all areas currently earmarked for tourism development are likely to lead to potential negative environmental impacts (e.g. overburden of an already inadequate wastewater management system with further lake water pollution) as well as negative visual impacts, taking also into consideration the artificialization already suffered by the lakeshore due to development including the recent construction of the highway and the pressures imposed in Pogradec. For the above- mentioned reasons, the Mission is of the opinion that no edification and no fixed structures could be envisaged in these areas, in order not to increase the already high pressure on the lakeshore. Map 29 of the GLP (figure 5 of this report) illustrates the various categories of intervention, from Conservation to Redevelopment. The latter is defined in the GLP as “an action in the planning process, in low - to high-density residential and use structural units, which aims to reassess the indicators of structural unit development and / or transform the existing urban structure.” The Mission notes that some of the areas earmarked for redevelopment are very sensitive and should not be subject to this category of intervention, if this means construction in areas which are not yet built-up. Two areas are particularly sensitive: the area along the shore at Lin and the area between Pogradec and Tushemisht, immediately behind the lakeshore.

Figure 1. Excerpt of Map 2 from the General Urban Plan (GUP) of Pogradec indicating areas for conversion.

Figures 2 and 3. Excerpts of Map 4: Proposed land use, with category economy and industry in violet.

Figure 4. Excerpt of Map 26: Zones of economic and urban development, with tourism areas in red.

Figure 5. Excerpt of Map 29: Intervention modes on the territory, with redevelopment areas in aqua green.

Figure 6. This GoogleEarth image shows that nothing is yet built along Lin shore. It is of the utmost importance that no construction is allowed here which would prelude to the area’s complete urbanisation.

Figure 7. This GoogleEarth image shows that nothing is yet built on top of the promontory. The situation should remain unchanged and unspoiled.

The Mission considers that the redevelopment units along the shore of Lin village and on the top of the promontory represent potential threats according to paragraph 179 and 180 of the Operational Guidelines and should be cancelled. Nothing should be built along the Lin shore; the one or two existing houses should remain isolated cases which, if built illegally, should be demolished. As a matter of fact, if legally built, consideration should be given by the State Party to purchasing these buildings for their removal, due to their negative visual impact and potential environmental impacts. Nothing further should be allowed to be built outside of the built-up areas of the village, which however can absorb careful consolidation / densification of its urban fabric, essentially in the two areas further away from the coastline and exception made for the upper part of the promontory. The redevelopment unit at the southern edge of the Peninsula is acceptable insofar as any proposal provides for an improvement of the current situation, through a revision of the landscaping with native vegetation and only a very limited increase of built volumes. Another sensitive area that is now planned for redevelopment is a long strip of land at the periphery of Pogradec, adjacent to the lakeshore (see figure 8 in this report). The area is divided into two planning zones, with slightly different development parameters. The Mission notes that the GLP does not include within its provisions of development the target area of the Waterscape Park Design project of the American-Albanian Development Foundation (AADF), which concerns the Drilon Springs and adjacent land. However, this project is in a well-advanced state of development, as demonstrated by the documentation shown to the Mission onsite and the one annexed to the 2020 State of Conservation report. This means that the Drilon Springs are threatened to be strangled by a continuous belt of built-up area from Pogradec to Tushemisht, with only a modest discontinuity corresponding to the springs themselves. The Mission further notes that the territory between the Buçimas-lakeshore road and the springs is still very rural, with only some rare buildings scattered on the territory (see figure 9 below). The Mission considers that the above-mentioned planning provisions, further illustrated below in images, represent further potential danger according to paragraphs 179 and 180 of the Operational Guidelines and should be cancelled.

Figure 8. Excerpt of Map 29: Pogradec and Tushemisht area.

Figure 9. Aerial view of the area between Pogradec and Tushemisht showing the almost unspoiled conditions of the plains in the area earmarked for redevelopment as PG/HU111.

Recommendations: ● Remove from the GLP the zones for redevelopment along Lin lakeshore and on the top of the Peninsula (PG/HU63 and PG/HU70); ● Remove redevelopment zoning area between Pogradec and Tushemisht (PG/BU111) so as to avoid depletion of a still qualitative rural area and the further extension of urbanisation; ● Establish stricter criteria for the redevelopment of area PG/HU64 in order to guarantee that any proposal improves the current conditions, characterised by low quality architecture, inappropriate landscaping and non-native vegetation, and excessive tourism structures on the lakeshore; ● Avoid edification on the stretches of land between the lakeshore and the highway connecting Pogradec to Qafe Thane; ● Preserve the rare rural areas along the lakeshore, which contribute to the appreciation of the OUV of the property. The only exception that can be considered for redevelopment is the former mining dumpsite of Guri i Kuq.

Management Plan for the Pogradec Terrestrial / Aquatic Protected Landscape The Management Plan for the Pogradec Protected Landscape (PPL) was approved in December 2014 and proposes a zoning for the protected landscape with a terrestrial and an aquatic core zone, a sustainable use zone, a traditional use zone and a recreational zone. It sets the following long-term management objectives: a) Strengthen the protected area management system; b) Increase habitats and biodiversity protection and conservation; d) Develop recreational and touristic uses; e) Develop sustainable agriculture and socio- economic activities; f) Promote scientific research and education. Almost all of the lake is considered as a sustainable use zone and only a very limited portion is restricted as a core zone, along the shore near Tushemisht and near Lin. The key forum for the management of the protected landscape should be the Management Committee that should ensure regular formal liaison between the relevant government and non-governmental agencies acting within the landscape. This Committee would consist of representatives of the key government agencies covering both culture and nature, with the National Agency for Protected Areas having a central responsibility in relation to nature conservation matters, and a representative of a citizen’s initiative. However, the 2019 IUCN evaluation noted that the Management Committee for the PPL was established in 2015 but has never met, and the 2019 State of Conservation report (received January 2020) confirmed that this Committee has not been

formally created yet. The draft by-law for its creation is in process of consultation and is expected to be finalized by March 2020. Recommendations: ● Ensure the effective operation of the Management Committee of the PPL, including regular meetings among its members; ● Give the Committee mandate to prepare an action plan to address the RMM and World Heritage Committee’s recommendations; ● Implement fully the Management Plan for the PPL.

World Heritage Supplement to the Management Plan for the Pogradec Terrestrial / Aquatic Protected Landscape 2017 – 2027 The World Heritage Supplement to the PPL Management Plan is intended to complement and strengthen the management for the property. The WH Supplement envisages a co- management approach, involving the following key actors: ● Mayor of Pogradec (Co Chair); ● General Director of Environment Policy and Delivery Unit, Ministry of Environment (Co Chair); ● General Director of National Agency of Protected Areas (NAPA); ● General Director of Culture Heritage Directorate; ● Director of Water Administration Directorate at the Ministry of Agriculture, Rural Development and Water Administration (MARDWA); ● Director of Fisheries Directorate at the MARDWA; ● Representative of the Ministry of Foreign Affairs (UNESCO Secretary General); ● Director of Institute of Cultural Monuments; ● Director of Regional Directorate of National Culture in Korçë; ● Representative of the Institute of Archaeology (Centre for Albanian Studies); ● Representative of the National Agency for Territory Planning; ● Head of the Regional Agency of Protected Areas (RAPA) in Korçë; ● NGO representative; ● Local citizen initiative representative; ● Representative of Pogradec Municipality in charge of environmental issues. This will imply modifying the Management Committee of the PPL. The WH Supplement envisages that the Supplement has to be endorsed by all stakeholders. It has been approved by the Ministry of Tourism and Environment in 2017 but it remains to be clarified if all actors - including representatives of other ministries and the municipal administration - have formally provided their endorsement. The WH Supplement aims to act as a practical guide for all stakeholders in managing and protecting the OUV of the property and its attributes. It has to be seen as an additional layer to the PPL Management Plan covering aspects not considered in that plan, as a complement to the GLP of Pogradec Municipality, to ensure that planned urbanization and development are compatible with the safeguarding of the OUV, and to the Management Plan elaborated by the Republic of North Macedonia for the part of the property located in their territory. It is also the basis for collaborative management of the property, its buffer zone and the Ohrid Prespa Transboundary Biosphere Reserve. The WH Supplement to the PPL Management Plan, which has been the object of a specific activity of the EU funded project “Towards the strengthened and shared governance of the

Ohrid Region”, does not seem to have been appropriated by the Albanian actors. It is written in English, with only a few sentences in Albanian, but a full translation is missing. Recommendations: ● Ensure the official endorsement of the WH Supplement by all relevant stakeholders; ● Create and guarantee the functioning of the larger Management Committee; ● Continuously communicate the Supplement and its content to all state and local institutions, agencies, administrations; ● Promote the Supplement among local communities through leaflets and meetings; ● Prepare an implementation calendar of short-, medium- and long-term measures envisaged by the Plan to address the World Heritage Committee recommendations.

Management arrangements at the national level The PPL is administered by the Regional Administration for Protected Areas (RAPA), a deconcentrated office of the National Agency of Protected Areas, which has its headquarters in Korçë. This office also administers Prespa National Park, as well as other smaller sites outside the Ohrid-Prespa watersheds. Its staff consists of one specialist responsible for natural resource management and biodiversity conservation. The Regional Directorate for Cultural Heritage of Korçë (RDCH) is a specialized deconcentrated state institution depending on the Ministry of Culture and is responsible for the management, preservation, protection and promotion of cultural heritage in the territory of Korçë Prefecture. A subdivision for Pogradec has been established within the RDCH which exercises control over the protected monuments within this territory according to the provisions of legislation in force for cultural heritage, including communication and promotion of the cultural heritage values in the region and abroad. Within the property and the buffer zone, only two cultural sites under the RDCH’s responsibility have some form of visitor services: the historic centre of Pogradec and the Early Christian Church of Lin. Conservation projects of protected monuments must be approved by the Tangible Cultural Heritage Council, a collegial body established by the Law on Cultural Heritage and Museums (2018). Currently the direct management and regular periodic monitoring of cultural heritage assets of Pogradec Municipality are responsibility of the designated personnel of Pogradec Department, part of RDNC Korça. The archaeological remains of the early Christian church in Lin are monitored and maintained by a designated staff who reports to the RDCH staff. He also takes note of the visitors.

Pogradec Municipality is responsible for the management of the territory falling under its responsibility through the GLP, which must respect the provisions and zoning of the Management Plan for the PPL and the principles and recommendations of the WH Supplement to the Management Plan. According to the law, all interventions in protected monuments must be authorized by the National Council for Tangible Cultural Heritage, whilst landscape permits must be sought at the National Cultural Heritage Institute for all interventions in areas protected for their landscape values, including areas protected ex lege, such as lake border areas until 300m from the shoreline. Theoretically, any project falling within this strip of land must first receive the landscape permit issued by the National Institute of Monuments before being authorized by the municipality. Ideally, this should strengthen protection and monitoring, however, it is not clear at which stage of implementation is this provision of the new law. For the property and buffer zone, prior approval of proposed interventions from the Ministry of Tourism and Environment and Ministry of Culture is obligatory.

Despite that on paper, the necessary management arrangements are in place, in practice many of these do not appear to be functional. There is limited culture and experience of collaboration between state and local authorities or among state authorities in Albania, nor between the bodies responsible for nature conservation and cultural heritage. Recommendations: ● Increase the RAPA and the RDCH staff dedicated to Pogradec (add one archaeologist to the team); ● Reinforce the cooperation among RAPA and RDCH staff dedicated to Pogradec and the technical staff of the municipality, including the Museum staff; ● Elaborate a plan for inventorying additional immovable cultural heritage objects, including archaeological sites, and implement it.

North Macedonia

Legal protection The Natural and Cultural Heritage of the Ohrid region has several layers of legal protection. The protection of cultural heritage is regulated by the Law on Cultural Heritage Protection (Official Gazette of RM No. 20/04, 115/07), by-laws and a law declaring the old city core of Ohrid as a cultural heritage of particular importance (Official Gazette of RM No. 154/15). The protection of natural heritage is regulated by the Law on Nature Protection (Official Gazette of RM No. 67/2004, 14/2006 and 84/2007), including within and outside of protected areas. There are also: the Law on Protection of Ohrid Lake, Prespa Lake and Dojran Lake (Official Gazette of RM No. 45/77) under which Ohrid Lake was proclaimed as a protected area (‘monument of nature’), and the Law on Managing the World Cultural and Natural Heritage of the Ohrid Region (Official Gazette of RM No. 75/10), as well as the Law on Waters (Official Gazette of RM No. 87/08, 06/09, 161/09, 83/10, 51/11, 44/12, 23/13, 163/13, 180/14). All legal instruments need to be kept updated and implemented to protect the property. The Draft Law on Managing the Natural and Cultural Heritage of the Ohrid Region, presented as additional information to the 2019 State of Conservation report, was submitted to parliamentary discussion but withdrawn by the Government for further consultations, due to political difficulties. There is no intention to re-submit it to debate before the parliamentary elections of 2020. At this stage therefore, the key law for the protection and management of the property remains the Law promulgated in 2010. Recommendations: ● Enforce fully the existing legal framework, in particular the Law on Managing the World Cultural and Natural Heritage of Ohrid Region; ● Proceed with the approval of the new law on the Management of the Natural and Cultural Heritage of the Ohrid Region as soon as possible.

Planning framework The Management Plan for the Natural and Cultural Heritage of the Ohrid Region (MP 2019- 28 and the updated version MP 2020-29) indicates that “the planning documents guiding the spatial development of the region are: Spatial Plan of North Macedonia i.e. the Spatial Plan of the Ohrid-Prespa region, General Urban Plan (GUP) of the cities of Ohrid and Struga,

detailed urban plans (DUP), urban plans on villages, urban plans for uninhabited areas (UPVNM), plans for urban areas and buildings of national importance, urban planning documentation for buildings of special interest, state urban planning documentation (DUPD), local urban planning documentation (LUPD), urban planning documentation for tourism development zones (UPTRZ), urban planning documentation for auto camps and infrastructure projects in the Ohrid region” (Page 42). The Management Plan has made an inventory of the key planning documents within the property. They include large scale spatial plans, such as the national plan for the Republic of Macedonia (2004), the Spatial Plan of the Ohrid-Prespa region (2005-2020), the Plan on Urban Planning of the Galičica National Park (1988), the GUPs for the towns of Ohrid, Struga and Debrca, the GUP for the Coastal Area of Ohrid, as well as a plethora of detailed plans for specific areas, most of which focusing on urban or tourist development. The Galičica National Park Management Plan (2010-2020) is another relevant management instrument for that part of the property. However, it has expired and a new Management Plan for the park is currently in development to be implemented in 2021: this should focus on halting its current forestry enterprise practices and reinforcing its protection and conservation, while regulating sustainable tourism activities. Both GUP for Ohrid and Struga have expired in 2016 and 2017 respectively. The elaboration of the Plan for Struga initiated in 2018, whilst the one for Ohrid has not begun yet. The Management Plan underlines the importance to achieve the elaboration and approval of new GUPs for Ohrid and Struga. From a planning perspective, North Macedonia is in an ideal situation to revert the current trends of overexploitation of the coastal territory of the property, of the Struga plain and of the property in general for various forms of development. The spatial plan for the whole of North Macedonia expires in 2020, which offers the opportunity to reconsider the vision for the Ohrid region and strategic choices related to infrastructure, commercial, industrial, urban and tourist development towards more sustainable and compatible models with the values of the region.

The expiration of the GUPs for Ohrid and Struga also represents an opportunity for the revision of their development provisions and to make an overall assessment of these Plans: to what extent their provisions and development plans have been fulfilled; what are the impacts, particularly the negative ones, on the OUV and the attributes of the property of the accomplished developments; what are the provisions and development previsions that have not been implemented and what are their potential impacts on the OUV of the property. A similar assessment should also be done to the Spatial Plan of Ohrid and Prespa region. The Management Plan of the Galičica National Park has also expired and it is being revised, offering the chance to strengthen the protection measures and the zoning.

The aims and objectives of the draft Management Plan for the property to safeguard the OUV of the property and its attributes should guide the revision of these plans, as well as of any other plan concerning the property. The elaboration of the Management Plan for the Natural and Cultural Heritage of the Ohrid Region could play a key role in re-aligning former planning provisions with negative impact potential. As a matter of fact, the aims and objectives of the Management Plan should have the priority over any other plans applying to the property. The Mission notes that a number of development previsions in the existing Plans for Struga and Ohrid concern sensitive areas and might need to be reconsidered or reduced (e.g. along the lakeshore in Ohrid and Struga, and in some inland areas bordering the Galičica National Park, e.g. near Studenčišča Marsh).

The zoning envisaged by the MP 2019-28 which has been provided to the World Heritage Centre and the Advisory Bodies in far too reduced resolution to allow for a detailed examination of the zoning and their provisions. However, the proposed zoning for the Management Plan seems to include the possibility that negatively impacting developments can take place: they should be expeditiously revised, as some of them represent potential dangers for the property. Recommendations: ● Assess the negative impacts on the OUV of the property of implemented development provisions of expired GUPs for Ohrid, Struga and Debrca, as well as of all other plans with validity on the property; ● Assess the potential negative impacts on the OUV and its attributes of the yet to be implemented provisions of the GUPs, as well as of other existing plans, and verify the opportunity to cancel or reduce them if needed, on the basis of the recommendations of previous RMMs and of the World Heritage Committee; ● Carry out the Strategic Impact Assessment requested by the World Heritage Committee on all plans and planned infrastructure projects before proceeding with their implementation; ● Revise / update the GUPs making them consistent with the aim of preserving the OUV of the property and its attributes and approve them;

Management Plan for the Natural and Cultural Heritage of the Ohrid Region (2020 – 2029) The draft Management Plan for the property was submitted to the World Heritage Centre in October 2019 for comment by the Advisory Bodies who provided their observations in November 2019. The Mission was informed that the Management Plan was subsequently revised, which was confirmed by the 2020 State of Conservation report, and that its English translation was underway at the time the mission took place. While the RMM report was being drafted, the Mission did not receive the updated version of the Management Plan. However, the revised Management Plan for the Natural and Cultural Heritage of the Ohrid Region World Heritage property 2020 – 2029 (MP 2020 – 2029), was transmitted to the World Heritage Centre by the State Party of North Macedonia at the end of April 2020. The Mission observes that the drafting team has harnessed the technical advice provided by ICOMOS and IUCN and the updated MP 2020 – 2029 is a more mature and informative document. It expands on the values and of the attributes of the property. The efforts to further specify and describe the attributes is noted, however, the landscape would warrant being included among the major attributes of the OUV in the summary list and further articulated in the analysis of the attributes and of their role in conveying the OUV. The revised MP 2020 – 2029 includes among its annexes an account of the history of Ohrid as well as a detailed inventory of cultural heritage objects and archaeological sites, accompanied by notes on the results of the monitoring of these objects, which focussed particularly on monuments and traditional architecture. The MP 2020 - 2029 now provides a detailed account of the legal and planning framework as well as of the issues that both certain laws and planning provisions raise regarding the potential negative impacts they have on the property, its OUV and attributes. However, as stated previously by the Advisory Bodies, a clear overview of key institutions responsible for different aspects of management and their relationship is still lacking. No

overarching body appears to be currently in place for the management of the natural values of the property, with Galičica National Park covering only part of the property. No bodies are proposed to manage Ohrid Lake and Studenčišča Marsh.9 The need remains to clarify how management of natural values will be undertaken for the property as a whole and not only for Galičica National Park. The MP 2020 – 2029 also thoroughly depicts the threats to, and the damages already suffered by, the property: the picture is worrisome as it clearly demonstrates that the highly vulnerable conditions of the property have resulted from decades of high development pressures, limited awareness of the values of the heritage of the region, and from structural management difficulties caused by a sectorial approach, insufficient interinstitutional dialogue and conflicting views about the future of the region and its destiny as a heritage place. The MP 2020 – 2029 includes an action plan that addresses the World Heritage Committee decisions and the 2017 RMM recommendations. The action plan includes a timeframe for each activity as well as the necessary financial resources. The Strategic Impact Assessment report of the MP 2019 – 2028 is a robust piece of work, which clearly identifies the threats to the property, compiles the results of previous EIA assessments on infrastructure projects, and presents an action plan for responding to these threats as well as to the World Heritage Committee decisions and to the RMMs’ recommendations. The Mission noted that the Strategic Impact Assessment report mentions (p. 128) that the draft MP 2019 – 2028 includes provisions for: ● converting the Studenčišča Marsh from a strictly protected zone into a housing zone with special regime; ● changes in the zoning of Galičica National Park to enable development projects; ● tourism development zones in Ljubaništa, Kalishta, Struga, Stenje Oteševo, as well as auto camps in Ljubaništa, Gradishte, Elesec, Andon Dukon, As, Livadishta, Treska. All the above-mentioned developments are considered by the SIA report to be in conflict with the aim of preserving the OUV of the property by the Heritage Impact Assessment. It is the opinion of the Mission that, given the pressures already existing on the property due to urban and tourism development, the above-mentioned proposals should be reconsidered. The Mission concurs with the above-mentioned findings of the SIA report and recommends that, if any of these provisions are still included in the revised MP 2020 – 2029, they are to be removed from it and also cancelled from planning documents.10 Differently from the SIA report, the Mission observes that the agricultural landscape of Struga plain cannot be dismissed as scenically unimportant, as it contributes - in its still relatively little spoiled conditions - to the understanding of “the convergence of well-conserved natural

9 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the Study for valorization of the Studenčišča Marsh has been finalized and adopted by the Ohrid city council and the Government procedure for justifying its designation has been initiated. The Law for designating the Studenčišča Marsh and appointing a management authority is underway. The valorization study for the Ohrid Lake is in its final stage and the protection regimes are currently harmonized with the Management Plan for the natural and cultural heritage. As part of the designation, a management authority will be appointed. Additionally, the existing Management Plan calls for a management body for the marsh. 10 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that any of the mentioned provisions are included in the adopted Management Plan.

values with the quality and diversity of its cultural, material and spiritual heritage makes this region truly unique”, as well as of “an exceptional harmonious ensemble, which is one of the key features that make this region truly unique” (criterion (i)). Therefore, modifications to the plain that diminish this ability to understand the value also undermine both the integrity and authenticity of the property. Hence, it is extremely important that no further urbanization is permitted and that all linear infrastructures are designed in a way to reduce the fragmentation of this landscape (e.g. by choosing, at least in the area crossing Struga plain, one aligned route). The correct considerations raised in the MP 2020 – 2029 on the threats posed to the property by legal and planning provisions need to be turned into actions that remedy the situation and the MP 2020 – 2029 needs to be approved11, enforced and its implementation needs to be supported through adequate human and financial resources and political back-up. Recommendations: ● Ensure that development provisions and zoning proposals that are likely to impact negatively on the OUV of the property and its attributes, including modifications to the zoning of Galičica National Park, are redressed and removed from the revised draft of the Management Plan for the Natural and Cultural Heritage of the Ohrid Region 2020 - 2029 (North Macedonia); ● Approve the Management Plan 2020-202912, enforce it, by, first of all, modifying planning provisions in other plans allowing for developments that may have negative impacts on the property, its OUV and attributes, and implement it and support its implementation by allocating adequate human and financial resources and guaranteeing high-level commitment.

Management arrangements at the national level (North Macedonia) The Law on Managing the World Cultural and Natural Heritage of the Ohrid Region n. 75/2010 establishes the creation of a Commission for the management of the property, with one president, one vice president and 21 members, representatives of a variety of state institutions, municipalities and NGOs, all appointed by governmental decision. The work of the Commission is public. Its tasks include reviewing and providing opinions on laws and regulations pertaining to the protection of the region; on the Management Plan for the region and on any other plans, including spatial and urban plans within the property; monitoring the state of conservation of the property, through an independent body if deemed necessary; and proposing measures to improve the protection of the property. A Management Plan must be developed (see previous section) and its implementation is the joint responsibility of the Ministry of Environment and Physical Planning, Ministry of Culture and the mayors of the municipalities of Ohrid, Struga and Debrca. The mayors must seek the opinion of the state bodies for the protection of environment and culture, as well as of the Commission on the urban plans or any modifications to them before opening them to public debate, and they must integrate these opinions within the plans. The timeframe for providing such an opinion

11 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the Management Plan has been approved by the Government of the Republic of North Macedonia in January 2020 (“Official Gazette of RNM” No. 45/20). 12 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the Management Plan has been approved by the Government of the Republic of North Macedonia in January 2020 (“Official Gazette of RNM” No. 45/20).

is 15 days; otherwise it would mean that they do not have comments and accept the proposal as such. The Law also outlines the scope of responsibilities of the different national institutions and local administrations. The municipalities of Ohrid, Struga and Debrca, along with state agencies responsible for culture are accountable for the management of, and implementation of measures for the protection and conservation of, the property. The holders of natural and cultural heritage of the property are accountable for its maintenance, upkeep, respect and proper use of its resources; the National Conservation Centre – Skopje and the National Institution for the Conservation of Monuments and Culture and Museums – Ohrid are responsible for undertaking preservation and conservation measures of the cultural heritage in Ohrid region; the Museum Dr. Nikola Nezlobinski – Struga is accountable for the preservation of its collections; the Hydrobiological Institute in Ohrid is responsible for proposing and undertaking measures aimed at the preservation and scientific exploration of the natural heritage of the Ohrid region, as well as the management of the fish hatchery to enrich the lake’s fish stocks; the Galičica National Park is responsible and accountable for the preservation of the natural heritage within the area of the park and the prevention of degradation caused by legal and physical persons. Two state bodies are responsible for supervising the implementation of the law by all other actors, in particular the municipalities of Ohrid, Struga and Debrca, the Environment Office and the Cultural Heritage Office. However, decisions on the territory of the property are also taken by other state actors (e.g. the Ministry of Transport and related agencies, the North Macedonia Free Zones Authority) independently of Municipalities, when outside the built- up areas. Recommendations: ● Ensure the full operationality of the Management Commission for the Ohrid Region and guarantee that their decisions are communicated to all interested parties; ● Ensure that all institutions and administrations involved implement the management activities they are responsible for.

Transboundary management arrangements

In 2004, an Agreement between the Councils of Ministers of the Republic of Albania and the Republic of North Macedonia (at that time the former Yugoslav Republic of Macedonia) was signed for the protection and sustainable development of Ohrid Lake and its watershed. To achieve the obligations included in the Agreement, the parties agreed to harmonize criteria, standards, strategies and regulations for urban and rural plans; approve and apply environmental standards for the watershed; create the watershed community and ensure their right to access information, public participation in decision-making and access to justice on environmental matters; develop an effective monitoring system to keep under control the environmental state and quality of the lake and its watershed. To set up the environmental standards and criteria, the agreement envisages a Watershed Management Committee, composed by an equal number of representatives from Albania and North Macedonia: three representatives of central governmental institutions, three representatives of local government institutions and one representative of civil society. The key functions of the Committee are: drafting standards, environmental criteria and requirements for sustainable development as the basis for integrated protection of land, water, air, natural resources, biological diversity, urban environment, natural landscapes and cultural values; completing the regulatory framework; drafting and applying strategies; drafting and implementing

monitoring systems; and gathering, elaborating and publishing environmental information. The Watershed management Committee is also requested to give opinions on the basis of prior provision of opinions by mutual bilateral subcommittees, with regard to spatial plans, status of legislative and regulatory measures, programmes for development, policies and decisions of governments and self-governments that might affect the aims and objectives of the Agreement. The Agreement provides for how decisions are taken (by consensus) and how they are expected to be implemented. A register of decisions is expected to be kept. A Secretariat to assist the Committee is envisaged. It is a technical body acting in the name and for the Committee. Such Secretariat is tasked with preparing the Committee meetings; drafting and managing documents related to the Committee’s and Secretariat’s activity; drafting the decisions; disseminating meeting materials; keeping the relationships with central and local institutions of the Parties, with bilateral bodies, research institutions, NGOs, donors and international environmental bodies; keeping economic and financial documentation; carrying out sensitization activities. The minimum number of Secretariat members would be two, one from each Party to the Agreement. The Secretariat would be based in Ohrid and would be provided with the necessary means of operation by North Macedonia, however, each Party is expected to bear the costs of its own representatives as members of the Secretariat and each Party would be obliged to provide a budget to cover the costs of the functioning of the Secretariat. Since its authorization in 2005 and the approval of the property’s extension at the 43rd session of the World Heritage Committee in 2019, only one meeting of the Watershed Committee took place, on 17 January 2020, with the aim to coordinate the organization of the 2020 RMM. The Agenda of the meeting included the appointment of the Chairperson, of the Secretary and of the members of the Secretariat; the adoption of the rules of procedure, discussion of priority areas for joint management in 2020; and fundraising options for a joint cross-border project involving Albania, North Macedonia and the World Heritage Centre. The minutes of the meeting are very concise and do not clarify what decisions have been taken with regard to rules of procedure, the members of the Secretariat, the priority areas for joint management in 2020, and fundraising options for joint projects. There is no mention in the minutes of key transboundary issues such as water pollution or the European Corridor VIII railway and the need to explore alternative routes that avoid the Lin area. The draft rules of procedure for the Watershed Committee repeat a number of the provisions already agreed upon through the 2004 Agreement and detail only some of them. More detailed rules of procedures would be necessary, in order to guarantee an effective functioning of the Committee, e.g. with regard to: the profile of the central government representatives of each State Party, the way in which decisions that could not be taken by the Committee by consensus are then taken by the governments of the States Parties, what are the Interstate subcommittees, by whom they are formed, how the representative of NGOs is identified and appointed, the forms and timeframe for informing the respective counterpart when a decision cannot be implemented and by when this will be done, etc. At this stage, the draft Rules of Procedure still appear too generic to guarantee effective work by the Committee. Given the wide mandate of the Watershed Management Committee, the Mission also recommends that it be comprised of high-level decision makers (e.g. ministers, vice- ministers) that are empowered on behalf of their governments, whilst the technical- administrative top management (State Secretary director–general levels) is to be reflected in the Secretariat, so as to ensure effective implementation of the decisions in each country and to guarantee adequate preparation of the documents and information for Committee decisions. The current membership of the Committee does not suggest that they can take

decisions within the scope of what is mentioned in the Agreement, given their positions in their respective administrations, nor the current members of the Secretariat hold a position in their respective administrations that can ensure the full implementation of the mandate of the Secretariat (see minutes of the meeting held on 17 January 2020 in Annex 3). Recommendations: ● Strengthen and detail the Rules of Procedure of the Watershed Management Committee in order to guarantee its effective functioning; ● Raise the profile of the members of the Transboundary Committee to include high- level decision makers (ministers, vice-ministers, no less than State Secretary level) to guarantee they are empowered to take high-level decisions, as is the scope of the Committee according to the transboundary agreement; ● Heighten proportionally the profile of the members of the Secretariat to guarantee full implementation of their mandate; ● Guarantee the functionality of the Secretariat by involving further human resources from relevant state and local administration offices.

Community participation

During the drafting of the Management Plan for the Ohrid Region, public consultations were held in Skopje, Ohrid and Struga which were attended by a large number of stakeholders including civil society organizations and private citizens. Contributions by civil society focused on the need to strengthen protection measures, not only by addressing immediate threats to the property, but also by including provisions for rehabilitation of the values that have been damaged or lost, according to the civil society organisations met. The interest of the public clearly shows that the conservation of the property should be a top priority at the local and national levels. During the drafting of the GLP for Pogradec Municipality, public consultations including civil society and private citizens were also held. Among the issues raised by the participants were: the mining dumpsite in Memëlisht and the proposed rehabilitation plan; waste separation and recycling; geo-monument designation; winter heating and solutions to cope with energy demands; uncontrolled fishing and measures to protect fish populations; definition and boundaries of zones for tourism development and zones for economic development. However, as noted in the 2019 IUCN evaluation report, the World Heritage Supplement to the Management Plan for PPL states that: “Management Committee meetings are closed. The chair [the Mayor of Pogradec] may invite stakeholders as appropriate.” To allow for full stakeholder involvement and independent monitoring, these meetings should be open. Transboundary management meetings should also be open to the public, and civil society representatives from North Macedonia attended the first meeting held in Ohrid on 17 January 2020. In Albania, the Mission met with a small number of civil society representatives in a larger meeting with local municipal officials in Pogradec. Among the issues raised there were: waste management and recycling; reforestation; and linking youth to cultural and natural heritage values. It was apparent that most of the participants were not aware of the World Heritage Committee recommendations for the property. They consider that this information was not sufficiently shared by the relevant authorities but showed the will to participate in the improvement of the conservation status of the property.

While in North Macedonia, the Mission met with a large number of civil society representatives and private citizens in Ohrid. Among the issues raised were: illegal constructions; urban development pressures especially by the lakeshore; preservation of St. Sophia Church; conservation of the Studenčišča Marsh; water quality of the lake; solid waste and wastewater management deficiencies; tourism activities in Galičica National Park; fisheries management; the new Law for management of the Ohrid region; and the possibility of the property being put on the List of World Heritage in Danger. Some participants also raised the issue of the public not having access to official information regarding the implementation of the Committee’s recommendations, since their requests to consult the new Law for management of the Ohrid region, as well as a number of large development proposals, were unsuccessful. It was clear that several of the civil society representatives were familiar with the Committee’s recommendations, which again reflects the great interest of the public in the property, as well as the attention of the media, at the local and national levels. This interest should be used to benefit the management and conservation of the property through active collaboration between authorities and civil society. Recommendations: ● Increase community participation in the management, conservation and monitoring of the property by promoting active collaboration between authorities and civil society and by ensuring that management meetings are open to the public, as well as facilitating access to official information regarding management and the implementation of the World Heritage Committee’s recommendations.

3. BOUNDARIES The boundaries of the property differ strikingly between the two States Parties. The lake component represents approximately 95% of the total area of the property in Albania while the watershed is in the buffer zone. Whereas in North Macedonia, the watershed has been substantively included in the property and no buffer zone exists. The draft Management Plan for the North Macedonia side of the property and its associated SIA report assess three alternatives for a possible buffer zone: buffer zone border identical to the border of Ohrid-Prespa Transboundary Biosphere Reserve; buffer zone smaller than the Biosphere Reserve, but including Prespa Lake; and a smaller buffer zone, not including Prespa Lake, but including the rest of Galičica National Park. The first option is not recommended in the Plan because the Resen Municipality and the Pelister National Park would need to be included as management authorities to the property and this might complicate the existing management model. In the second option, Resen Municipality would still need to be added to the management, but the inclusion of Prespa Lake would be assured. In the third option, no new management authorities would need to be added, and the Plan states that the necessary protection of the property would be assured since, by including the border of the National Park that corresponds with the Prespa lakeshore on that section, the connection between it and Ohrid Lake is being recognized. One of the key challenges in defining the buffer zone is proper safeguarding of the St. Naum- Drilon spring complexes in Ohrid Lake, which are connected with Prespa Lake through karstic Galičica mountain. Prespa is also seen as a source of invasive species and pollution, so adding it to the buffer zone might ensure effectiveness of Ohrid Lake protection. During the Mission, local and national authorities in both countries stated that the current priorities are to fully implement the management plans and to consolidate protection of the

existing property, and then think about creating/expanding the buffer zone. This should be one of the long-term issues discussed at the Transboundary Committee meetings, also taking advantage of the fact that this Committee is responsible for governing the Ohrid- Prespa Transboundary Biosphere Reserve according to the watershed agreement signed in 2004. Recommendations: ● Use the Transboundary Committee meetings as an opportunity to discuss the potential creation/expansion of the buffer zone for the long-term future of the property.

5. IDENTIFICATION AND ASSESSMENT OF ISSUES AND THREATS

Insufficient management effectiveness

Although management policies and arrangements are mostly in place, in practice many of these are not sufficiently efficient.

There is a limited and insufficient dialogue, culture and tradition of collaboration among different branches of administration at state and local levels, whilst the dialogue between authorities responsible for nature conservation and cultural heritage is still weak and based on personal efforts. This is evident from the unfamiliarity with and absence of coordination among initiatives from different institutions that may have negative impacts on the values of the property. There is also a lack of culture of transboundary management and of dialogue at the highest decision-making level at the national and transboundary levels on crucial transboundary issues, such as the EU Corridor VIII projects for the railway and highway A2.

Regarding the legal framework, there is some lack of coordination among planning documents, as well as poor implementation of the legal and management policies, for example in terms of enforcement of land use restrictions. This is frequently the result of insufficient human and financial resources for the management, conservation and monitoring of the area.

Finally, there is an excessive focus from authorities on mass tourism development and related urban development, instead of aiming for sustainable tourism and urban planning strategies more appropriate to the management of a World Heritage property. Combined with a lack of understanding the importance of maintaining the ecological continuity between the lake and its surroundings, as well as the heritage importance of the agricultural plains, this is leading to the acceptance of several large development projects with high potential to impact the OUV of the property and its attributes.

Type and extent of the threats to the property

Environmental threats Fishing and Aquaculture Fishing in the region, primarily of the endemic Ohrid trout (Salmo letnica) and the European eel (Anguilla anguilla), is poorly regulated, monitored and enforced. The number of licensed

fishers in Albania has doubled in the last decade, and the activity is certainly unsustainable despite the operation of hatcheries, with frequent seizures of illegal fishing nets by the authorities in both countries. The Hydrobiological Institute in Ohrid supervises artificial spawning for restocking of the lake, also done by the hatchery near Lin village which has released 1.5 million juveniles in 2019, but the impact of the releases is not monitored and it is widely accepted that populations of Ohrid trout are declining. It has also been reported that the European eel population has declined significantly since the construction of hydroelectric dams on the Crn Drin River; and currently is maintained only through restocking. The dams had severe effects on eel fishery as the constructions entirely inhibited natural migration of the fish into the lake (GIZ 2017). In January 2020, the North Macedonia government terminated the fishing concession agreement with the responsible concessionaire due to irregularities (e.g. no protection of fish stocks, no accurate records of caught fish) (Ohrid SOS 2020) but the Mission did not receive information on future actions regarding fisheries management. Likewise, the Mission did not receive data on the status of endemic fish populations as there seems to be no data available, but Jordanova et al. (2016) noted that Ohrid trout stocks have been consistently decreasing over the last decades, despite annual repopulation efforts. Additionally, the presence of fish farms in the Albanian part of the lake has been of serious concern, although steps are being undertaken to address this threat. These breed exotic species such as the rainbow trout (Oncorhynchus mykiss) and lead to pollution from antibiotics and other chemicals used by fish farmers. Several fish farms were dismantled in 2017-2018 during the removal of illegal buildings along the lakeshore but many still subsist namely in the Drilon and Tushemisht areas. According to the SIA of the GLP for Pogradec Municipality, high levels of nutrients such as phosphorus and nitrogen, which accelerate eutrophication of the lake, have been detected in nearby streams. This is especially alarming since the Drilon Springs feed the lake with cool, clean and oxygen rich water, being critical to maintaining the oligotrophic status and the endemic biodiversity of the lake and, therefore, the OUV of the property. Additionally, the springs are designated Natural Monuments and the modifications that have been made to them are illegal. The Fisheries Inspectorate in Pogradec, RAPA in Korçe and the State Police undertake periodic monitoring of aquaculture activities. In October 2019, 25 subjects operating illegal fish farms were identified and given warnings for voluntary dismantling and area rehabilitation by February 2020. Five subjects received fines as well. Consequently, some abandoned the activity, but 19 subjects were still active at the time of the mission visit. When subjects do not comply, the Inspectorate of Territorial Protection is responsible for issuing orders to shut down and dismantle the fish farms but the Mission did not get information on when this will happen. According to the North Macedonia Ministry of Agriculture, Forestry and Water Economy, fish breeding is not allowed in Ohrid Lake and there are no registered or illegal fish production facilities in the area. Recommendations: ● Ensure the closure of fish farms and rehabilitation of affected areas in all water bodies connected with the lake, especially in the Drilon and Tushemisht springs13;

13 In a letter dated 15 January 2021 in which the State Party of Albania provided comments on factual errors in the draft mission report, the State Party informed that all trout fish has been removed. According to the State Party, there is only one construction left, which will be removed when the Water Park Project is implemented. Monitoring is done regularly.

● Establish long-term transboundary cooperation on monitoring the lake’s biodiversity and water quality, and establishing common management actions such as jointly agreed fishing quota.

Photo 1. Illegal fish farm located in the Drilon Springs.

Photo 2. Voluntary dismantling of fish farm in Tushemisht by subject warned by local authorities.

Solid Waste Solid waste management is problematic in the region due to inadequate waste collection, separation and treatment; existence of irregular/illegal dumpsites and landfills which lead to soil, water and air contamination as well as being a threat to human health; and lack of environmental awareness of local populations. The tourist season brings additional pressure to the region due to a large increase in waste generation. In Albania, 70% of areas outside of Pogradec are not served by a waste collection system. Here, inappropriately disposed waste is commonly observed on the side of roads and in drainage and irrigation channels. A non-compliant landfill located near the village of Alarup, in Buçimas administrative unit, serves as such until construction and exploitation of the Maliqi regional landfill. The Mission did not receive information on the progress of the construction of a new waste transfer station and the closure and rehabilitation of the Alarup landfill, as recommended in the SIA of the GLP for Pogradec. Additionally, the shoreline is cluttered with debris throughout much of its length (e.g. near Lin village, between Pogradec and Tushemisht). Seven rivers and water channels are well known to carry solid waste into the lake therefore initial steps have been undertaken to implement a filtering project. The Mission was informed that project activities will include putting in place barrier nets to keep plastic bottles and other waste out of the lake, as well as a filtering mechanism for mud and sand. The project procurement has already been launched and implementation should start by April 2020. In North Macedonia, inappropriately disposed waste is also observed on the side of roads and in drainage and irrigation channels at various sites (e.g. Struga surroundings). Additionally, there are two active irregular landfills in Ohrid Municipality, Bukovo and Maucker, and one in Struga Municipality. Bukovo landfill has been functioning since 1972 but according to the National Waste Management Plan (2009-2015) it is extremely risky for the environment (e.g. Koselska River might carry waste from landfill to lake; uncontrolled fires were reported in 2017) and it needs to be shut down by 2020. A Regional Plan for Waste Management financed by the EU’s IPA Program, including a feasibility study for closure and remediation of non-compliant landfills and dumping sites, has been completed (Enviroplan S.A. & consortium partners 2017). However, funding still needs to be secured for implementation. A draft costing study should be ready by February 2020 for possible implementation by the beginning of 2021. According to this study, the establishment of a new waste management system is expected to commence by the end of 2021, while the closure of irregular landfills including Bukovo would commence at the beginning of 2022. Recommendations: ● Close all irregular landfills such as Bukovo, Maucker, Struga and Alarup, as well as all illegal waste dumping sites within the property, and rehabilitate the affected areas; ● Establish a functional system for communal waste collection, separation and treatment, including the rural areas outside the main towns; ● Develop and establish an environmental awareness and education programme in close collaboration with local citizens’ groups, targeting especially children and visitors during the summer season.

Photo 3. Inappropriately disposed solid waste at the entrance of Struga.

Photo 4 (left). One of the streams between Pogradec and Tushemisht that carries solid waste into the lake. Photo 5 (right). Inappropriately disposed solid waste in Tushemisht village.

Former Mining Activity Former mining activity and the presence of unmanaged brownfields/dumpsites in Albania are an extremely serious threat to the property. Until the early 1990s, the mining industry (e.g.

iron, nickel, chromium) was one of the most important economic activities in Pogradec Municipality but mine closures have left behind many contaminated areas and little has been done to decontaminate and rehabilitate them so far. According to the WH Supplement to the Management Plan of PPL, there are three main sources of contamination in the property: the tailings dam and the mining dumpsite at Memëlisht, and the waters flowing through abandoned mine workings and spoil heaps within the catchment of the lake (in fact, a period of very heavy rainfall could cause a major pollution incident). If left unchecked, this situation will continue to lead to highly toxic soil, water and air pollution from heavy metals and will severely impact the whole Ohrid Lake region. In Memëlisht, just outside Pogradec, a mining dumpsite used until 1992, during the extraction of iron and nickel at Guri i Kuq, is considered a dangerous “Hot Spot” due to the presence of hazardous waste which can have toxic, corrosive, carcinogenic, and other harmful properties. Soil monitoring done in the area showed toxic levels of nickel (up to 40 times the EU limit), chromium (up to 20 times), cobalt (up to 6 times) and lead (up to 2 times). Very high levels were also observed for manganese (1086-1396 µg/kg.) According to the SIA of the GLP for Pogradec, heavy metal content is at such high values that threatens local fauna and flora, including harvested fish species and cultivated plant species, and therefore directly and indirectly also threatens human health. In 2019, remediation of the Guri i Kuq dumpsite (with 100.000 m3 of mining residues) was initiated and the Mission observed that a large part of the residues have already been removed from the area. Removal is being undertaken by the mining company which, according to regulations, will also need to rehabilitate the affected area on the lakeshore. The mining company was supposed to already have finished with residue removal, as well as rehabilitation of the area, but the Ministry of Tourism and Environment and RAPA in Korçe will continue to collaborate on the monitoring of this process. Mineral and oil/gas exploration and exploitation (including associated infrastructure and activities) is incompatible with World Heritage and should not be permitted within these sites. The same activities outside of World Heritage properties should not, under any circumstances, have negative impacts on their OUV. Therefore, it is essential to secure the closure, decontamination and rehabilitation of any mining brownfields/dumpsites inside the property, as well as any mining activity proven to affect the OUV (e.g. there are at least seven licensed mining operators just outside the property). Recommendations: ● Urgently complete the removal of the tailings dam and the mining dumpsite at Memëlisht, as well as the area’s rehabilitation and the monitoring of heavy metal contamination in soil, water and locally caught fish; ● Evaluate the impacts of former and active mining activity in the surroundings of the property on its OUV and attributes, and ensure the permanent closure and remediation of any activities proven to have negative impacts.

Photos 6 and 7. Removal of mining residues from the Guri i Kuq dumpsite on the lakeshore.

Lake Pollution Water pollution is the most significant nature conservation issue in Ohrid Lake, which suffers from untreated sewage and agricultural discharges contributing to eutrophication. The highly endemic biodiversity and natural beauty of the lake, and therefore the OUV of the property, is particularly vulnerable to water pollution. Agriculture is concentrated along the watersheds of the lake’s main tributaries which wash away fertilizers, soil particles and pesticides. While untreated sewage discharges occur in settlements without wastewater management systems that use inappropriate septic tanks and also endanger underground waters. Currently, the Pogradec Wastewater Treatment Plant with capacity for 50.000 people in Albania is functioning efficiently, even during the summer when the local population can double or triple in size. However, there are concerns for the future sustainability of such a costly centre since the German Development Bank (KfW) funding used for its construction terminated in 2018. It is imperative that sufficient financial resources are allocated for the efficient running of the plant which covers the whole town of Pogradec. Even though a wastewater management system is implemented for the town of Pogradec, this is still fully or partially lacking for several of the surrounding rural areas such as the villages of Tushemisht, Buçimas, Vërdovë and Gurras in Buçimas administrative unit. The Mission was informed that a project to connect Gurras to the main system will be finalized in June 2020. Pogradec Municipality has also approved a project to connect other villages to the main system but is currently waiting for budget allocation from the Ministry of Infrastructure and Energy. Other areas still lacking a wastewater management system are Udënisht and Proptisht administrative units. Here, it is not possible to make a connection to the Pogradec main system due to the difficult terrain so smaller wastewater treatment plants are urgently needed. The Mission was informed this area is also currently in the process of application to the government for implementation of a wastewater management system, but the project is not as advanced as the above-mentioned one. Meanwhile in North Macedonia, the existing sewage system is defective causing up to 100 events of wastewater overflow to the surface, and consequently into the lake, throughout the year (JICA 2012). A state-owned enterprise was recently created to rehabilitate the wastewater management system of the region with works starting at the end of 2019. The first phase of the project is planned until June 2020 and includes clearing out the most clogged locations where wastewater overflow occurs, as well as repairing several pumps and pre-pumps to ensure better water flow. Additionally, the Ministry of Environment and Physical Planning (MOEPP) is in the process of planning the EU’s IPA3 Program (2021-2027) which will be dedicated to upgrading the sewage systems of Ohrid and Struga, reconstructing the Vranishta Wastewater Treatment Plant and extending the collector system for the region (Hydro Energo Engineering 2015; Particip GmbH & ETI Consulting 2015). Here, 35% of wastewater produced in Ohrid and Struga municipalities is not being treated i.e. they are directly discharged into the lake, with the sewage coverage of rural areas being especially low, according to the SIA of the Management Plan. Locations not connected to the main system include the villages of Trpejca (inside Galičica National Park) and Ljubanista, as well as the village of Radožda in Struga Municipality. The Mission was informed that Ohrid Municipality is currently considering all potential solutions and is preparing a study for the installation of a small wastewater treatment plant in Trpejca. Water quality monitoring is the responsibility of the National Environment Agency in Albania and of the Hydro-meteorological Institute in North Macedonia. Public Health institutions in both countries also perform water monitoring but this is restricted to beach areas during the summer season. The Hydrobiological Institute in Ohrid gathers water quality data as well,

which is shared with the Albanian Ministry of Tourism and Environment. Yet, a coordinated transboundary water monitoring programme is still lacking. This would greatly help in the control of untreated sewage and agricultural discharges into the lake, which contribute to the rise in nutrient levels. It would also inform the actions needed to tackle climate change impacts already being felt in Ohrid Lake. Recommendations: ● Improve the existing wastewater treatment system for all settlements in the lake’s basin, ensuring the connection of the lacking rural areas to the main system or the creation of smaller treatment plants where needed; ● Ensure the allocation of sufficient financial and human resources for the continuous and efficient running of the Pogradec Wastewater Treatment Plant; ● Implement a long-term, transboundary water quality monitoring programme, including the exchange of relevant scientific data and technical support, and in close collaboration with local environmental authorities.

Photo 8. Agricultural run-off in stream between Pogradec and Tushemisht going into the lake.

Photos 9 and 10. Clearing works of clogged pipes from the Ohrid sewage system.

Invasive Species Several invasive species have been found in Ohrid Lake such as the Canadian waterweed (Elodea canadensis), the Acute pond snail (Physa acuta), the amphipod Gammarus roeseli, and the fish species Rainbow trout (Oncorhynchus mykiss), Silver carp (Hypophthalmichthys molitrix), Stone moroko (Pseudorasbora parva), Prussian carp (Carassius gibelio), Eastern mosquitofish (Gambusia holbrooki), Pumpkinseed (Lepomis gibbosus) and European bitterling (Rhodeus amarus). They have been introduced from various sources, namely from Lake Prespa through the underground karstic system that connects both lakes, from the Sateska and Crn Drim rivers, and directly from human introduction (e.g. accidentally through fish farming). According to the European Alien Species Information Network (EASIN), the Stone moroko is part of the list of 49 invasive species of concern for the European Union, which recommends appropriate measures to be taken if the species has become widespread. Because the Stone moroko is tolerant to a wide range of environmental conditions and occasionally predates on the eggs of other fish species, it can quickly dominate new water bodies, causing the loss of native species. Preliminary studies carried out by the Hydrobiological Institute in Ohrid in 2016-2017 (Trajanovski 2019) established a positive correlation between water quality disturbance and the presence of invasive species, especially in lake tributaries and the Crn Drim River. They also indicated a tendency of aggregation of invasive species, i.e. the appearance of secondary and tertiary invasion in locations with water quality disturbance, which could lead to the alteration of native habitats and food webs. Rigorous information on the presence and impact of invasive species in Ohrid Lake, which can potentially impact the OUV of the property, is still lacking. Therefore, further monitoring of invasive species should be undertaken for the wider Ohrid Lake watershed and, if necessary, control and/or eradication programs should be implemented.

Recommendations: ● Implement a transboundary invasive species monitoring programme for Ohrid Lake, and take all necessary measures to control invasive species in the lake and its tributaries, including implementing control and/or eradication programs if needed; ● Ensure the closure of fish farms14 and rehabilitation of affected areas in all water bodies connected with the lake, especially in the Drilon and Tushemisht springs (same recommendation as above).

Hydrological Issues The diverting of Sateska River into Ohrid Lake in the 1960s had major negative impacts on the lake’s water quality and levels. It became the largest source of phosphorus, a major source of nitrogen, and contributed to the inflow of sediments (over 100.000 m3/year) leading to coastal alterations and eutrophication. Complete restoration of the Sateska River remains an urgent management priority and initial steps have now been undertaken for returning the Sateska to its old riverbed. A UNDP funded study on redirecting the Sateska into the Crn Drim River has recently been completed and funds from the EU’s IPA Programme have been secured to implement the first phase until May 2020. A regional project financed by the Adaptation Fund will also be used to complete the structures needed to redirect most of the water flow by the end of 2023 (UNDP 2019). This is expected to reduce the discharges of lake water into the Crn Drim by 20% which are currently controlled by ESM (Power Plants of North Macedonia), former ELEM, to produce hydroelectric power. Discharges into the Crn Drim result in the decrease of the lake’s water levels and are still heavily felt on the Albanian side. Therefore, these should be appropriately managed in accordance with best practices in transboundary water management. The water levels of Ohrid Lake are regularly monitored by ESM, as well as by the Hydrometeorological Institute of North Macedonia. Although the Mission did not receive detailed data on this, it was possible to observe the impact of climate change on the lake’s low water levels after a very mild and dry winter. The Mission was informed that the water levels of Lake Prespa, which plays an important role in the hydrological recharge of Ohrid Lake, were also unusually low for the season. Recommendations: ● Proceed with implementing plans to re-divert the Sateska River back into the Crn Drim River as soon as possible, and ensure complete restoration of the Sateska; ● Monitor and control the discharge of lake waters into the Crn Drim River by North Macedonia power plants company ESM and ensure implementation of best practices in transboundary water management.

Timber Harvesting A significant amount of timber harvesting (legal and illegal) is still done in the region. According to the WH Supplement to the PPL Management Plan, most households in Pogradec Municipality rely on wood for cooking and winter heating. Total demand has not

14 In a letter dated 15 January 2021 in which the State Party of Albania provided comments on factual errors in the draft mission report, the State Party informed that all trout fish has been removed. According to the State Party, there is only one construction left, which will be removed when the Water Park Project is implemented. Monitoring is done regularly.

been formally measured, but it is likely to exceed 55.000 m3 per year. It is unlikely that fuelwood production is sustainable. This represents a major threat to the landscape and ecological integrity of the area, and demand is likely to increase as the local population increases. If left unchecked, it will lead to soil erosion, siltation of the lake, possible flash floods and will amplify the impacts of climate change. Recovery and reinforcement of the native forest vegetation should be carried out. Protected areas in North Macedonia are traditionally managed as forest enterprises. Likewise, Galičica National Park does not receive funds for conservation management from the central government, so the park has relied on a forestry tradition (e.g. timber extraction) to finance itself. However, park management plans to halt these activities already in 2020 once the park can fully rely on income from tourism activities (e.g. entrance fees were implemented in 2014) and from Prespa Ohrid Nature Trust (PONT) funding (already half of the budget). The Mission was informed that a new management plan for Galičica is currently in development, to be implemented in 2021, which will help ensure the new management vision for the park. Recommendations: ● Enforce legal provisions to protect native forests, including restoring degraded areas, and take all necessary measures to regulate and reduce timber harvesting as well as to introduce alternative fuel and power sources; ● Ensure that the ongoing development of the new Management Plan for Galičica National Park halts timber extraction activities within its territory and reinforces the protection of its forested areas while regulating sustainable tourism activities, and send it to the World Heritage Centre and the Advisory Bodies for review.

Urban sprawl and illegal buildings As already detected by previous RMMs, urbanization has increased significantly since the inscription of the property on the World Heritage List. This Mission can only confirm the findings of the 2017 RMM with regard to the widespread urbanization of the coast of the lake and the diffusion of low-quality construction, often massive and out of scale. Unfortunately, provisions of the Urban Plans in both countries confirm the tendency of urban expansion, also in areas that are unbuilt and have not been developed yet. Specific comments have been provided in the relevant sections of this report. Along the lakeshore, in the last 20 years several developments took place, mostly related to tourism infrastructures. Most of these are poorly planned, developed and executed which leads to fragmentation and degradation of the ecological continuity between the lake and its surroundings, and the cultural and natural landscapes of the area. Additionally, these developments increase the pressures on already inefficient, and in some places inexistent, solid waste and wastewater management systems and contribute to further water pollution.

Figure 11. Aerial view dated 2003. Figure 12. Aerial view dated 2019.

The lakeshore continues to be further artificialized even outside the major urban centres of Ohrid and Struga, in North Macedonia, and outside Pogradec, in Albania. The mission visited the locality of Radožda in North Macedonia, where many permanent concrete structures are built on the shore of the lake, encroaching the lake itself.

Photo 13. Lakeshore in Radožda continues to be artificialized by reinforced concrete embankments and further encroached upon by structures expanding into the lake

On the Albanian side, urban sprawl has concerned essentially Pogradec (in the buffer zone), where several high-rise buildings have been built along the lakeshore and in the city centre.

Photo 14. View of Pogradec from the lake with evident high-rise buildings and urbanisation of the hillsides.

However, several villages along the coast and in the immediate inland in the Pogradec plain have experienced expansion and replacement of traditional or older buildings with new ones, mostly exhibiting low design and material quality. Lin village and its peninsula have suffered a comparatively low urbanization, although in the village, building substitution and increase of height has been detected. Similarly, Tushemisht has suffered less from urbanization, although some negative examples of massive buildings along the coast can be found. Lin peninsula and the stretch of lakeshore north up to the North Macedonia border are the only areas that remain largely unspoiled, despite some development having taken place also at the southern edge of the peninsula and some inappropriate buildings erected in the village. This is why it is essential that new developments are not allowed here, so as not to compromise the integrity of the ecosystems and landscapes to the north of Lin village.

Photos 15 and 16. Two examples of negatively-impacting buildings in Lin. These two structures have remained unfinished for several years now.

Illegal buildings Illegal/informal construction is a widespread phenomenon around the lake which has contributed to exacerbate environmental pressures and negative visual impacts. Legislation for the legalisation of illegal buildings has been issued since 2011 in North Macedonia and

since 2006 in Albania. Recently both countries have begun to address this issue in the Ohrid Lake region. The Ministry of Transport and Communications of North Macedonia worked, in cooperation with the municipalities and Galičica National Park, to obtain information about the illegal constructions erected within the property. As of September 2019, based on the data received during the mission, the requests for legalization received by Ohrid Municipality total 15.939, of which 12.289 consist of buildings, 621 of extensions, 339 of additional flats (as per table provided), 193 of buildings for which the permission procedure was not completed, 165 of terraces. Of the total number of requests submitted, 5805 have been approved (although no information is provided on the typologies of illegal constructions that were legalized), 2543 were not approved and 11.025 are still under process. In Struga, the requests for legalization inventoried a total of 10.693 (no detail on the type of illegal construction has been provided), 4489 have been rejected or found incomplete, 3000 have been approved, 3204 are under examination (it has to be noted that the MP 2020 – 2029 contains slightly different numbers). Ohrid Municipality has prepared a priority list for demolition of 21 structures, including individual and weekend houses, hotel complexes, business facilities and one sports hall. Galičica National Park has listed 29 priority demolitions, all located in Trpejca, 17 within 50m from the shoreline, 8 in the strict protection zone and 4 in the sustainable use zone. The Directorate for the Protection of Cultural Heritage (DPCH) has explained that the legalisation procedure of illegally constructed buildings requires that each request must obtain the consent, complete or partial, from the DPCH, before the municipalities or the Ministry of Transport and Communications issue legalisation decisions. The DPCH requires the Institute for the Protection of Cultural Monuments and Museums - Ohrid to inspect the illegal structures, a Commission within the Institute issues an expert opinion on whether the illegal structure can be legalised or not. On this basis, the Directorate may issue a Consent (if the structure can be legalised), a Notice (if it cannot be legalised) or a Decision (if only part of the structure can or cannot be legalised). No information has been provided on how many Consents, Notices or Decisions have been issued by the DPCH in relation to the requests received. When the Mission visited the property in Ohrid, a handful of structures encroaching upon the lake (restaurant terraces) have only partially been removed, the main supporting structures were still standing. The Mission considers that the demolition of these structures should be finalised as a matter of urgency. While appreciating the effort made by the State Party to address this recommendation, the Mission considers the progress made so far to be insufficient in addressing the demolition of illegal buildings/structures. The Mission recommends completing expeditiously the initiated demolitions of the whole illegal structures and to speed up the process of removal of illegal buildings and structures. The announced new Law on establishing the Legal Status of Illegally Built Facilities in North Macedonia is still pending, meanwhile more than 8.000 legalization requests have been approved, and it is not clear whether the already legalised buildings have been assessed with regard to their possible negative impact on the OUV of the property and whether they received favourable opinion by the DPCH in North Macedonia. In the outskirts of Ohrid town, the structure of Lagadin Hotel, the construction of which started some six years ago within 50m from the lake shore, is still standing, despite decisions taken by different mayors that established that it must be demolished. The Mission was informed that the latest owner’s appeal against the decisions was deposited nine months before the

Mission took place. The Mayor of Ohrid explained that the Lagadin Hotel would not be illegal, but because of public opinion pressure, the municipality is trying to revoke the building permit. In Albania an inventory of illegal buildings located in the property or in the buffer zone exists and all objects have been identified electronically (ashk.gov.al; vd.ashk.gov.al). The information provided counts around 89 applications/declarations in Tushemisht (70 for Informal Buildings built after 1991 and almost 19 for Informal Buildings built before 1991), 1528 applications in the administrative unit Buçimas, which includes Tushemisht and the villages of Buçimas, Verdove, Remenj, Geshtenjas, Baçallek, Guras, Peshkepi, 646 applications for the administrative unit of Udenisht, which includes the villages of Udenisht, Memelisht, Pisqupat, Bukeze and Lin with 58 applications. The Mission was informed that some illegal buildings were demolished in 2016-2019, most of which related to the construction of the highway. Recommendations: ● Speed-up the process of demolishing negatively-impacting illegal buildings/structures both in North Macedonia and Albania by preparing an action plan with identified priorities and timeframes for demolition with a three- year time horizon. This implies:  prioritizing for demolition the priorities identified by Galičica National Park and within Ohrid Municipality;  drafting a list of demolition priorities also for Struga and Debrca municipalities;  compiling an inventory for Pogradec Municipality similar to the one prepared for Ohrid Municipality and proceeding with an assessment of the negative impacts on the OUV of the property, its attributes and its setting to determine the priorities for demolition;  considering the demolition of the negatively-impacting structures and unfinished buildings in Lin village;  speeding up the administrative procedures to achieve the demolition of the unfinished Lagadin Hotel near Ohrid;  preparing an updated map with demolished illegal buildings and those for which demolition has been proposed.

Delay and weakness of the moratorium on any new construction The moratorium on any coastal and urban transformation was requested by the 2017 RMM and endorsed by the World Heritage Committee in the same year, at its 41st session. However, only in August 2019, after the Committee reiterated this request at its 43rd session, the Municipalities of Ohrid, Struga and Debrca finally passed municipal decisions in this regard. This delay has postponed the halt to the issuance of building permits, thereby increasing potential threats deriving from building activity that, despite their legality, may nevertheless have negative impacts on the OUV of the property. The moratorium expired in February 2020. The moratorium requested by the World Heritage Committee targeted any coastal and urban transformations, however the moratorium decisions adopted by the Municipalities of Ohrid, Struga and Debrca allow for a long list of building activities to be continued: plan excerpts, decision on changes during construction, changes of investors, reconstruction, adaptation, reconversion, decisions on buildings for which no building permit is issued, initiated procedures for the issuance of a building, enlargement and extension permit, construction and reconstruction of facilities, construction of buildings for public services (education, sports, science, culture, healthcare and social protection), construction of transmission lines up to 35kV and substation lines up to 10kV, construction of tramway track, fire protection facilities,

local water supply, sewerage and treatment system, stadiums and sports facilities with up to 10.000 spectators, multi-storey garages, municipal roads, squares, public parks, markets, public parking lots, cemeteries, monuments and memorials. The Mission observes that the municipal decisions of Ohrid, Struga and Debrca cannot be considered as an adequate response to the recommendations of the World Heritage Committee and of the RMM. Recommendations: • Reinstate as a matter of urgency the construction moratorium which is expected to expire in 2020 and revise the Ohrid, Struga and Debrca municipal decisions on the construction moratorium to significantly reduce its exceptions, limiting authorised interventions to ordinary maintenance but excluding from the moratorium the installations of transmission lines up to 35kV and substations up to 10kV, fire protection installations, local water supply and upgrade of the existing sewerage treatment system.

Proposed Development Projects Ljubaništa 1 and 2 tourism development zones15 Neither the 2017 nor 2020 RMMs visited the area where the projects for two tourism development zones - Ljubaništa 1 and 2 - are envisaged. The 2017 RMM reported that the project for Ljubaništa 1 (26.8ha) was under approval at the time of the mission. No project documentation was provided to the 2017 RMM nor to the 2020 RMM. The 2017 RMM reported that the SIA on the proposed draft amendment of the Management Plan for the Galičica National Park indicated that at least 20% of the development was planned for construction in Ohrid Lake itself. The project envisaged Ljubaništa 2 (289.50ha) was in 2017 in the initial phase of planning. The 2017 RMM raised concerns about both projects, but no updated information has been provided on these since their mention in the 2017 report. Recommendations: ● Halt all approval procedures and implementation of both development projects, and transmit the project documentation to the World Heritage Centre for examination by the Advisory Bodies; ● Provide an update of the condition of the area with updated photos of the situation (year 2020); ● Provide updated information and details on the wastewater management system planned for the development zones.

One hundred villages initiative: target villages Lin and Tushemisht The 100 Villages Programme is a government-led initiative for integrated rural development. It aims to coordinate development interventions in the 100 villages’ rural area, through a cross-sectoral and multi-stakeholder approach. The programme targets rural development,

15 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the “zone” Ljubaništa 2 does not exists and there are no plans for its development. A site had been considered in the period 2015-2016 but has since been abandoned. No legal or administrative measures have been taken for its creation.

through a centralized approach (integrated and coordinated programming) of public investment, and donor and private investment in 100 villages. The programme objectives include: the improvement of public infrastructure (road, community and environmental infrastructure, revitalization of public / urban spaces, public services, tourism, cultural heritage monuments, multifunctional community centres, and environmental landscape), economic development through diversification of economic activities and the development of social and human capital. The Programme includes Lin village, which is included in the property, and also Tushemisht and Gurras, both in the buffer zone. The Mission notes that all these are sensitive areas - Tushemisht and Gurras due to their proximity to Drilon Springs (in the property) and Tushemisht Springs (in the buffer zone), and Lin for its intrinsic historic and landscape value. The Mission was informed that the projects should be finalised by June 2020. Recommendations: ● Submit all updated project documentation for all local villages (Lin, Tushemisht, Gurras) to the World Heritage Centre for examination by the Advisory Bodies before any approval is issued.

Waterscape Park Design of Drilon-Tushemisht The Drilon Springs are one of the most important systems of springs feeding into Ohrid Lake and contributing to its oligotrophic status by providing cool, clean and oxygen rich water. The main water supply of the lake comes from Lake Prespa via underground tunnels and comes out along the St. Naum-Drilon coast. Therefore, Drilon is one of the most sensitive and valuable areas along Ohrid Lake and any projects planned here should carefully consider its environmental impacts, as well as impacts to the OUV of the property. In 2018, the Albanian American Development Foundation (AADF) launched an Architectural Competition for the Waterscape Park Design (WPD) of Drilon-Tushemisht with the goal to rehabilitate Drilon Park and Tushemisht village. The draft design has been chosen (PROAP 2019) and the project is now in the phase of preparing the schematic design for implementation which will be completed in July 2020. After that, ToR’s for implementation of the project will be prepared. The Mission was informed that the project might be developed with possible KfW funding, but it lacks financial support at the moment. Some key elements of the project include: rehabilitation of Drilon Park; the promenade along the lakeshore; rehabilitation of Tushemisht village; the construction of a Lake Museum; solving the sewage system connection for the village of Gurras and the surrounding areas of Drilon and Tushemisht; and the creation of a ring road between Pogradec and Tushemisht, diverting traffic from the lakeshore, by transforming most of the area into a pedestrian zone. An expected positive result of this project is the much-needed rehabilitation of Drilon Park (currently presenting signs of pollution and damage), if done appropriately, resorting to the recovery and reinforcement of the native riparian vegetation associated with the water channels along Drilon Park as well as the lakeshore. On the other hand, the project also states that “In addition to these socio-cultural activities, the canal itself is already exploited with aquaculture. It will undoubtedly be an excellent opportunity to attribute to these pre-existences the ability to improve their production and increase the associated economic development.” (PROAP 2019). It is worrisome that the illegal fish farms located in the Drilon Springs were included in the project, also mentioned as an opportunity to improve and increase their production.The

springs are designated Natural Monuments and the modifications that have been made to them are illegal. As stated above in this report and widely reported in previous mission reports and assessments, fish farming is an extremely polluting activity besides being a pathway of introduction for invasive species and, as such, it should be terminated and the affected areas rehabilitated. The envisaged urban development between Tushemisht and Drilon Springs covers a far too large area, currently used for farming and not urbanised so far. Furthermore, planning further development in the fields along the inner part of Drilon Springs does not appear acceptable, in that it would expand urbanization and construction in an area so far rural and completely non constructed, as it appears evident from aerial photos (see below), and it could lead to further soil impermeabilization and possibly increased pollution of the springs. Plans include the construction of a Lake Museum on the top of the hill which is known to be a key feature of the hydrological system of Ohrid Lake. Additionally, the location is prominent and very sensitive from a visual perspective; therefore, it is highly recommended that this provision be cancelled, in that it can represent a potential danger according to paragraphs 179 and 180 of the Operational Guidelines. The Lake Museum can be created inside the village of Tushemisht, where a number of houses incorporating water springs exist. Agreements with the owners may offer the opportunity to develop a sort of diffuse museum in the village and public-private partnerships in the spirit of the recommended participative management approaches.

Figure 17. Excerpt of the project documentation indicating the new Lake Museum and a new road to be built on the top of the hill.

Figure 18. Excerpt of the AADF project for Drilon Springs in the version transmitted in annex to the 2020 State of Conservation report.

Figure 19. Excerpt of the project for Drilon Springs – Tushemisht.

Figure 20 Another map of the project for Drilon Springs which identifies further areas for development.

Figures 21 and 22. Aerial view of the areas proposed for development. It is evident that these areas are still pristine.

The Mission noted some differences between the version of the documentation transmitted as annex to the 2020 State of Conservation report and what was shown to the Mission on site. It is of the utmost importance that upon completion of the project’s schematic design, and before any decision is taken, the project is shared with the World Heritage Centre for review by the Advisory Bodies in compliance with paragraph 172 of the Operational Guidelines.

Recommendations: ● Provide the most updated version of the project for the Waterscape Park Design of Drilon-Tushemisht to the World Heritage Centre for examination by the Advisory Bodies; ● Permanently remove from the project: o all provisions of fish farming activity in Drilon Springs; o the possibility to build in the agricultural plains along Drilon Springs; o the plan for building the Lake Museum or any other building on top of the hill near Drilon Springs; ● Reduce significantly the areas eligible for urban development and relocate them away from the lakeshore and from the agricultural fields, e.g. in Gurras or in the hinterland of Tushemisht where some development already occurred.

Requalification of Ohrid Lake Waterfront, Pogradec - Tushemisht village and Lin Village This project is part of a larger operation that focuses on the Regions of Korçë and Vlorë; it is funded by the German Government through KfW and is implemented by the Albanian Development Fund. In Pogradec Municipality, the target areas are the waterfront of Pogradec – Tushemisht and the shoreline of Lin. In Pogradec – Tushemisht, the interventions envisaged include the rehabilitation of degraded areas and ‘reconstruction’ of abandoned structures, as well as the extension of the promenade from Pogradec to Tushemisht. Also, the demolishing of informal settlements along the shore at the entrance of Pogradec and in Tushemisht, the creation of parking spaces at the entrance of Pogradec and in Tushemisht, providing for a new sports area and building the Museum of Fishing. In Lin, the philosophy of the ‘rehabilitation’ of the village is far too much tourism-oriented rather than heritage-oriented. In particular, the idea to build along the lakeshore in the zone currently not built does not respond to the needs to preserve the integrity and authenticity of this area, which is the only one along with Drilon Springs included in the property. This idea should be abandoned. Planning to complete the construction of the Church on the top of the hill in Lin is also ill- conceived. This idea should be abandoned. On the contrary, the existing unfinished structure should be demolished, as it impacts negatively on the setting of the archaeological remains of the early Christian church with its mosaics. Careful consideration should also be given on where to proceed with reforestation. In particular, the rocky outcrop protruding from the peninsula into the lake does not seem to need being reforested, particularly if this implies introducing alien species and geometrical alignments as this is the prevailing landscaping style in the area. In Lin there is also the need to remove structures built into the lake in front of the houses, however there is no mention of such type of intervention. It is also worrisome that key interventions for the environmental safety of the lake and of the inhabitants, such as the water supply system and the sewage system, have not been quantified yet in terms of funding needed, considering that these are priority interventions. The Mission considers that a requalification plan for the Lake Waterfront in Pogradec is more than welcome as long as no new permanent constructions are permitted on the shore and the arrangements provide for an improvement of the current situation, characterized by

fragmentation, lack of services (e.g. dustbins, bicycle path, pedestrian path) and low quality structures for the summer season (which should be temporary, that is to say dismantled and re-mounted at the beginning of each season). It is crucial that interventions are discreet and not massive. Particular care will be necessary in the selection of materials for the promenade, vegetation with preference for native tree species, and furniture. The philosophy of the interventions in Pogradec and Lin should be completely different from the one that has governed the construction of the highway from Pogradec to Qafe Thane. The size and way of construction of this highway has resulted in excessive artificialization of the lakeshore, massive use of concrete, inappropriate vegetation species and distribution, and inappropriate illumination system, with an overall negative impact on the relationship between the lake and its surroundings, interrupting the ecosystem continuity and damaging the experience of the approach to Pogradec along the lake. Recommendations: ● Permanently remove from the project for Lin the provisions of construction along the lakeshore and of the completion of construction of the new church on top of the hill; ● As soon as a draft masterplan documentation for the waterfront projects is prepared, submit it to the World Heritage Centre for review by the Advisory Bodies, and progressively submit all projects for implementation of the masterplan; ● Proceed expeditiously with calculating the costs for the water supply and the sewage systems in Lin, which are two priority interventions, before street rehabilitation; ● Submit any further developed documentation for Lin to the World Heritage Centre for review by the Advisory Bodies.

Tourism pressures Ferry Network project and lake navigation A project to connect Pogradec with the North Macedonia side of the lake via ferry system is under development. The new ferry system will be the first lake transportation line and will work according to EU standards. The service will be operating starting in February 2020 and will work on a reservation basis. The boat is reported not to be polluting and its full capacity is 150 people. The line will connect Pogradec, Lin, Struga and Ohrid. The boat is expected to spend two hours in Struga and two hours in Ohrid. Information on navigation on the North Macedonia side of the property is provided in the SIA report for the Management Plan. There are three 150-passenger ships and one 80- passenger ship. The total number of boats registered in the last 10 years totals 1872. There is no available information on passenger traffic since there is no monitoring of this data. Recommendations: ● Provide detailed information to the World Heritage Centre and the Advisory Bodies on passenger transportation of the already operating passenger boats on both sides of the lake as well as on the propelling system of the ferry boats and potential pollutants, if any, which can be dispersed into the lake.

Off-road Vehicle Tourism Activities in Galičica National Park Galičica National Park has signed Memorandums of Understanding with six companies that operate off-road, 4x4 vehicle tourism activities. Four of these companies use a fleet of up to five vehicles, while two companies can use up to 10 vehicles (for a total of 40 vehicles allowed

inside park premises). If not properly managed, these activities can lead to increased noise disturbance, inappropriate waste disposal, habitat destruction through crushing of flora, soil erosion, water pollution, human-wildlife conflict, introduction of invasive species, and degradation of the pedestrian visitor experience. The Mission did not receive information on the regulations, which manage this activity inside the park, and whether any related impact assessment had been carried out. Recommendations: ● Carry out an impact assessment of the off-road vehicle tourism activities currently permitted in Galičica National Park on its protected habitats and species, and develop and enforce regulations to manage these activities within the National Park.

Use and artificialization of the lakeshore The Mission was informed that rules apply for the use of the beaches in Albania, that the municipal council must approve concession contracts with the operators to manage the use of beaches and of boat piers, and that guidelines and rules exist for these activities and for the structures needed for these operations. The Mission was sent the Copy of the Decision Nr. 171, on 27.03.2019, On Approval of the Regulation on “The Conditions and the Criteria of Conducting Beach Station Activities”, which has been approved by the Council of Ministers. That is the Regulation, based on which the Activities in the Beach Station are conducted. The municipality reported that all temporary structures have been removed; however, no mapping of the structures that existed and have been removed has been provided. The Mission detected at least one ‘temporary’ structure, which was still in place at the time of the mission.

Photo 23. Temporary structure along the lake shore between Pogradec and Tushemisht (January 2020).

In North Macedonia, theoretically no construction should be allowed within 50m from the lakeshore, however encroachment and artificialization of the coast continues, either informally or through plans envisaged by the local authorities. In Radožda, several concrete platforms have encroached the lakeshore, as illustrated in a previous section of this report. In the zone of the Studenčišča Marsh, a massive concrete promenade has been built, without any previous documentation being submitted to the World Heritage Centre, as requested by paragraph 172 of the Operational Guidelines. Concept proposals for the creation of a tourist marina at the marsh continue to exist and to be discussed at the local level.

The Ohrid GUP zoning envisages ‘recreation’ use for this stretch of the lakeshore. An updated aerial view shows that a number of facilities have already been built along the lakeshore, with negative impacts on the connectivity between the marsh and the shore.

Figure 24. Aerial view of the Studenčišča Marsh and the lakeshore, where several seasonal facilities have already been built, with the subsequent artificialization of the lakeshore in a highly sensitive zone.

Recommendations: ● Proceed with the rationalization of the uses of the lakeshore in all general and detailed plans based on the respect of OUV of the property and avoid further degradation of the ecosystem and landscape integrity of the lakeshore; ● Speed up the process of removal of illegal structures and provide a map of illegal structures and buildings that have been demolished or removed since 2015; ● Ensure that temporary legal structures are dismantled at the end of the tourist season; ● Restore ecologically sensitive sections of the lakeshore that have been degraded such as the Studenčišča Marsh, including removing seasonal tourism facilities and moving those to less sensitive sections.

Studenčišča Marsh marina project Studenčišča Marsh is a sensitive wetland system containing valuable species and performing important ecological functions as fish hatchery, natural flood mitigation system and filter to the lake from coastal activity. It lacks adequate legal protection against high coastal development pressure (e.g. recent construction of a wide, asphalted pedestrian promenade separating marsh from lake; conversion into agricultural land; construction of commercial and beach infrastructure; use as illegal dumpsite for communal solid waste) which has led to habitat destruction, fragmentation and intense human disturbance. It is one of the final, intact and fully functioning examples of a marshland habitat on the lakeshore but its survival is threatened and will depend on the maintenance of its connection to the lake waters. An evaluation study of the natural and socio-economic values of Ohrid Lake and Studenčišča Marsh, including a management and zoning plan, is currently being prepared by IUCN ECARO (Eastern Europe and Central Asia Regional Office) with GEF/UNEP funds. A draft 10-year management plan will be completed by middle of 2020 and will be used as the basis for proclaiming these as protected areas in the last quarter of 2020. MOEPP submitted the draft dossier for designation of the marsh as a Ramsar site in 2018, and proclamation is finally expected in the second half of 2020. National and international designation of Studenčišča should be given the highest priority since, without legal protection and effective management, further degradation of the area is likely to occur. MOEPP is currently considering putting the area under temporary protection until official designation is in place, with support from Ohrid City Council. Since the marsh is already under high anthropogenic pressure, all projects planned in this area should carefully consider its environmental impacts, taking into account that Studenčišča contributes to maintaining the water quality and biodiversity of Ohrid Lake and, therefore, the OUV of the property. A proposal from the early 2000s for construction of a 400- boat marina and associated 1000-vehicle parking facility in Studenčišča is still being considered by the Ohrid Municipality. This would increase human disturbance in the area even more (e.g. noise, traffic, repeated boat waves) as well as lead to the degradation of water quality (e.g. fuel spills, inappropriate waste disposal, sediment resuspension) and possibly facilitate the introduction of alien species. The impacts of the marina’s construction could be even greater if excavation and dredging activities are taken into account. Extensive digging would be required to ensure water depth for such a large marina, resulting in wide- scale habitat loss. Such an impactful project is not in line with the actions needed to preserve this sensitive area and plans to make it into a nationally and internationally designated area. The Mission was informed that the project for a marina at Studenčišča marsh is being considered as a possible way to control the boating activity that occurs in the Studenčišča channel, which might be necessary, but it would be far more appropriate to transfer this activity to a less sensitive, and already developed, section of the coast. However, the decision about where to locate such infrastructure must be informed by unbiased environmental and heritage impact assessments. It is highly recommended that the plans for construction of this marina be cancelled, since this represents a potential danger to the property, according to paragraphs 179 and 180 of the Operational Guidelines. Recommendations: ● Permanently abandon plans for a marina at Studenčišča Marsh and remove from any planning instruments, zoning provisions allowing any form of development, including leisure zones, at Studenčišča Marsh;

● Proceed urgently to designate Studenčišča Marsh as a protected area at the national and at the international level, through Ramsar designation; ● Restore ecologically sensitive sections of the lakeshore that have been degraded such as the Studenčišča Marsh and ensure their connection to the lake, including removing seasonal tourism facilities and moving them to less sensitive sections of the coast.

Construction of the Promenade along Ohrid Lake (Studenčišča channel to Galičica National Park) The area of this project was not visited by the Mission in 2017 nor was the mission team shown the project. The following is an excerpt of the 2017 Mission report: Two projects for reconstruction of the pedestrian path by the Studenčišča channel and the construction of a pedestrian street from the channel to the national park are currently planned. It is unclear if appropriate planning documentation for these two projects have been prepared and approved yet. The information on the exact location and environmental impacts of these projects has not been provided, nor has the mission visited the area. Studenčišča marsh is a sensitive wetland system containing many valuable species and acting as a natural filter for the lake. Considering that Studenčišča marsh is already under severe pressure from nearby urban development, any projects planned in this area should carefully consider environmental and biodiversity impacts before getting approval for implementation. It was therefore with surprise that the 2020 Mission saw the almost completed large promenade built in an area that would supposedly be at the periphery of Ohrid town, and which borders the Studenčišča Marsh along the lakeshore. The Mission considers the promenade out of scale compared to the needs of a peripheral zone of the town and seems to announce further urban development in an ecologically sensitive area. The GUP considers the area between the promenade and the lakeshore for recreational use, whilst the zone of the marshes is earmarked as protected zone, but nothing is known on the area further south, possibly because it is not included in the Ohrid Municipality. The construction of this promenade confirms the trend of urban expansion. The promenade has interrupted the linkages between the marsh and the lake waters which the former needs to survive. It has been built without any known prior assessment of its impacts on the ecosystem of the Studenčišča Marsh and without submitting the project documentation to the World Heritage Centre, despite the 2017 mission warning of potential negative impacts.

Photo 24. Recently built pedestrian promenade separating the Studenčišča Marsh (on the right) from the lake (on the left) which has led to habitat fragmentation and human disturbance.

Recommendations: ● Ensure that solutions to re-establish the connection between the marsh and the lake are found and implemented; ● Ensure that no permanent structures are erected along the beach parallel to the promenade or on the inland side of the promenade, and that temporary ones are strictly regulated in terms of material used, ease of dismantling, shape, size.

Requalification of the Quay Macedonia in Ohrid The 2017 mission had already addressed this issue. At the time, the project was different and envisaged a three-meter enlargement of the quay. The existing concrete structure supporting the promenade and facing the lake is damaged and in need of repair. The current project is a reduced version of the previous one, in that the enlargement resulting from the rehabilitation of the quay would be around 1.3 - 1.5m instead of 3m. This enlargement is justified by the designers as the only way to reinforce the quay without demolishing the old structure, which would be technically more difficult and costlier. The proposal envisages to improve the quality of the foundations of the reinforced concrete poles that are expected to support the whole structure. These poles are currently proposed to be 96cm in diameter (external side). The poles will be stuck in the ground side by side for the entire length of the quay and will be reinforced with steel bars and injected with concrete. The poles will then be connected with a 62cm-high cantilever beam.

The World Heritage Centre requested additional architectural documentation in December 2019 and the Mission requested one additional drawing showing the total measure of the proposed enlargement. Unfortunately, this information was not received by the Mission as the additional drawing provided does not indicate the overall extension. No sample of the finishing material and of the architectural arrangements has been provided.

Figure 25. Additional drawing on the proposed rehabilitation and enlargement of the Quay Macedonia.

The Mission observes that, whilst the structure of the quay needs repairs, the proposed project would continue the trend of artificialization of the lake and further expansion of infrastructures into the lake, which cannot be accepted. The proposed RC pole structure appears excessive for the purpose of simply repairing the quay, unless there is an intention to use this structure to support further cantilevered elements in the future, which cannot be accepted. It is the opinion of the Mission that the repairs should be carried out without any enlargement of the quay into the lake. Recommendations: ● Modify the project for the Quay Macedonia in order to achieve its repair without any enlargement of the quay into the lake; ● Prepare an architectural design with illustration of the finishing, the urban furniture, illumination system and vegetation to be installed in the rehabilitated Quay Macedonia, and submit it to the World Heritage Centre for review by the Advisory Bodies.

Tourism Tax In Albania a Tourism tax exists based on the Law Nr. 9632, on 30.10.2006, On the System of Local Taxes, Amended. The Tax collected by the Municipality of Pogradec is 140. Lek/client in case of a five-star hotel and 70 Lek/client for every other kind of hotel. In North

Macedonia by law the tax is fixed nationally (less than one euro per night) but must be collected by municipalities through hotels. Eighty per cent of this tax remains available for the municipality for tourism promotion activities. Recommendations: ● Dedicate the revenue of the tourism tax to the improvement of the wastewater management systems as a matter of priority.

Large Infrastructure Projects Highway Qafe Thane - Pogradec The construction of the highway along the coast connecting Pogradec with Qafe Thane in Albania has been recently completed. This road has further contributed to the artificialization of the lakeshore. It has radically altered the shoreline landscape and acts as a physical barrier between the lake and its surrounding ecosystems.

Photo 26. Aerial view of the completed ‘panoramic tunnel’ along the highway to Pogradec (source: https://www.turismo.al/2019/07/galleria-panoramica-lin-pogradec/)

Photo 27. View from the lake of the impacts on the landscape by the construction of the ‘panoramic tunnel’.

Despite the highway having been completed, the service road that had been built by dumping rubble into the lake to allow traffic to reach Pogradec has not been removed yet, as it was recommended during the Upstream Process by the Advisory Bodies.

Photo 28. The temporary road built into the lake to keep traffic flowing during construction of the highway tunnel has not been removed yet, after months since completion of works (July 2019–January 2020).

Recommendations: ● Remove the service road built to facilitate traffic during the construction of the highway Qafe Thane - Pogradec and in particular the tunnel near Pogradec; ● Mitigate the negative impacts of the cutting of the falaise to build the tunnel through renaturation and environmental engineering works; ● Mitigate the impact of the highway Qafe Thane - Pogradec by revising the landscaping and the tree species, preferring natural-like clusters of trees instead of lines and native species, excluding conifers and palms;

Railway, European Corridor VIII The Mission visited the location of the railway in Albania, near Lin, and in North Macedonia. Here the coastline is rather steep, and the railway will run high above the lake level. In some locations it is expected that the line will be protected by building tunnels or semi-tunnels. The staff of the North Macedonia railway authorities informed the Mission that the project for the railway line is ready, and that it is designed for a train speed of 100 km/h. The documentation submitted in response to the request for additional information made by the Mission is a report finalized in October 2017, which deals with specifics of different types of railway bed and ballast, railway bridges and overpass. The report presents typical sections for one track in different conditions and terrains but does not show how the railway line will look like in the different sections of its route and in its setting. The documentation that was shown during the meeting with the railway authorities was not transmitted. The Mission notes that no assessment of alternative routes, requested since 2017, has been initiated yet. The meeting of the Transboundary Commission held on 17 January 2020 did not include the item in its agenda. The Albanian Ministry of Foreign Affairs has assured that the two Ministries of Infrastructure are in contact to address the issue; however, no details

have been disclosed. The Mission confirms that the railway line is likely to have disruptive impacts on this stretch of the coast and particularly in Albania, where the terrain is less steep and logistics associated to the railway are likely to be located, being the closest accessible area near the border. The location and construction of the rail link should not compromise the integrity of the ecosystems and landscapes in the north of Lin village up to the border, as this is one of the few unspoiled sections of the whole lakeshore. This means that a different point of connection apart from Lin should be envisaged for the railway corridor between Albania and North Macedonia. Recommendations: ● Develop and submit to the World Heritage Centre, for review by the Advisory Bodies, a comprehensive comparative study of alternative routes for the European Corridor VIII railway including those that do not pass close to the lakeshore, and in particular avoiding one of the last well-preserved stretches of the lakeshore on the Albanian- Macedonia border (including the option identified and proposed by ICOMOS, based on the 2017 mission’s visit to the site, and presented in Annex 5, map 6.5.2.5.). ● Submit to the World Heritage Centre for review by the Advisory Bodies all updated project documentation so far prepared for the railway; ● Submit a detailed map showing the railway line and the roads in the area (existing one from Qafe Thane to Frangovo-Struga and planned route of highway A2 up to the border);

Highway A2, European Corridor VIII The project of highway A2 was the object of a joint ICOMOS/IUCN Advisory mission in December 2019. Specific recommendations have been provided by the IUCN and ICOMOS mission experts on that occasion. The Advisory mission recommends a number of mitigation measures for the already built sections of the highway, as well as for the sections still to be built, if modification of the route cannot be envisaged. However, it also recommends the study of alternative routes further from Ohrid Lake than the presented route for the sections not yet built. The 2020 Mission visited the area where the section of highway A2 will branch off from the already built highway connecting Kicevo-Ohrid (section 1) and the area where the highway will reach Struga (section 2, Trebenište-Struga). No construction was underway yet at the time the Mission took place, but an EIA and HIA were carried out and the project design has been completed. However, the cumulative assessment of impacts on the OUV of the A2 highway and proposed railway that was requested by the 2017 RMM has not been carried out yet. The Public Enterprise of State Roads has informed through a letter sent on 3 March 2020 that “for the construction of the Trebenište-Struga highway section, no funds have been secured yet for the implementation of the Project, nor has the time for construction start been planned yet”. Section 3 of the highway (Struga-Kjafasan) is just at the stage of establishing terms of reference for a call of tenders. The Mission considers that the lack of funds and no precise timeframe for implementation offer an opportunity to modify the project so as to remove, reduce or mitigate as much as possible negative impacts on the OUV of the property, as well as to study the possibility to pair highway A2 and the railway, to reduce the impacts of the two infrastructures on the property. Consideration should also be given to the opportunity to combine in one single corridor all planned transportation and energy infrastructures, at least within the property, in

order to avoid landscape fragmentation and an augmented impact on the property. This requires a strong dialogue between the ministerial branches responsible for the railway corridor and for highway A2, a dialogue which has not occurred yet, and including all other authorities responsible for the energy infrastructure. Recommendations: ● Take advantage of the pending timeframe for implementation of highway A2 and verify the possibilities of combining in one single corridor all planned energy and transportation infrastructure within the North Macedonia side of property, at least in the Struga plains; ● Consider the possibility to combine highway A2 and the railway in one tunnel, if upgrade of the existing road from Qafe Thane to Struga is not possible, to take advantage of the construction of the tunnel and exclude the passage of both road and railway in sensitive areas within the property, thereby removing threats to its OUV; ● Implement the related recommendations of the 2017 RMM and of the World Heritage Committee.

400kV transmission line Bitola – Elbasan The transmission line is mentioned in the draft Management Plan for the Natural and Cultural Heritage of the Ohrid Region and in the Strategic Environmental Impact Assessment report. Information found online (source: https://balkangreenenergynews.com/energoinvest-koncar- to-construct-first-n-macedonia-albania-power-line-new-substation/) reports that North Macedonia’s state-owned electricity transmission system operator (TSO) MEPSO has signed contracts for a new 400 kV line to connect the country with Albania, a new 400/100 kV substation near Ohrid and an extension of Bitola 2 substation. The bids were due by the end of October 2019. The new line will be the first power link between North Macedonia and Albania (Bitola - Elbasan). The project will provide the link in the initiative to establish an East-West electricity transmission corridor between Bulgaria, North Macedonia, Albania, Montenegro and Italy. The project includes the construction of electricity transmission infrastructure from Bitola to the Albanian border, with a substation at Ohrid, and the introduction of Smart Grid components at MEPSO (source: website of the European Bank for Reconstruction and Development, EBRD). The value of the project is 49 million Euros. The funds are secured by loans and grants approved by the EBRD and the Western Balkans Investment Fund (WBIF). The EU is co-financing the project with a 12 million Euros grant. Technical activities were already planned in 2017. The Mission observes that it is highly regrettable that no prior information was provided to the World Heritage Centre before decisions were finalized, and that no consideration has been given at a strategic planning phase - when determining the feasible corridor for this high voltage line - to the potential impact of this line on the property. It is equally regrettable that no consideration has been given to the possibility of combining all planned infrastructures in one single corridor, to reduce the impacts on the environment, the landscape and on the OUV of the property. Ohrid Lake is considered an Important Bird and Biodiversity Area (IBA) due to the natural birdlife of the lake which contributes significantly to its conservation value. The lakeshore reed beds and wetlands provide critical habitat for hundreds of thousands of wintering water birds, including rare and threatened species. Therefore, it is essential that careful mitigation measures are put in place to reduce the risk of bird collision and electrocution. Measures

should also be put in place to reduce as much as possible the potential negative impacts of the project on surface water and groundwater pollution, as well as on land and vegetation clearance, resorting to site restoration where possible. Recommendations: ● Explore possibilities of combining the route of the electricity transmission line with the routes of all other planned infrastructures for the area (gas line and transportation infrastructure) in one single corridor; ● Carry out environmental and heritage impact assessments focusing on the overhead and buried transmission line alternatives before any activities are carried out.

New gas pipeline The Management Plan for the Ohrid Region locates on a map several infrastructure projects, including a new gas pipeline. No precise information has been given to the Mission with regard to this project by North Macedonia, however the report by Analyticamk dated 2008 on “Gas pipelines and Regional Challenges: Assessment of the Macedonian role in the SEE natural gas market” (source: https://www.analyticamk.org/files/ReportNo16.pdf) mentions a gas pipeline connecting North Macedonia (Skopje) with the Albanian border, with connecting branches towards Ohrid, Debar and Struga. The map included in the Management Plan clearly indicates that the corridors for this infrastructure is also different from the corridors of the other infrastructures. Recommendations: ● Explore possibilities of combining the route of the new gas pipeline with the routes of all other planned infrastructures for the area; ● Carry out environmental and heritage impact assessments to determine the details of the project in a way that negative impacts on the OUV of the property and its attributes are reduced.

Free economic zone During the Mission, the team transited between Struga and Ohrid and detected infrastructure building activity. It was explained by the North Macedonia representatives that it was the construction of a ‘free economic zone’. The official name of these zones is Technological Industrial Development Zone (TIDZ). A number of these are distributed throughout the country. Information was requested by the Mission on this specific zone. The Office responsible for the management of these zones (Directorate for Technological Industrial Development Zones) has informed that the Urban Planning documentation for TIDZ Struga was approved by decision of the Ministry of Transport and Communication on 4 November 2011 and that, subsequently, the Environmental Impact Assessment Report for infrastructure projects in TIDZ Struga, was approved by the Ministry of Environment and Physical Planning (MOEPP) in 2012. TIDZ Struga has completed the first phase which includes road infrastructure, hydrotechnical infrastructure, water supply, surface water sewage and drainage to the recipient, sewerage and drainage to the collector, and electrotechnical infrastructure. The construction of the interchange for connection of TIDZ Struga with the national road network is underway.

The letter also informs about the approval of the Urban Planning documentation for Kosel Industrial Zone on 18 January 2016 and that, subsequently, the Environmental Impact Assessment Report for Kozel Industrial Zone was approved on 20 December 2019 by the MOEPP. None of these projects were communicated in advance to the World Heritage Centre, as required by paragraph 172 of the Operational Guidelines. Nor were Environmental and Heritage Impact Assessments carried out according to the IUCN and ICOMOS guidance. Recommendation: ● Submit information and documentation about the project for the free economic zone to the World Heritage Centre for consideration by the Advisory Bodies.

Expansion of the Ohrid airport The Mission found information online about the intention of the current manager of the Ohrid airport, the Turkish society TAV, to expand it and to double its capacity from 300.000 to 600.000 passengers. The mission recommends that updated information on this project be submitted to the World Heritage Centre, as required by paragraph 172 of the Operational Guidelines. Recommendations: ● Submit all updated information on the Ohrid airport expansion to the World Heritage Centre, including any project documentation that might be available; ● Carry out environmental and heritage impact assessments on this expansion before finalizing any decision in its regard and submit the EIA and the HIA report to the World Heritage Centre.

Ring-road for Ohrid city The Mayor of Ohrid mentioned the construction of a ring-road for Ohrid city, which was in the plans of the central government and it is currently frozen due to administrative issues. The Mission observes that no information or documentation has been submitted on this project to the World Heritage Centre, as required by paragraph 172 of the Operational Guidelines. Recommendation: ● Submit all available documentation on the Ohrid ring road to the World Heritage Centre for review by the Advisory Bodies.

Projects for the conservation of cultural heritage monuments and historic urban fabric The archaeological remains of the paleo-Christian church in Lin require regular maintenance, particularly the removal of the invasive vegetation that grows around and above the walls, periodical repair of the caps for protection of the tops of the authentic walls, and the monitoring of the conditions of the mosaics, which are protected by a plastic sheet and a thick layer of sand. The Mission was informed that each year a different section of the mosaics is opened for visitation during the summer season. This also offers the opportunity to verify the conditions of the mosaics and to carry out maintenance interventions. The

Mission recommends that between the plastic sheet and the mosaic a layer of non-woven fabric sheet be interposed for protection purposes. Albanian authorities have informed the Mission that a proposal exists for the restoration of Pogradec Castle as well as for pursuing the rehabilitation of Pogradec historic centre, which however needs further funding. The Mission recommends that any restoration project for Pogradec Castle be transmitted to the World Heritage Centre. No update has been reported for the preparation of the detailed urban plans for 19 complexes of the Old Nucleus of Ohrid, which were expected by 2017. The Mission considers that the plans should be finalised and implemented expeditiously. Update on this subject should be transmitted by the State Party of North Macedonia. A visit to St. Sophia Church in Ohrid, suggested during the meeting with civil society, revealed that the Narthex of the Church is used as a deposit. The Mission recommends that the material deposited in the narthex be removed and relocated in other more suitable spaces. In this way, the narthex, which is covered with mural paintings can be made accessible to visitors. It is also suggested that the conditions of these paintings be verified by specialised restorers and steps for their conservation be undertaken, if and where necessary.

Photo 29. The ground level of the narthex with Photo 30. First floor of the narthex with chairs material accumulated along its walls. piled up in one monumental space.

Recommendations: ● Provide updated information on the detailed urban plans for the 19 complexes of the Old Nucleus of Ohrid and their stage of implementation; ● Remove the material deposited in the narthex of St. Sophia Church and make it accessible to the public; ● Monitor the state of conservation of the narthex and of its mural paintings by certified restorers and assess the priorities for intervention.

Projects for the conservation of natural heritage A 2012-2020 project entitled “Conservation and Sustainable Use of Biodiversity at Lakes Prespa, Ohrid and Shkodra/Skadar” is currently being implemented by the German Corporation for International Cooperation (GIZ) in Albania, North Macedonia and Montenegro. The project is funded by the German Federal Ministry of Economic Cooperation and Development and its main objective is that the lakes’ natural resources are managed on a transboundary basis and in compliance with EU environmental and biodiversity protection targets. It has produced publications on “Fish and Fisheries” (November 2017) and a “Monitoring Manual for Lake-bound Species and Habitats of Lakes Prespa, Ohrid and Shkodra/Skadar” (May 2019). In Galičica National Park there are also several projects currently being planned such as: a biodiversity monitoring programme (to be included in the new management plan), an ecosystem services study, a red deer (Cervus elaphus) reintroduction project, and an agreement with a local mountaineering club to develop joint activities. For the 5th consecutive year, RAPA and civil society in Albania participated in the 2020 International Waterbird Census organized by Wetlands International. In January 2020, 11.000 birds (26 species) wintering at Ohrid Lake were counted, with the largest presence being of Common coot (Fulica atra), Black-headed gull (Chroicocephalus ridibundus), Tufted duck (Aythya fuligula) and Little grebe (Tachybaptus ruficollis). Results showed a smaller number of wintering birds compared to previous editions, probably as a consequence of the mild and dry winter. The counting was conducted simultaneously in the Albanian and North Macedonia parts of the lake. Recommendations: ● Develop environmental awareness and education programmes in close collaboration with local citizens’ groups, targeting especially children and visitors during the summer season ● Ensure that reintroduction of red deer in Galičica National Park is only carried out according to expert opinion, and the most recent scientific data and best practices available.

6. ASSESSMENT OF THE STATE OF CONSERVATION OF THE PROPERTY

Current state of conservation of the property and trends

The Mission found that the conclusions of the 2017 RMM still hold valid after three years, due to the slow or insufficient progress made in implementing the recommendations of previous World Heritage Committee decisions and RMMs. The natural values of the property consist of Ohrid Lake being a unique lake of tectonic origin supporting high diversity of endemic and relict freshwater species of flora and fauna. It is also an important wintering site of Palaearctic waterbirds. Moreover, it exhibits other important biodiversity values in richness of fauna species including endemism, diversity of habitats, and rare and endemic flora, mainly present in Galičica National Park. Several factors are affecting Ohrid Lake and its unique biodiversity. Water pollution is the most significant nature conservation issue affecting the property due to inadequate, and sometimes absent, wastewater and solid waste collection and management, as well as

uncontrolled agricultural discharges. This is expected to worsen with the current trend of growing tourist numbers and tourism infrastructure development along the lakeshore. Ohrid Lake is still in an oligotrophic state but eutrophication is in progress, being most evident near the rivers’ mouths of Sateska, Koselska, Velgoška and Čerava in the North Macedonia part of the lake. These are also the areas where reduced species diversity of macrophyte vegetation and macroinvertebrate fauna was detected, even though endemic benthic macroinvertebrates seem to be in a stable condition (Lorenschat et al. 2014, Trajanovski 2016, GIZ 2016). Stocks of the endemic Ohrid trout (Salmo letnica) have been consistently decreasing over the last decades despite annual repopulation efforts (Jordanova et al. 2016), mainly due to overfishing and lack of enforcement of fisheries regulations. However, consistent species population data is lacking, making a more thorough assessment of the situation challenging. A positive correlation between water quality disturbance and the presence of invasive species, especially in lake tributaries, was also established (Trajanovski 2019). Invasive species are considered one of the reasons for some native species being endangered, with fish farms in the Albanian part of the lake, which breed exotic species contributing to invasive species introduction as well as to water pollution. Hydrology of the lake has been affected by uncontrolled discharges of lake water into Crn Drim River in the North Macedonia part of the lake as well as by climate change, with prolonged dry periods without heavy rains, decreasing the water level. Sedimentation is evident near the Sateska River mouth, ultimately altering flora and fauna composition in this part of the lake. In the long-term, this can pose serious threats to the entire ecosystem but steps have been undertaken for returning the Sateska to its old riverbed, which, if implemented, should reduce sedimentation and discharges of lake water. Furthermore, unmanaged, contaminated areas from former mining activity in Albania (e.g. iron, nickel, chromium) is already leading to highly toxic pollution and will further impact the whole region if left unchecked. Heavy metal contamination in the Memëlisht dumpsite, with toxic levels of nickel, chromium, cobalt and lead, is threatening local fauna and flora, as well as human health (Bolles + Wilson & IDRA & S. Guri 2015). Dumpsite removal has been initiated but there are other areas that need urgent closure and remediation. Waterbirds are especially abundant in parts of the lake where reed beds are still present. In the winter of 1989, as much as 79.000 waterbirds were recorded on the lake in North Macedonia, while in 2010 and 2011 only 10.000 and 17.000 individuals were counted, respectively (Wetlands International 2006, Velevski et al. 2010). With growing tourism, alteration of the lakeshore (destruction of reeds and marshes), ongoing eutrophication and poaching, waterbird populations seem to be in decline. The status of species in Galičica National Park appears to be stable, although timber extraction, modifications in land use and tourism pressures, including illegal construction, are changing the landscape thus impacting species habitat. No visitor management plan for the park is in place but a new Management Plan for Galičica is currently being drafted, offering the opportunity to strengthen protection and tourism management measures. In terms of cultural values, in North Macedonia, the historic urban fabric in Ohrid reflects numerous interventions on traditional buildings, infills of empty plots or the substitution of dilapidated old buildings by new ones carried out without the necessary design and implementation skills. Many recent buildings are rehabilitated, reconstructed or constructed using inappropriate building techniques and unsympathetic building materials, such as structures in reinforced concrete, walls in hollow bricks and wooden planks applied to hide concrete beams. The traditional horizontal and vertical wooden supporting structures are

often mimicked by simply painting in dark brown the corners and the inter-floor lintels, the upper lintels are often much thicker than the traditional ones, due to change in building techniques (concrete slabs instead of wooden structures), and the proportion of windows and doors are also different from traditional ones. This type of intervention has already begun to impact on the integrity and authenticity of the property and if it continues, may lead to the diminution of the authenticity and integrity of the traditional historic fabric of the old town and its harmonious relationships with the monumental complexes. Along the lakeshore in the historic town, restaurants and bars encroach upon the lake and removal of these structures has only slowly begun.

Photo 31. View over the cityscape from St. Sophia church premises revealing the progressive alteration and degradation of the cityscape through alien materials and architectural forms.

Photo 32. The abundance of technical installations on the roofs reduce the visual harmony of the cityscape.

Photos 33, 34, 35, 36. Examples of complete alteration of the construction concept, forms and elements in the old town of Ohrid compared to the example in photo 35 depicting a building still exhibiting traditional structural conceptions and materials.

Photos 37 and 38. One example of a traditional house which has suffered a heavy partial reconstruction intervention and one example of a dilapidated traditional building.

In Albania, the terrestrial part of the property includes Lin village, with its peninsula and the remains of an early Christian church, which represents one of the last well-preserved stretches of the Ohrid Lake coast, despite some cases of negatively-impacting buildings, and the Drilon Springs, which are among the most important systems of springs feeding the lake. The construction of tall buildings close to the water; the poor architectural quality of the built

environment especially in the main towns, Ohrid and Struga in North Macedonia, and Pogradec in Albania (part of the buffer zone), but also along the coast outside urban centres; and the inappropriate and excessive use of the coast for tourism exploitation all have a negative impact on the property, and undermine the possibility to appreciate “the convergence of well-conserved natural values with the quality and diversity of its cultural, material and spiritual heritage [which] makes this region truly unique”. These developments and activities not only have occurred in the past, but they have been ongoing, legally and informally, along coastal stretches, thus making the property highly vulnerable, and are also envisaged in planning provisions and in progressing project proposals. These threats worsen an already vulnerable situation due to considerable accumulated transformations that have occurred since the inscription of the property in North Macedonia and over the last three decades in Albania. Increased urbanization and infrastructure development along the coast have progressively interfered with natural resources, causing higher water and timber consumption, increased pollution from untreated wastewater and solid waste, and fragmentation and destruction of native habitats. Existing proposals for large infrastructure and construction projects that could lead to irreversible transformations of the overall relationship between the historic settlements, archaeological remains, natural values and setting had already been identified in the 2017 RMM. Some of the threats to the property have been removed since 2017, notably the plans for the Galičica Ski Centre, the A3 road (sub-sections (a) and (e)) and the tourism development at Ljubaništa 3. However, other known potential threats according to paragraph 179 and 180 of the Operational Guidelines for implementation of the World Heritage Convention still impend over the property. In summary, since the inscription of the property in North Macedonia over the last three decades and in Albania since 2019, above-mentioned inappropriate interventions have created a highly vulnerable situation due to considerable accumulated transformations; ongoing and planned modifications and developments are exacerbating this already vulnerable situation towards a point of no-return. Increased urbanization and infrastructure development along the coast have progressively interfered with natural resources, causing higher water and timber consumption, increased pollution from untreated wastewater and solid waste, and fragmentation and destruction of native habitats. Based on the findings gathered during the visit to the property, the Mission considers that the property is facing both actual threats - namely deterioration of architectural and town-planning coherence; of urban or rural space, and of the natural environment; of the natural beauty and scientific value of the property by pollution and mining – and potential danger – namely lack of adequate implementation of protection and conservation policies; threatening effects of town planning and large scale development and infrastructure projects; planned development projects within the property; the management system is lacking and not fully implemented - according to paragraphs 179 and 180 of the Operational Guidelines for implementation of the World Heritage Convention (OG).

Progress made in addressing the threats and in responding to previous Reactive Monitoring missions’ recommendations and World Heritage Committee decisions

Given the complexity of the issues and threats affecting the property, as well as the large number of previous RMMs’ recommendations and World Heritage Committee decisions, the Mission decided to prepare a detailed analysis of the progress made by the States Parties in addressing these to facilitate review.

During the Mission and based on the examination of the 2020 State of Conservation reports prepared by the States Parties, their annexes and additional information provided, it emerges that only a few of the recommendations have been addressed satisfactorily. However, most of the other recommendations have been addressed only partially or insufficiently and some have not been acted upon.

The three recommendations listed below have been implemented: ● Cooperate towards a transboundary extension of the property to include the Albanian part of Lake Ohrid and its watershed (32 COM 8B.49, 2008) This extension has been proactively supported by the Upstream Process guided by the World Heritage Centre, with the contribution of the Advisory Bodies, and largely funded by the European Union.

● Halt the construction projects of the sub-sections (a) and (e) of the A3 road and the Galičica ski resort within the property (41 COM 7B.34, 2017) These projects were reported as cancelled in the 2019 State of Conservation report, however, this action was not found sufficient by the World Heritage Committee to reduce the vulnerabilities of the property. ● Finalise the Management Plan for the property (North Macedonia) (43 COM 7B.36, 2019) The recommendations for the finalization of the Management Plan can be traced back to 2014. The 2020 State of Conservation report informs that the drafting of the Management Plan was resumed in 2018-2019 and a copy of the draft was transmitted in October 2019 to the World Heritage Centre for comments by the Advisory Bodies. A Strategic Environmental Impact Assessment and Heritage Impact Assessment were carried out in parallel. Working meetings were carried out with representatives of the municipalities of Ohrid, Struga and Debrca, and with relevant institutions in the field of protection of cultural and natural heritage in the region. Public debates were held in Skopje, Ohrid and Struga. The draft management plan was revised and updated taking into account the technical advice by ICOMOS and IUCN and was positively considered by the Commission for Managing the World Cultural and Natural Heritage of the Ohrid Region and by the National Commission for UNESCO in early January 2020. However, the SIA report identifies a number of conflicting projects and inadequate zoning that the Management Plan should take into consideration and revise accordingly. The Management Plan has been revised according to the technical advice provided by ICOMOS and IUCN and the version transmitted in April 2020

(Management Plan for the natural and Cultural Heritage of the Ohrid Region 2020 – 2029) has been considerably improved. At the time of the mission, the Management Plan was about to be approved; however it has not yet deployed its effects on the other planning instruments and projects in place or planned in the Ohrid region. The modifications of other planning documents following the approval of the MP 2020 – 2029 remains urgent to remove threats to the OUV of the property.

The recommendations that have been partially implemented include the following:

● Fully implement the Management Plan (Albania) (43 COM 8B.9, 2019) The Management Plan for PPL was approved in December 2014. The World Heritage Supplement to the Management Plan is approved but remains to be clarified if all named stakeholders have officially endorsed it. However, the Management Committee for the Protected Landscape has not yet been created and therefore has never met. The draft by-law for its creation is in process of consultation and is expected to be finalized by March 2020.

● Approve and operationalise the Municipal Development Plan (Albania) (43 COM 8B.9, 2019) The GLP for Pogradec Municipality has been prepared throughout 2016 and completed the consultation process in line ministries as well as public consultations. However, it has not been approved by the Municipal Council of Pogradec and the National Council of Territory yet. It also includes provisions that the Mission considers are not in line with the protection of the OUV of the property and its attributes, and should therefore be altered, such as zones for redevelopment along the lakeshore of Lin and its peninsula, as well as in other rural areas along the lakeshore.

● Increase human and financial resources to support the management of the property (43 COM 8B.9, 2019) In October 2019, the State Party of the Republic of Albania informed the World Heritage Centre regarding the appointment of the site managers responsible for the cultural and natural components of the property. The natural component of the property and buffer zone is under direct responsibility of the Regional Administration of Protected Areas (RAPA), Korçë. Its staff consists of one specialist responsible for natural resource management and biodiversity conservation. The cultural component of the property and buffer zone is under direct responsibility of the Regional Directorate of Cultural Heritage (RDCH), Korçë. Its staff consists of two persons, one specialist and one technical personnel. However, the Mission considers that the RAPA and the RDCH staff dedicated to Pogradec should still be increased (one more person for each institution) given the many threats impacting on the property, as well as the many conservation and monitoring actions that urgently need implementation.

● Introduce a monitoring regime for cultural assets; prepare an inventory of the cultural sites in the buffer zone and introduce a conservation approach for these and the buffer zone landscape (Albania) (43 COM 8B.9, 2019) This recommendation was specifically addressed to the State Party of Albania at the moment the extension of the property was approved. The State Party has provided 13 inventory fiches concerning formally protected monuments. Monitoring at these sites has been carried out in December 2019 and January 2020. The Mission considers that a plan for inventorying further objects and sites exhibiting cultural significance should be developed in order to steadily and systematically improve the knowledge of the heritage resources in the region, so as to shed further light on the historical cultural development of the area. Such an inventory exercise should also include archaeological sites. The Mission recommends improving the form for the monitoring of the cultural monuments and sites in order to gather more information on the state of conservation and trends that could serve as a basis for prioritising interventions.

● Strengthen protection at Lin church and appoint designated personnel for the management of Lin church, Lin village and Lin peninsula (43 COM 8B.9, 2019) The Lin Church is covered by legal protection which extends to its setting. The State Party has appointed a dedicated staff member of the RDCH Korce, Department of Pogradec to monitor the church and open it to visitors. This Department reports to the RDCH who oversees monument protection for Pogradec Municipality, which also includes Lin village and its peninsula, being part of the municipal territory of Pogradec. However, the management of the village and of the peninsula is a joint responsibility for Pogradec Municipality, RDCH and RAPA. Therefore, there is a need for the municipality to appoint a responsible person on its behalf that is responsible for implementing the competences and tasks of the municipality.

● Reduce motorised traffic in Ohrid old town (RMM 2017) The traffic in Ohrid Old Town is regulated via controlled access at three different locations which can be opened via electronic key card. Access is reserved to inhabitants only, although it has not been understood by the Mission if this access is limited to residents of the historic town or is extended to Ohrid residents in general. A study for a transport plan was presented to the Mission by a consultant: the municipality envisages to develop an electric transport system to get visitors from and to their hotels, although the time frame is not yet known, and to close the road running parallel to Quay Macedonia to car traffic.

● Explore options to re-divert the Sateska river back into the Crn Drim river (RMM 2017) The Mission recognizes the efforts being deployed to implement this recommendation. Steps have been undertaken for returning the Sateska to its old riverbed. A UNDP study has been completed and funds from the EU’s IPA Programme have been secured to implement the first phase until May 2020. A regional project financed by the Adaptation Fund will also be used to complete the structures needed to redirect most of the water flow by the end of 2023. The only point lacking is implementation.

● Continue to remove illegal buildings along the lakeshore and re-align part of the road away from the lake (Albania) (43 COM 8B.9, 2019) Some illegal buildings were removed in 2015 along the coast of the lake, in relation to the development of the new highway Qafe Tane – Pogradec, however progress in this regard

remains slow. The State Party of Albania provided a table listing the number of illegal/informal buildings in Pogradec Municipality and in the former communes of Buçimas and Udenisht, based on the number of requests for legalisation received: they are 1378 in Pogradec, 1528 in Buçimas and 646 in Udenisht. A full inventory, including the type and size of illegal/informal constructions, their possible impacts on the OUV of the property (taking into consideration also the existence and adequacy of the sewerage) has to be developed. The re-alignment of the road connecting Tushemist with Pogradec is included in the AADF project at Drilon spring and it is expected to be implemented with that project. The Mission recalls that the Tushemisht/Drilon project includes previsions that will have a highly negative impact on the property, these cannot be accepted in exchange of funding a diversion of the road.

The recommendations that have insufficiently progressed include the following: ● Strengthen the transboundary cooperation (RMM) The Upstream Process and the EU funded project “Towards a strengthened shared governance of the Ohrid Region” have supported the reinforcement of the transnational cooperation. However, after the end of the project, the only documented meeting of the Transboundary Committee has been held on 17 January 2020. Key transboundary issues, such as the EU Pan-European transportation corridor VIII, were not in the agenda. Draft rules of procedure, largely repeating provisions already included in the transboundary agreement signed in 2004, have been prepared but have not been endorsed yet. This offers opportunities for their improvement. While recognizing the recent efforts being deployed, the Mission considers that progress on this matter is far too slow for the urgency of the current situation of the property and transboundary proactive response that is needed. Furthermore, the level of the membership of the Transboundary Committee is not sufficiently high in terms of decision-making power to guarantee the effective functionality of this body. This consideration applies also to the members of the Secretariat.

infrastructures, in order to avoid landscape fragmentation and an augmented impact on the property. This requires a strong dialogue between the different ministerial branches responsible for the railway, for highway A2, and for energy infrastructure, a dialogue which has not occurred yet.

● Put in place a moratorium on any coastal and urban transformation within the property (North Macedonia) (RMM 2017; 43 COM 7B.36, 2019) The moratorium, requested by the World Heritage Committee since 2017, was established in August 2019 and was to expire in February 2020. This delay postponed the halt to the issuance of building permits, thereby increasing potential threats deriving from building activity that, despite their legality, may nevertheless have negative impacts on the OUV of the property. Several exceptions are included in the municipal decisions so a large number of constructions can proceed, thereby frustrating the aim of the World Heritage Committee’s request. The Mission observes that the municipal decisions of Ohrid, Struga and Debrca cannot be considered as an adequate response to the recommendations of the World Heritage Committee and of the 2017 RMM. Additionally, there is the need to reinstate the moratorium for any type of new construction, much more general that the first issued in August 2019.

● Inventory illegal constructions, assessing their impacts on the OUV of the property, and proceed to demolishing all those which represent a threat to the property (North Macedonia) (43 COM 7B.36, 2019) The Ministry of Transport and Communications of North Macedonia, in cooperation with the municipalities and Galičica National Park, has prepared an inventory of the illegal constructions erected within the property in the form of a list. If not yet done, it is essential that the illegal buildings are mapped on the technical maps of the master plans/ land use plans and/ or- of the cadastre. A large number of illegal constructions has already been legalised (some 9.000 out of 20.000) however, it is not clear if any assessment of their impact on the OUV has been carried out nor whether the Ministry of Culture has expressed its opinion on the legalisation requests. In case the Ministry expressed its opinion, it would be important to learn on how many cases and in what cases their opinion has been followed. The Mission considers that these points must be clarified by the State Party of North Macedonia. The State Party of Albania has informed that some buildings were demolished in 2016-2019; in Albania no inventory of illegal buildings was requested, therefore it would be important that a similar exercise as the one asked to North Macedonia be carried out.

● Improve the central wastewater treatment system for all settlements in the Lake Ohrid basin (RMM 2017; 43 COM 8B.9, 2019) Several projects to connect the rural areas to the Pogradec main wastewater management system, or to establish smaller systems in areas where connection is not possible, are currently being developed but lack financial support for implementation. Additionally, there are concerns for the future sustainability of the Pogradec Wastewater Treatment Plant since the KfW funding used for its construction terminated in 2018. It is imperative that sufficient financial resources are allocated for the efficient running of this plant. A first phase of rehabilitation works to improve the wastewater management system in Ohrid and Struga have been initiated, but funding needs to be secured for implementation of all

necessary measures, including reconstructing the Vranishta Wastewater Treatment Plant and extending the system to the whole region.

● Close and clean up the Bukovo landfill and all illegal waste dumping sites within the property, and establish a functional communal waste collection system (RMM 2017) In North Macedonia, a Regional Plan for Waste Management, including a feasibility study for closure and remediation of non-compliant landfills and dumping sites, has been completed. A draft costing study is also in development. However, funding still needs to be secured for implementation. Irregular landfills such as Bukovo, Maucker and Struga in North Macedonia, as well as Alarup in Albania, have not yet been closed and cleaned up.

● Take all necessary measures to control invasive species in Lake Ohrid and ensure the regular implementation of a biodiversity monitoring programme (RMM 2017) Local authorities in Albania undertake periodic monitoring of aquaculture activities and give warnings for voluntary dismantling and rehabilitation of illegal fish farms. A few subjects have abandoned the activity but several were still active at the time of the mission visit. Some fish farms were also dismantled during the removal of illegal constructions along the lakeshore in 2017-2018. However, biodiversity monitoring programmes for Ohrid Lake, including monitoring of invasive species, are still lacking in both countries.

● Undertake a thorough assessment in view of defining and establishing a buffer zone for the property, which should ideally include Prespa Lake as well as the remaining part of Galičica National Park (RMM 2017) The Management Plan for the North Macedonia side of the property, and its associated SIA, assess three alternatives for a possible buffer zone: buffer zone border identical to the border of Ohrid-Prespa Transboundary Biosphere Reserve; buffer zone smaller than the Biosphere Reserve, but including Prespa Lake; and a smaller buffer zone, not including Prespa Lake, but including the rest of Galičica National Park. During the Mission, local and national authorities in both countries stated that the current priorities are to fully implement the management plans and to consolidate protection of the existing property, and then think about creating/expanding the buffer zone.

● Increase community participation (43 COM 8B.9, 2019) Only limited progress has been made in addressing this recommendation but full implementation is still lacking. During the drafting of the Management Plan for the Ohrid Region and of the GLP for Pogradec, public consultations were held. Civil society from North Macedonia also attended the transboundary management meeting held in Ohrid in January 2020. However, the Management Committee meetings of the PPL are closed to the public. To allow for full stakeholder involvement, these meetings should be open once the Committee starts functioning. The mission was informed by civil society representatives in Albania that the World Heritage Committee decision was not made accessible to civil society and the general public. The World Heritage Supplement to the Management Plan for the PPL

is approved by Order of the Minister of Environment and is both available in Albanian and in English. Some civil society representatives from North Macedonia met by the Mission raised the issue of the public not having access to official information regarding the management of the property and planned development projects.

● Improve collection facilities at Pogradec museum and the conservation of waterlogged material from the pile dwelling sites (Albania) (43 COM 8B.9, 2019) The Museum is a municipal institution, which is funded by Pogradec Municipality. Information was provided about a plan for relocating the museum to a different building, along the lakeshore, owned by the Ministry of Defence. The Ministry of Culture will support the improvement of the collection facilities either in the new facility or in the current one. However, no clear progress was reported on immediate improvement of the conditions of the collection or on the conservation of waterlogged material.

● Finalize the detailed urban plans for each of the 19 complexes which are part of the monumental ensemble in Ohrid (North Macedonia) (40 COM 7B.68, 2016) No updated information on the advancement in the implementation of these plans has been presented to the Mission.

On the other hand, other key recommendations have not been acted upon: ● Prepare an overall Strategic Environmental Assessment (SEA) and Heritage Impact Assessment (HIA) that assess comprehensively the potential cumulative impacts of all proposed infrastructure plans and other major projects on the property’s OUV (North Macedonia) (40 COM 8B.68, 2016; 41 COM 7B.34, 2017) The Strategic Impact Assessment on the Management Plan for the Cultural and Natural Heritage of the Ohrid Region cannot be considered as replacing the SEA requested by the World Heritage Committee to assess the cumulative impacts of all plans and projects on the property.

● Undertake a comprehensive comparative study of alternative routes for the railway of the Pan European Corridor VIII, including those that do not pass in close vicinity of the lakeshore, and in particular avoiding one of the last well-preserved stretches of the lakeshore on the Albanian-Macedonian border (41 COM 7B.34, 2017; 43 COM 8B.9, 2019) This recommendation, which dates back to 2013 and was reinforced in 2017, has not yet been addressed by the States Parties. The Mission received only a general update about the beginning of dialogue in this regard. The Albanian Ministry of Foreign Affairs has assured that the two Ministries of Infrastructure are in contact to address the issue, but no details have been disclosed. However, the topic was not included in the agenda of the Transboundary Committee meeting held in January 2020.

● Strengthen transboundary cooperation on monitoring the lake’s biodiversity and water quality, and establish common management actions such as jointly agreed fishing quota (RMM 2017) This recommendation, dated 2017, has not yet been addressed by the States Parties. The Mission did not receive any information regarding progress to establish a common biodiversity and water quality monitoring programme or common management actions such as jointly agreed fishing quotas. These issues were also not covered during the Transboundary Committee meeting held in January 2020.

Notwithstanding some positive actions, the Mission found that actual threats already acknowledged by the World Heritage Committee in Decisions 43 COM 7B.36, 41 COM 7B.34 and 40 COM 7B.68 still persist within the property and new ones have emerged during the 2020 RMM.

7. CONCLUSIONS AND RECOMMENDATIONS The Mission noted the remarkable efforts deployed by the States Parties, and particularly by the Ministry of Tourism and Environment and the Ministry of Culture in Albania and by the Ministry of Environment and Physical Planning and the Ministry of Culture in North Macedonia, and their subordinated institutions, to address the World Heritage Committee decisions and missions’ recommendations. Nevertheless, the Mission found that the property continues to suffer from an accumulation of negative changes and uncoordinated developments occurring throughout the decades which have not been adequately addressed and have led the property’s integrity and authenticity to become vulnerable. The property is currently impacted by a number of factors, which represent actual and potential danger to its OUV in accordance with paragraphs 179 and 180 of the Operational Guidelines.

Progress has been achieved with the finalisation of the Management Plan for the property in North Macedonia; however, further improvements and modifications to this Plan are necessary, particularly regarding zoning, based on the findings of the SEA report and of the Advisory Bodies’ recommendations. Likewise, the Management Plan for the Pogradec Protected Landscape (PPL) in Albania was approved in 2014, however its Management Committee was not created, nor was the enlarged Management Committee envisaged by the World Heritage Supplement to the Management Plan. The Mission recognizes the considerable efforts being deployed to return the Sateska River to its old riverbed. A study has been completed and funding secured for its implementation, which should start soon.

A transboundary coordinated management structure has been constituted - based on the Transboundary Agreement signed in 2004, which established a Watershed Committee - with one meeting held in January 2020. The Agreement remains a forward–looking document for international cooperation. While recognising the recent efforts being deployed by both States Parties on this matter, it is apparent that the proposed implementation is progressing slowly and, in the Mission’s view, is not adequate to address the urgency and gravity of the current situation of the property, which requires rapid, proactive and high-level response. The Mission also found that the membership level of the Transboundary Committee is not sufficiently high, in terms of decision-making powers and in relation to its mandate as envisaged in the 2004 Agreement, to guarantee its effectiveness. The Secretariat of the Committee appears not adequately resourced to respond to the wide mandate envisaged by the 2004 Agreement. The draft Rules of Procedures would need to be further detailed to provide adequate guidance to the operationalisation of the Transboundary Committee. The inventory of the illegal constructions in the property is also a step forward, however the demolition of illegal buildings is proceeding far too slowly, especially in North Macedonia. At the time of the Mission only a few structures had been partially demolished.

of Lin. The presence in Tushemisht of several springs would suggest extending the monument of nature designation of Drilon to also include these springs or, at least given the intermingling with human use and presence, designating Tushemisht and its spring system as cultural landscape as per the above-mentioned law.

In North Macedonia, national and international designation of the Studenčišča Marsh as a protected area has become urgent since, without legal protection, further degradation of the area is likely to occur, however plans in this direction proceed very slowly. This is one of the last, intact and fully functioning examples of a marshland habitat on the lakeshore, but its survival is threatened by high coastal development pressure. Furthermore, Ohrid Lake’s hydrology and biodiversity are exposed to serious impacts and threats to the entire lake ecosystem. Despite projects to improve and enlarge the wastewater management systems, shut down irregular landfills, and establish communal waste collection systems being proposed or initiated by both States Parties, these still lack funding for complete implementation, and thus the Mission considers that more should have been done to address such priority recommendations. The recommendation to control invasive species in the lake has been partially addressed, with local authorities in Albania having dismantled some fish farms during the removal of illegal constructions along the lakeshore in 2017-2018, but many others are still active today. The recommendation to strengthen transboundary cooperation on monitoring biodiversity and water quality, and establish common management actions such as jointly agreed fishing quota has not been addressed by the States Parties. This is especially worrying given the impacts of overfishing and evident eutrophication in certain parts of the lake, which should be monitored and controlled. The Mission is concerned that this situation will worsen with the current trend of growing tourist numbers and infrastructure development along the lakeshore. Hence, progress in implementing World Heritage Committee decisions remains too slow and weak due to the insufficient shared understanding of the values of the property by all actors, conflicting visions and priorities for the area among different branches of national institutions and agencies and local administrations, insufficient communication and coordination among central administrations, their regional branches and local administrations, and little involvement of civil society. This has resulted in large scale development and infrastructure projects, often funded or supported by international donors, without adequate evaluation of their impacts on the OUV of the property; in inappropriate planning provisions which cause threats and potential dangers for the property; and in excessive and gradual developments further exacerbated by unregulated constructions and activities. Steps undertaken to strengthen the transboundary management framework are to be encouraged yet remain insufficient: major, strategic and more proactive efforts in transboundary cooperation between Albanian and North Macedonia authorities remain crucial for ensuring appropriate integrative conservation measures not only for the protection of Ohrid Lake, but also for the wider region including Lake Prespa. There are a number of transboundary agreements, strategic plans, bodies, and designations that the property benefits from, the success of which depend on the commitment and the implementation of concrete monitoring and management actions by the two States Parties for the protection of the Ohrid Lake region. The Mission therefore concludes that the actions requested since 2017 have not been completed to address the vulnerabilities and threats then

identified, with the result that the gradual erosion of attributes has not been halted, threatening projects and plans are still evolving, and further new threats have been brought to the attention of the Mission. It is therefore evident that the property is highly vulnerable due to significant management issues and poor implementation of the legal framework. These have led to inappropriate interventions, negative effects of town planning, and large scale project proposals, all of which have resulted in severe deterioration of its urban, rural and natural landscapes, and the key attributes of its OUV, thus causing the property to meet the conditions for inscription on the List of World Heritage in Danger. On the basis of the information gathered and discussions during several meetings with national and local authorities, as well as of the analysis of the state of conservation of the property and the additional documentation made available by the States Parties, the Mission has proposed several recommendations to address the actual threats which have negatively impacted the property’s OUV and the potential threats that could increase those impacts. These recommendations are presented in the relevant sections of this report and are summarised below. They have been articulated by area of action and prioritised according to immediate, short- and mid-term timeframes.

Recommendations Timeframe 1. Recommendations concerning potential threats according to paragraphs 179 and 180 of the Operational Guidelines: 1.a Permanently abandon plans for a marina at Studenčišča Marsh and remove from any planning instruments, zoning provisions allowing Immediate development, including leisure zones, at Studenčišča Marsh; 1.b Permanently abandon plans for building developments along the Lin lakeshore and on top of Lin Peninsula, including the completion of a church building near the archaeological remains of the early Christian church, as well as between Pogradec town and Tushemisht. This implies to: Immediate i. Remove from the Pogradec General Local Plan the development zoning areas along the Lin lakeshore and on the top of the Lin Peninsula (PG/HU63 and PG/HU70); ii. Remove from the Pogradec General Local Plan the development zoning area between Pogradec and Tushemisht (PG/BU111). 1.c Permanently remove from the tourism development project at Drilon springs all provisions for fish farming, building options in the agricultural plains along the springs, construction of the Lake Museum or any other building on top of the hill, and significantly Immediate reduce the areas eligible for building development, by excluding construction in the plain near the water course linking Tushemisht and Drilon spring main water body, explore options to relocate part of the proposed development in the hinterland of Tushemisht or in Gurras, where development already occurred; 1.d Modify the project to repair Quay Macedonia without any further enlargement of the quay into the lake; Immediate 1.e Halt all approval procedures and implementation of Ljubaništa 1 and 2 tourism development projects, and transmit the project documentation to the World Heritage Centre for examination by the Immediate Advisory Bodies, including details of the planned wastewater

management system and updated visual documentation of the areas16; 1.f Urgently undertake a joint comprehensive comparative study of alternative routes for the railway of Pan European Corridor VIII, Immediate including those that do not pass in close vicinity to the lakeshore, and in particular avoiding one of the last well-preserved stretches of the lakeshore on the border of Albania and North Macedonia, and taking into account the alternative suggested by the 2017 Reactive Monitoring mission; 1.g Reinstate as a matter of urgency the construction moratorium which is expected to expire in 2020 and revise the Ohrid, Struga and Debrca municipal decisions on the construction moratorium to significantly Immediate reduce its exceptions, limiting authorised interventions to ordinary maintenance but excluding from the moratorium the installations of transmission lines up to 35kV and substations up to 10kV, fire protection installations, local water supply and upgrade of the existing sewerage treatment system. 1.h Take advantage of the uncertainty regarding fund availability and the consequent pending implementation timeframe of highway A2 and: i. verify the possibilities of combining all planned energy (electricity transmission line and gas pipeline) and transportation infrastructure within the North Macedonia side Immediate of the property in one single corridor in the Struga plain, in order to avoid the fragmentation of the landscape in the plain, which contributes to the integrity and understanding of the OUV of the property; ii. explore the possibility to combine highway A2 and the railway in one tunnel, if upgrade of the existing road from Qafe Thane to Struga is not possible, to take advantage of the construction of the tunnel.

3. Recommendations for the remediation of already implemented and negatively-impacting activities / interventions: 2.a Ensure the closure of fish farms and rehabilitation of affected areas Immediate in all water bodies connected with the lake, especially in the Drilon and Tushemisht springs; 2.b Close all irregular landfills such as Bukovo, Maucker, Struga and Three years Alarup, as well as all illegal waste dumping sites within the property, and rehabilitate the affected areas; 2.c Complete the demolition of the structures supporting the terraces Immediate along the lakeshore in Ohrid town, which at the time of the Mission was only partially carried out; 2.d Speed up the process of demolishing negatively-impacting illegal buildings/structures both in North Macedonia and Albania by Immediate preparing an action plan with identified priorities and timeframes for demolition with a three-year time horizon. This implies:

16 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the “zone” Ljubaništa 2 does not exists and there are no plans for its development. A site had been considered in the period 2015-2016 but has since been abandoned. No legal or administrative measures have been taken for its creation.

i. prioritizing for demolition the priorities identified by Galičica Immediate National Park and within Ohrid Municipality; ii. drafting a list of demolition priorities also for Struga and Debrca Immediate municipalities; iii. compiling an inventory for Pogradec Municipality similar to the one prepared for Ohrid Municipality and proceeding with an assessment of the negative impacts on the OUV of the property, Immediate its attributes and its setting to determine the priorities for demolition; iv. considering the demolition of the negatively-impacting Three years structures and unfinished buildings in Lin village; v. speeding up the administrative procedures to achieve the Three years demolition of the unfinished Lagadin Hotel near Ohrid; vi. preparing an updated map with demolished illegal buildings Immediate and those for which demolition has been proposed. 2.e Urgently complete the removal of the tailings dam and the mining dumpsite at Memëlisht, as well as the area’s rehabilitation and the Three years monitoring of heavy metal contamination in soil, water and locally caught fish; 2.f Evaluate the impacts of former and active mining activity in the surroundings of the property on its OUV and attributes and ensure Immediate the permanent closure and remediation of any mining activities proven to have negative impacts; 2.g Mitigate the impacts of the highway Qafe Thane - Pogradec by: v) removing the service road built to facilitate traffic during Immediate construction; vi) rehabilitating through environmental engineering interventions Five years the cut of the Falaise near Pogradec to build the ‘panoramic (completion) tunnel’; vii) re-designing the landscaping of the highway, prioritising visual Immediate alignment with the natural landscape instead of tree-lines, and (design) native tree species instead of conifers and palms. Five years (execution) viii) preventing any type of edification on the stretches of land between Immediate the lakeshore and the highway;

2.h Restore ecologically sensitive sections of the lakeshore that have Immediate been degraded such as the Studenčišča Marsh and ensure their

connection to the lake, including removing seasonal tourism

facilities and moving them to less sensitive sections of the coast;

2.i Prevent the construction of permanent structures along the beach Immediate adjacent to the new promenade being built at Studenčišča Marsh and

that temporary ones are strictly regulated in terms of material used,

ease of dismantling, shape, size.

2.j Carry out within an 18-month timeframe the revision of the uses of

3. Recommendations to strengthen the management framework and its effectiveness at the transboundary and national levels: 3.a Raise the profile of the members of the Transboundary Watershed Immediate Management Committee to include top-level decision makers to

guarantee they are empowered to take high-level decisions and, proportionally, of the members of the Watershed Management Committee Secretariat; guarantee its functionality by involving further human resources from national and local offices; and strengthen and detail the Rules of Procedure of the Committee in order to guarantee its effective functioning; 3.b Establish and guarantee the effective functioning of the extended Immediate Management Committee for Pogradec Protected Landscape (PPL) envisaged by the World Heritage Supplement to the Management Plan of the PPL, and implement fully the Management Plan and its Supplement ensuring formal endorsement of the latter by all relevant stakeholders; 3.c Give the extended Management Committee for PPL the mandate to Immediate prepare an action plan to address the Mission’s and World Heritage Committee’s recommendations; 3.d Ensure the full operationality of the Management Commission for the Immediate Ohrid Region in North Macedonia and guarantee that their decisions are communicated to all interested parties; 3.e Ensure that development provisions and zoning proposals that are likely to impact negatively on the OUV of the property and its Immediate attributes, including modifications to the zoning of Galičica National Park, are redressed and removed from the revised draft of the Management Plan for the Natural and Cultural Heritage of the Ohrid Region 2020 - 2029 (North Macedonia); 3.f Approve the Management Plan 2020-202917, enforce it, by, first of all, modifying planning provisions in other plans allowing for Immediate developments that may have negative impacts on the property, its OUV and attributes, and implement it and support its implementation by allocating adequate human and financial resources and guaranteeing high-level commitment; 3.g Ensure that the ongoing development of the new Management Plan for Galičica National Park halts timber extraction activities within its Immediate territory and reinforces the protection of its forested areas while regulating sustainable tourism activities, and send it to the World Heritage Centre and the Advisory Bodies for review; 3.h Prepare both at the national and transboundary levels an action plan and an implementation calendar of short-, medium- and long-term measures to address all previous World Heritage Committee and Immediate Reactive Monitoring missions’ recommendations and integrate this action plan into the respective management plans for the property; 3.i Increase the RAPA and the RDCH staff dedicated to Pogradec and reinforce the dialogue and cooperation among RAPA and RDCH Immediate dedicated staff, and municipal technical staff, including the Museum staff; 3.j Establish long-term transboundary cooperation on monitoring the lake’s biodiversity and water quality, and establishing common Three years management actions such as jointly agreed fishing quota.

17 At the time of the mission, the Management Plan was about to get approved. In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that the Management Plan was approved by the Government of the Republic of North Macedonia in January 2020 (“Official Gazette of RNM” No. 45/20).

3.l Ensure that all institutions and administrations involved implement the management activities they are responsible for through Two years appropriate monitoring and accountability mechanisms 3.m Consider the introduction for both countries of a tourism tax, its amount being proportional to the hotel class rather than a flat rate, where it does not exist, to be managed locally and to provide Three years municipalities with additional revenue to cover the costs deriving from environmental pressures caused by tourism; 3.n Dedicate the revenue of the tourism tax to the improvement of the wastewater and waste management systems as a matter of priority. Five years

4. Recommendations to fully align planning provisions to the OUV of the property and its attributes: 4.a Assess the negative impacts on the OUV of the property of implemented development provisions of expired General Urban Plans Immediate (GUP) for Ohrid, Struga and Debrca, as well as of all other spatial or development plans covering the property or parts of it; 4.b Assess the potential negative impacts on the OUV of the property of the yet to be implemented provisions of the GUPs, as well as of other Immediate existing spatial or development plans, and verify the possibility to cancel or reduce them, on the basis of the considerations and recommendations of all Reactive Monitoring missions and of the World Heritage Committee; 4.c Revise / update the GUPs for the municipalities in North Macedonia and the draft General Local Plan (GLP) for Pogradec making them Immediate consistent with the aim of preserving the OUV of the property and its attributes; approve and implement them. This includes: iii. Establish stricter criteria for the development of area PG/HU64 in Pogradec GLP in order to guarantee that any proposal improves the current conditions, characterised by low quality architecture, inappropriate landscaping and non-native vegetation, and excessive tourism structures on the lakeshore; iv. Preserve the rare rural areas along the lakeshore, which contribute to the appreciation of the OUV of the property and adapt planning objectives and provisions accordingly, the only exception being the former mining dumpsite of Guri i Kuq (Albania) that can be considered for redevelopment.

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Management of the Natural and Cultural Heritage of the Ohrid Region as soon as possible; 5.e Elaborate a plan for inventorying additional immovable cultural Three years heritage objects, including archaeological sites, and implement it; 5.f Monitor and control the discharge of lake waters into the Crn Drim River by North Macedonia power plants company ESM and ensure Immediate implementation of best practices in transboundary water management; 5.g Enforce legal provisions to protect native forests, including restoring Immediate degraded areas, and take all necessary measures to regulate and reduce timber harvesting as well as to introduce alternative fuel and power sources; 5.h Use the Transboundary Watershed Management Committee meetings as an opportunity to discuss the potential creation/expansion of the Five years buffer zone of the property; 5.i Remove the material deposited in the narthex of St. Sophia Church and make the narthex accessible to the public, and check the state of Immediate conservation of the narthex and of its mural paintings by certified restorers assessing priorities for intervention.

6. Elaborate Strategic, Environmental and Heritage Impact Assessments according to the ICOMOS Guidance and IUCN World Heritage Advice Note to assess the cumulative impacts of plans and projects and submit them Immediate to the World Heritage Centre before any final decision is taken. These should include: 6.a All plans and planned infrastructure projects (e.g. highway A2, all envisaged stretches, railway corridor VIII Kichevoe – Lin) that may impact on the property, its OUV and attributes, before proceeding with their implementation, including the alternatives that combine the routes of linear infrastructure planned for the Struga plain, as requested by the World Heritage Committee; 6.b High Voltage transmission line focusing on the overhead and underground alternatives; 6.c Gas pipeline project;

7. Recommendations concerning projects to enhance the conservation conditions of the property: Immediate 7.a Improve the existing wastewater treatment system for all settlements (beginning)/ in the lake’s basin, ensuring the connection of the lacking rural areas Five years (completion) to the main system or the creation of smaller treatment plants where

needed;

7.b Ensure the allocation of sufficient financial and human resources for Immediate the continuous and efficient running of the Pogradec Wastewater

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7.e Proceed with implementing plans to re-divert the Sateska River back Two years into the Crn Drim River as soon as possible, and ensure complete (beginning) restoration of the Sateska; 7.f Provide updated information on the detailed urban plans for the 19 complexes of the Old Nucleus of Ohrid and their level of Immediate implementation; 7.g Implement a transboundary invasive species monitoring programme for Ohrid Lake, and take all necessary measures to control invasive species in the lake and its tributaries, including implementing control Three years and/or eradication programs if needed; 7.h Ensure that reintroduction of red deer in Galičica National Park is only carried out according to expert opinion, and the most recent scientific Three years data and best practices available; 7.i Carry out an impact assessment of the off-road vehicle tourism activities currently permitted in Galičica National Park on its protected Immediate habitats and species, and develop and enforce regulations to manage these activities within the National Park; 7.l Provide detailed information to the World Heritage Centre and the Advisory Bodies on passenger transportation of the already operating Immediate passenger boats on both sides of the lake as well as on the propelling system of the ferry boats and potential pollutants, if any, which can be dispersed into the lake. 6. Recommendations concerning raising awareness of the values of the property and community participation: 8.a Increase community participation in the management, conservation and monitoring of the property by promoting active collaboration Immediate between authorities and civil society and by ensuring that management meetings are open to the public, as well as facilitating access to official information regarding management and the implementation of the World Heritage Committee’s recommendations; 8.b Develop environmental awareness and education programmes in Immediate close collaboration with local citizens’ groups, targeting especially (preparation) implementation children and visitors during the summer season. extended in the 8.c Continuously communicate the World Heritage Supplement to the mid- and long Management Plan of the PPL and its content to all national and local term institutions and agencies, and promote the objectives and actions of the Supplement among local communities through leaflets and Immediate meetings. 7. Provide updated information and documentation on all project and plan proposals according to paragraph 172 of the Operational Guidelines and submit the most updated project documentation to the World Heritage Immediate Centre for examination by the Advisory Bodies before any decision is (for all taken, particularly on the following projects: projects) ● Ljubaništa 1 and 2; ● One hundred villages initiative: Lin, Tushemisht, Gurras; ● Waterscape Park Design of Drilon-Tushemisht; ● Draft masterplan for the Pogradec waterfront and subsequent implementation operational plans and projects; ● Pan European VIII railway; ● Free economic zone near Ohrid airport;

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● Ohrid airport expansion18; ● Architectural design for the Quay Macedonia in Ohrid, including the finishing, urban furniture, illumination system and vegetation arrangements; ● Ohrid ring road19.

18 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that there are no plans for an airport extension. 19 In a letter dated 17 January 2021 in which the State Party of North Macedonia provided comments on factual errors in the draft mission report, the State Party informed that there are no plans for the Ohrid ring road.

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8. LIST OF RECEIVED AND CONSULTED DOCUMENTS AND PUBLICATIONS (2017) World Heritage Supplement to the Management Plan for Pogradec Protected Landscape 2017-2027. Pogradec and Tirana, Albania. (2019) Natural and Cultural Heritage of the Ohrid Region - Management Plan 2019-2028. Skopje-Ohrid-Struga-Debrca. (2020) Revised Management Plan for the Natural and Cultural Heritage of the Ohrid Region World Heritage property 2020 – 2029. AD MEPSO (2015) Environmental and Social Impact Assessment for the 400 kV Transmission Line SS Bitola – Macedonian /Albanian border and SS 400/110 kV Ohrid. Project Updated Non-Technical Summary. Skopje, Macedonia. Bino T. (2019) Preliminary report on the IWC 2019 in Albania. NaturAL Project Report. Tirana, Albania. Bolles + Wilson & IDRA & S. Guri (2015) Strategic Environmental Assessment for the General Local Plan of Pogradec Municipality (2016 – 2031). Civil Engineering Institute “Macedonia” JSC Skopje (2019) Strategic Environmental Assessment for the Management Plan for the Natural and Cultural Heritage of the Ohrid Region (2019-2028). Enviroplan & partners (2017) Detail Design for the closure and rehabilitation of non-compliant landfills and dumpsites. In: Preparation of necessary documents for establishing of an Integrated and Financially Self-sustainable Waste Management System in Pelagonija, Southwest, Vardar and Skopje Regions (EuropeAid/136347/IH/SER/MK). Athens, Greece. GIZ (2016) Initial Characterisation of Lakes Prespa, Ohrid and Shodra/Skadar. Implementing the EU Water Framework Directive in South-Eastern Europe. Project: Conservation and Sustainable Use of Biodiversity at Lakes Prespa, Ohrid and Shkodra/Skadar (CSBL). Bonn and Eschborn, Germany and Tirana, Albania. GIZ (2017) Fish and Fisheries - Lake Ohrid. Implementing the EU Water Framework Directive in South-Eastern Europe. Project: Conservation and Sustainable Use of Biodiversity at Lakes Prespa, Ohrid and Shkodra/Skadar (CSBL). Bonn and Eschborn, Germany and Tirana, Albania. GIZ (2019) Monitoring Manual for Lake-bound Species and Habitats of Lakes Prespa, Ohrid and Shkodra/Skadar. Implementing the EU Nature Conservation Directives in South-Eastern Europe. Project: Conservation and Sustainable Use of Biodiversity at Lakes Prespa, Ohrid and Shkodra/Skadar (CSBL). Bonn and Eschborn, Germany and Tirana, Albania. Hydro Energo Engineering (2015) Detailed design of collector system from Radožda to Kalishta, Municipality of Struga (Tech. num. ETI– IV–310/15 Lot 2/1). Skopje, Macedonia. ICOMOS and IUCN (2019). Advisory Mission to the Natural and Cultural Heritage of the Ohrid Region World Heritage site (North Macedonia part) on highway A2. Paris, France and Gland, Switzerland. IUCN (2019) Technical Evaluation Report on the World Heritage Nomination for Extension of the Natural and Cultural Heritage of the Ohrid Region (Albania, extension of property in North Macedonia). Gland, Switzerland.

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JICA (Japan International Cooperation Agency) (2012) Former Yugoslavia Republic of Macedonia Data Collection Survey for Ohrid Lake Environmental Improvement. Nihon Suiko Sekkei Co., Ltd. Tokyo, Japan. Jordanova M., Rebok K., & Rocha E. (2016) Liver Pathology of Female Ohrid Trout (Salmo letnica Kar.) from the Eastern Coast of Lake Ohrid: Baseline Data Suggesting the Presence of a Pollution Gradient. Turkish Journal of Fisheries and Aquatic Sciences, 16, 241-250. NIVA (Norwegian Institute for Water Research), UBT (Agricultural University of Tirana) & HIO (Hydrobiological Institute Ohrid) (2013) Developing Biological Tools for Monitoring of Lake Ohrid in accordance to European Water Framework Directive. Ohrid, North Macedonia & Durrës, Albania. Ohrid SOS (2020) World Heritage on the Edge III - Another Brick in the Wall. Ohrid, North Macedonia. Particip & ETI Consulting (2015) Preparation of necessary documentation for upgrading the WWTP in Vranishta and extension of the collector system for Ohrid Lake, Feasibility Study – Part 1 (IPA/OPRD2007-2011/3.1/LOT6/08). Paris, France. PROAP (2019) Waterscape Park Design – Schematic Design, Masterplan. Location: Drilon / Tushemisht. Lisboa, Portugal. State Party of the Republic of North Macedonia (2019) Report of the State Party to the World Heritage Committee on the state of conservation of the Natural and Cultural Heritage of the Ohrid Region and related annexes. State Party of the Republic of Albania (2019) Report of the State Party to the World Heritage Committee on the state of conservation of the Natural and Cultural Heritage of the Ohrid Region and related annexes. Trajanovski (2019) ESENIAS-TOOLS Case Study 3: Invasive Alien Species - growing threat to biodiversity and ecosystem functionality in ancient Lake Ohrid and its watershed. Ohrid, North Macedonia. UNDP (2019) Regional Project Proposal: Integrated climate-resilient transboundary flood risk management in the Drin River basin in the Western Balkans. UNESCO, ICOMOS and IUCN (2017) Reactive Monitoring Mission report on the Natural and Cultural Heritage of the Ohrid Region (Former Yugoslav Republic of Macedonia). Paris, France and Gland, Switzerland. Velevski M., Hallmann B., Grubač B., Lisičanec T., Stoynov E., Lisičanec E., Avukatov V., Božič L. & Stumberger B. (2010) Important Bird Areas in Macedonia: Sites of Global and European Importance. Acrocephalus, 31 (147): 181-282. Wetlands International (2006) Waterbird Population Estimates. Fourth Edition. Wageningen, The Netherlands. World Heritage Committee (2015) Document 15/39.COM/8E. Rev. Adoption of Retrospective Statements of Outstanding Universal Value. Bonn, Germany. World Heritage Committee (2016) Decision 40 COM 7B.68. Natural and Cultural Heritage of the Ohrid region (the Former Yugoslav Republic of Macedonia) (C/N 99ter). Istanbul, Turkey. World Heritage Committee (2017) Decision 41 COM 7B.34. Natural and Cultural Heritage of the Ohrid region (the Former Yugoslav Republic of Macedonia) (C/N 99ter). Kraków, Poland.

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World Heritage Committee (2019) Decision 43 COM 7B.36. Natural and Cultural Heritage of the Ohrid region (North Macedonia) (C/N 99ter). Baku, Azerbaijan. World Heritage Committee (2019) Decision 43 COM 8B.9. Natural and Cultural Heritage of the Ohrid region (Albania, North Macedonia). Baku, Azerbaijan. Additional information submitted by the States Parties upon request of the Mission. In Annex 2 the list of additional information requested by the Mission can be found.

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ANNEX 1. TERMS OF REFERENCE, PROGRAMME AND COMPOSITION OF THE 2020 REACTIVE MONITORING MISSION

Mission Terms of Reference

Joint World Heritage Centre / ICOMOS / IUCN Reactive Monitoring mission to “Natural and Cultural Heritage of the Ohrid region”

Albania-North Macedonia, 27 – 31 January 2020

The World Heritage property “Natural and Cultural Heritage of the Ohrid region” (Albania, North Macedonia) was inscribed on the World Heritage List in 1979 under natural criterion (vii). The property was extended in 1980 to include cultural criteria (i)(iii)(iv), and again in 2019 to include the Albanian part of the lake, becoming a mixed transboundary property.

A superlative natural phenomenon, Lake Ohrid provides refuge for numerous endemic species of freshwater fauna and flora dating from the Tertiary period. Situated on the shores of the lake, the town of Ohrid is one of the oldest human settlements in Europe. Built mainly between the 7th and 19th centuries, it has the oldest Slav monastery (St Pantelejmon) and more than 800 Byzantine-style icons dating from the 11th to the end of the 14th century. In the shallow waters near the shores of the lake, three sites testify to the presence of prehistoric pile dwellings, and the small Lin Peninsula is the site of the remains of an Early Christian church founded in the middle of the 6th century. The convergence of well-conserved natural values with the quality and diversity of its cultural, material and spiritual heritage makes this region truly unique.

On the side of North Macedonia, concerns have been raised since 1998 regarding the lack of an adequate management planning system to protect the Outstanding Universal Value (OUV) of the World Heritage property, as well as the impact of accelerated urban development and urban pressure, increased traffic, inadequate treatment of wastewater and solid waste, and unsuitable tourism on the property. The efforts of the State Party to address the issues raised by the World Heritage Committee at its 41th session are appreciated. However, many issues addressed in previous Committee decisions and mission recommendations (September 1998: joint UNESCO/ICOMOS/IUCN Monitoring mission; /December 2013: joint ICOMOS / UNESCO Advisory mission; April 2017: joint World Heritage Centre/ICOMOS/IUCN Reactive Monitoring mission) require further progress.

At its 43rd session (Baku, 2019), the Committee noted with concern the threats facing the cultural and natural attributes of the property and encouraged the States Parties “to develop, as a matter of urgency, a joint transboundary approach to address these threats to the values, integrity and the serious protection and management issues facing Lake Ohrid” (Decision 43 COM 8B.9). The Committee (Decision 43 COM 7B.36) requested the States Parties to submit by 1 February 2020, an updated report on the state of conservation of the property, for examination by the World Heritage Committee at its 44th session in 2020, with a view to considering, in case of the confirmation of the potential or ascertained danger to its Outstanding Universal Value, the possible inscription of the property on the List of World Heritage in Danger.

The Committee further requested the States Parties to invite a joint World Heritage Centre/ICOMOS/IUCN Reactive Monitoring mission to the property to discuss the measures to address the recommendations of its Decision 43 COM 8B.9.

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The objective of the Reactive Monitoring mission is to review the overall state of conservation of the property as well as progress in the implementation of the Committee’s Decision 43 COM 8B.9, including its specific recommendations (paragraph 6 points a-n), and previous Committee decisions and mission recommendations.

In particular, the mission should review and asses the following key issues:

1. Assess the overall state of conservation of the property and evaluate factors and conservation issues that could potentially impact on its OUV, including particularly its conditions of authenticity and integrity;

2. Analyse the planning situation for all major construction and reconstruction projects in the property and its setting, whether proposed, approved or contracted, including but not limited to:

· Progress on a comprehensive comparative study of alternative routes for the planned Railway corridor VIII, from Kičevohe in North Macedonia to Albania including those that do not pass through the property,

· Implementation of the recommendations of the Committee regarding the proposed highway stretch A2 Trebenište – Struga, including necessary Heritage Impact Assessments (HIAs),

· Status of the major tourism development for Drilon Springs and the nearby springs of Tushemisht in the buffer zone,

· Status, location and setting of the project to reconstruct the Quay Macedonia in the city of Ohrid, including necessary Heritage Impact Assessments (HIAs);

3. Analyse the planning and protection framework for the property and consider progress with developing short and medium term measures and strategies to strengthen the overall systems of protection and management for the property and its setting; and longer-term measures for more targeted strategic and spatial plans together with planning tools and guidance;

4. Assess the current situation in relation to the Committee’s request to maintain in North Macedonia a moratorium on any transformation within the property, to create an inventory of illegal buildings and to demolish those negatively impacting on OUV; also assess progress in Albania with the removal of illegal buildings along the lake shore and re-aligning part of the road away from the lake;

5. Review the work undertaken by the States Parties to develop a formal adequately resources and functioning transboundary coordinated management structure and to strengthen collaborative working between cultural and natural agencies and departments at both national and regional levels;

6. Consider progress with strengthening legal protection in Albania, fully implementing the Management Plan, and introducing an effective management system, with adequate human and financial resources; and consider progress with the implementation of the Management Plan in North Macedonia;

7. Consider whether measures have been taken to improve the physical protection of Lin church and to appoint designated personnel for the management of Lin church, Lin village and Lin peninsula;

8. Review progress with preparing an inventory of the cultural sites in the buffer zone in Albania and introducing a conservation approach for these and the buffer zone landscape;

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1. Analyse the impact or potential impact of the current treatment of sewage around the Lake, recalling the Committee’s request to install and operationalize sewage treatment plants and introduce monitoring and control of agricultural run-off into the lake;

10. Also review progress with the implementation of previous Committee Decisions, and the recommendations of the 1998, 2013 and 2017 mission reports, including the approval of all relevant planning instruments, including the Management Plan, and identify those recommendations which are yet to be implemented and which remain relevant to the conservation of the OUV of the property.

The mission team should ensure that a comprehensive inspection of all parts of the property, and relevant parts of the buffer zone occurs and should hold working meetings and consultations with authorities of Albania and North Macedonia at national and local levels and all other relevant stakeholders, including NGOs. The State Party should facilitate necessary field visits to key locations of the property and its buffer zone, including Lin Peninsula and the locations for the planned Railway corridor VIII and the highway stretch A2 Trebenište – Struga.

Based on the results of the above-mentioned assessment and discussion with the States Parties representatives, the mission team should propose recommendations to the States Parties and the World Heritage Committee to improve the conservation and management of the property. The mission team should prepare a concise mission report in English or French on the findings and recommendations of this Monitoring mission for review by the World Heritage Committee at its 44th session (2020). It should be noted that the final recommendations should be provided in the mission report and not during the mission. The report should follow the standard format.

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Mission Programme

Albania

Day 1 - Monday, 27th January

14.30 Arrival in Tirana airport and pick up Receipt of documents to be consulted

15.00 - 16.00 Meeting at Ministry of Tourism and Environment Meeting with high Officials from the Ministry of Tourism and Environment.

16.30 - 17.30 Meeting at Ministry of Culture Meeting with high Officials from the Ministry of Culture.

17.30 - 18.00 Meeting at Ministry for Europe and Foreign Affairs Mr. Sokol Gjoka, Director of the Directorate of the International Organizations, Ministry for Europe and Foreign Affairs / SG of the National Commission for UNESCO 18.00 - 21.00 Travel to Pogradec Accommodation in hotel and dinner

Day 2 - Tuesday, 28th January

8.00 - 12.30 Site Visits “Lin village, one of 100 tourist villages, potential for development of projects focusing on Tourism and Agribusiness” - Presentation of project vision for Lin village. Ruins of the Early Christian Church and the "Mosaics" (Basilica) in Lin village: assessment of conservation and physical security. Railway tunnel, former railway station, railway and remains of the former Red Stone Mine (Memëlisht) during the Lin-Pogradec itinerary. Along the shore of Ohrid Lake (Lin-boat anchor place in the city): assessment of progress made on demolition of illegal constructions along the shore, sewage spill. Presentation of the following projects: Border Crossing Guide with Ferry "Lyhnidas”: Pogradec - Lin - Struga - Ohrid - Saint-Naum - Tushemisht - Pogradec; Tushemisht Beach Line and Coast Guard Station.

12.30 - 13.45 Lunch Time

14.00 - 17.30 Site Visits Along the shore of Ohrid Lake (Pogradec-Tushemisht): areas affected by illegal construction, measures taken and ongoing projects, wastewater management with a tendency to discharge into the lake. Presentation of the project "Lungo-Lake” (Lake Pedestrian). Drilon Springs, area of the AADF project, and presentation by Regional Directorate of Territorial Regulation, Korçë representatives on the inventory of cultural heritage sites in the Buffer Zone and planning for the development of major projects focusing on tourism.

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“Tushemisht village, one of the 100 tourist villages, potential for developing projects focusing on Tourism and Agribusiness” - Presentation of project vision for Tushemisht village. Pogradec Historical Center - Presentation of projects related to the Historic Center.

17.30 - 18.45 Meeting at Pogradec Municipality Issues such as the Territorial Adjustment Plan; planning joint management of property issues, potential risks; and implementation of applicable property protection legislation. Mr. Ilir Xhakolli, Mayor of Pogradec; Cabinet of the Mayor; representatives of local institutions responsible for urban planning, environment, property issues and territory in the Buffer Zone, cultural relations.

18.45 - 19.45 Meeting with Civil Society

19:45 Welcoming Dinner Hosted by Pogradec Municipality

Day 3 - Wednesday, 29th January

08:00 - 8.45 Site Visits Pogradec Wastewater Treatment Plant

8.45 - 9.15 Accompanying the Mission to the border crossing with North Macedonia, Ohrid Region.

9.15 Meeting with the Macedonian authorities at the border crossing

List of people and stakeholders met during the Mission

Ministry of Culture Mrs. Entela Çipa, Secretary General Mr. Kozeta Angjeliu, Director Mrs. Sonila Kora, Head of Unit

Ministry of Tourism and Environment Mr. Adrian Kamenica, Secretary General Mr. Pellumb Abeshi, General Director of Environmental Policies Mrs. Klodiana Marika, Director of Development Programmes on Environment Mr. Zamir Dedej, General Director of National Agency of Protected Areas Ms. Lediana Karalliu, Head of Waste Management Sector

Ministry of Europe and Foreign Affairs Mr. Sokol Gjoka, Director, Ministry for Europe and Foreign Affairs / National Commission for UNESCO

Pogradec Municipality Ilir Xhakolli, Mayor, Pogradec Municipality Mr. Gani Bego Mr. Alban Dervishaj Mrs. Froseda Angjellari, Museum of Pogradec

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Regional Agency of Protected Areas (RAPA) Mihallaq Qirjo, Director of RAPA Ernold Shaho, RAPA Pogradec

National Institute of Cultural Heritage Mrs. Arta Dollani, Director General, National Institute of Cultural Heritage (NICH) / National Focal Point for World Heritage Convention Ms. Daniel Pirushi, Director Mrs. Rudina Zoto, Director Mrs. Marsela Plyku Demaj, Head of Department

Regional Directorate of Cultural Heritage, Korçë Mr. Edvis Koki, Director, Regional Directorate of Cultural Heritage, RDCH) Korçë Mrs. Amanda Cici, Specialist, RDNC Korçë

Institute of Archaeology, Academy of Albanian Studies Prof. Luan Përzhita, Director, Institute of Archaeology (IoA) Dr. Adrian Anastasi, Underwater Archaeologist, IoA

Representatives of local community and NGOs Mrs. Shpresa Blaceri, Local NGO “Gruaja intelektuale” Mrs. Eleni Jajcari, local NGO “Unë Gruaja” Mrs. Bajana Ceveli, NGO for Women Fishermen community Lin Village

North Macedonia

Mission pick-up from Saint Naum border crossing

09:15 - 13:30 Site Visits Galičica National Park urban developments along the coast and mountainous part Andon Bojadzi, Head of Department for Natural Protection, Galičica National Park / Management Commission for the Ohrid Region Studenčišča Marsh and Hydrobiological Institute Dr. Sasho Trajanovski, Hydrobiological Institute / Management Commission for the Ohrid Region Wastewater Management System ongoing works (Park/Gorica) Vladimir Aleksijoski, Director, PE Kolekstorski Sistem Dr. Konstantin Georgievski, Mayor of Ohrid

13:30 - 15:00 Lunch Hotel Laki, Ohrid, Hosted by National Park Galičica

15:30 - 17:30 Meeting with Civil Society Ohrid Municipal Building

19:30 Welcome Dinner and Working Meeting Saint Sofija Restaurant, Ohrid, Hosted by Mayor of Ohrid Attending: Minister Edmond Ademi Mayor Dr. Konstantin Georgievski Mission Core Team

Day 4 - Thursday, 30th January

9:00 - 10:30 Working meetings with Ohrid Municipality

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Ohrid Municipal Building Review of ongoing process for removal of illegally built structures, Quay Macedonia project, update on ongoing studies for the Studenčišča Marsh, and long-term traffic circulation. Attending: Dr. Konstantin Georgievski, Mayor of Ohrid Mission Core Team

10:30 - 14:30 Site Visits Struga Natmir Nexhepi, Head of Sector for Urban Development, Struga Municipality Gjorgji Dislioski, Advisor for the implementation of urban plans, Sector for Urban Development, Struga Municipality Valentina Todorovska, Nezlobinski Museum- Struga

Highway A2, section(s) Trebenište-Struga (PE State Roads) Saska Bogdanova Ajceva, Advisor for Environmental Protection, PE State Roads Mirjana Jankovik, PE State Roads Slobodan Ognjenovik, PhD, Faculty of Civil Engineering/Consultant, PE State Roads

Corridor VIII Railway, Radožda and Environs (PE Macedonian Rail-Infrastructure) Gjorgi Pushev, Civil Engineer for Project Documentation Preparation Driton Rusi, Architect/Engineer for Project Documentation Preparation

14:30 - 16:00 Working Lunch on Cultural Conservation and Site Visits with Institute for Protection of Monuments of Culture and Museum Ohrid Old City Attending: Daniela Nedelkovich, Director Goran Patchev, Conservator Milcho Georgievski, Art Historian Bojan Taneski, Archeologist Mission Core Team

16:00 - 18:00 Internal expert working meeting

Day 5 - Friday, 31st January

08:00 Departure for Skopje from Hotel Millennium Palace

10:45 Arrival at Hotel Alexander Square Boutique, Skopje

11:30 - 13:30 Meeting with Ministry of Environment and Physical Planning Ministry of Environment and Physical Planning Review and presentation of ongoing projects and studies on Sateska River, Ohrid Lake, waste management process. Attending: Naser Nuredini, Minister of Environment Vlatko Trpeski, Head of the Department on Nature Protection Biljana Petkoska, Head of the Department on Environment Ljupka Dimovska Zajkov, Deputy Head of the Department on Water Vesna Indova, Head of the Department on EU integration Bajram Camic, Department on Spatial Planning, associate Mission Core Team Angel Panov, ProPoint/UNDP Consultant, Sateska River Project

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13:30-14:45 Lunch Stara Kuka, Skopje, Hosted by Ministry of Environment and Physical Planning Attending: Naser Nuredini, Minister of Environment and Physical Planning Jani Makraduli, Deputy Minister of Environment and Physical Planning Ana Petrovska, State Secretary, Ministry of Environment and Physical Planning Hristijan Gjorgievski, Adviser to the Prime Minister

15:00 - 16:15 Meeting with Directorate for Protection of Cultural Heritage Directorate for the Protection of Cultural Heritage Presentation of Management Plan ongoing protection activities Attending: Vladimir Lazovski, Deputy Minister of Culture Faton Fazliu, Chief of Staff to the Minister of Culture Aco Kostov, Director for the Protection of Cultural Heritage Vesna Ilievska, State Counselor, Ministry of Culture Ana Aleksova, Directorate Mission Core Team

16:30-17:30 Meeting with State Railways, Ministry of Transport Government of the Republic of North Macedonia Railway route Corridor VIII, Inventory of Illegal Structures Attending: Edmond Ademi, President, National Commission for UNESCO Festim Halili, Director of Macedonian Rail-Infrastructure Petar Spasovski, Assistant Director MR-Infrastructure Ana Gjorgijoska, Cabinet of the Minister for Transport Ljupka Siljanoska, State Advisor, Ministry of Transport Blijana Zdraveva, Head of Sector- Railways, Ministry of Transport Tanja Dzokik, Deputy Head of Sector for Legal Affairs, Ministry of Transport Biljana Dejanovska, Head of Department, Office of the Minister of Transport

19:30 Farewell Dinner Gurmet, Skopje, Hosted by Minister Edmond Ademi Attending: Minister Edmond Ademi, President of the National Commission Adrej Zernovski, Deputy Minister of Foreign Affairs Faton Fazliu, Chief of Staff to the Minister of Culture Mission Core Team

Day 6 - Saturday, 1st February

End of mission and departure of UNESCO/ICOMOS/IUCN representatives.

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Mission Composition

UNESCO representative:

Thomas Rigauts Associate Project Officer Europe and North America Unit UNESCO World Heritage Centre 7, place de Fontenoy F – 75352 Paris 07 SP [email protected]

ICOMOS representative:

Luisa De Marco Conservation and landscape architect, independent consultant [email protected]

IUCN representative:

Diana Rodrigues Biologist and Conservation Specialist IUCN World Commission on Protected Areas [email protected]

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ANNEX 2. LIST OF ADDITIONAL INFORMATION REQUESTED BY THE MISSION

ALBANIA - list of persons met during the mission including name, function, institution (all ministries/stakeholder meetings); - final approved law on “Cultural Heritage and Museums”; - summary in English of the regulations of the Municipal Development Plan (master plan) and of the legends of the maps, particularly those related to the zoning and land- use; the complete regulations and implementation norms of the Municipal Development plan in Albanian; - list of protected buildings within the property and the buffer zone, a sample of an inventory card (in English at least the form fields), and a risk list (if available); - all available information on the Drilon Springs project, including proposals, designs, budget as well as the new ring road project (including maps) and the Lungo Lake project and if the two are connected (e.g. priorities, timeframe); timeframe of the ring road from Elbasan to Korçe; - summary of the ministerial order regarding the Pogradec Protected Landscape Management Committee (including both MOC and MOTE), including a list of members with titles and institutions, and the mandate of the Committee; - last State of the Environment Report of the Natural Environment Agency with information on the lake, such as (but not limited to) water quality, benthic fauna, fish population; - information on the 2018 EU project on composting where women from rural areas were trained to decrease waste (mentioned during meeting with NGOs); - Bird Report of 2019 and previous years (if available); - order to remove the mining dump near the lake and rehabilitate the area, including amount removed, amount still to be removed, timeframe of the removal (when started, projected end), timeframe for rehabilitation, as well as water quality of the lake next to the dump (if available); - inventory of illegal buildings (buildings that have issues with permits) by the Agency of Properties and Legalisation, mapping (if available) and state of the art of the demolitions and legalisations; - project information on the “100 villages” project, including context, criteria and detailed information on the projects for selected villages located in the property (e.g. Lin, Tushemisht); - detailed report with a map that shows which villages are (not yet) connected to the sewage system; - information on regulation of the beach use, including permitted and unpermitted uses, restrictions, timeframe for temporary installations (when they can be installed when they are to be removed), examples of structures that are approved or denied; - related to the point above, list of temporary structures that have not been removed voluntarily by the concessionaires and for which the municipality had to intervene, list and pictures of structures that are still to be removed since last summer;

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- procurement process and/or TORs to conduct work on the 6-7 polluting rivers/channels such as nets to stop waste (e.g. bottles) and mechanisms to filter smaller material, including the timeframe for these interventions; - progress (such as TORs or any other updated document) for the sewage project prepared for the Ministry of Infrastructure and Energy for villages that are not yet connected to the sewage system such as Buçimas and Vërdovë, etc.; - progress on the waste dump in the buffer zone near Tushemisht including pictures on any interventions done (e.g. fences around the area); - photographs of the removal requested by the Mission of presumed temporary structures near the shoreline that should have been removed after the summer season (e.g. white metal structure on the coast near Tushemisht); - information on the proposed transboundary ferry project including schedule, number of boats, and the agreement with North Macedonia; - list of projects (including TORs, appointed firm, budget, concept note or draft project design if available) accompanied by location maps in the property, in particular in Lin, Tushemisht, Drilon - including but not limited to the “100 villages” projects, or in the buffer zone; - photographs of the last maintenance/monitoring of Lin church, as well as copy of the monitoring reports on the state of conservation and monitoring of the mosaics, including materials used, budget allocated this year and how frequently is monitored; - written order to shut down fish farms from the National Inspectorate of Territorial Protection (if available), order to fine fish farms, and results of the inspection; - inventory of illegal fish farms, including a map of the fish farms (legal, illegal, voluntarily closed, forced closed) and dates of closure for those farms that were removed; - information on the monitoring of the water quality of the lake, including at which locations the samples were taken (especially whether they covered the lakeside near the mining dump, to see whether there is contamination by heavy metals).

NORTH MACEDONIA - list of persons met during the mission including name, function, institution (all ministries/stakeholder meetings); - list of members (name, role, institution), minutes of the transboundary Watershed Committee meeting of 17 January 2020, agenda upcoming meeting and statute of the Committee; - study on underwater archaeology (cooperation with Switzerland); - existing urban development plan/ masterplan of Ohrid and of Struga, with zoning, land use regimes and regulations for implementation; - plans for the first phase project for upgrading sewage system and the second phase for the reconstruction of the wastewater treatment centre (timeline, funding, activities, etc.); - available project documents of the railway Kichevoe – Lin and of Highway A2 and period/ dates of project elaboration;

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- information about whether and when funds for the implementation of highway A2 and railway corridor VIII are or will be available, including sources of funding and related decisions (amount, stages, timeframe for implementation); - inventory of illegal buildings (buildings that have issues with permits), mapping (if available) and state of the art of the demolitions and legalisations (how many legalised and for what reasons, how many are pending); - excerpt of the law on legalisation of building infringement that has been the legal basis for the legalisation process; - flow charts which clearly show the procedure of legalising or removing illegal buildings, including institutions responsible and timeframes; - additional drawings regarding the Macedonia Quay project, which clearly shows the difference between the existing quay and the project, as well as the structure of the existing quay (and how the existing quay would be reinforced); - plans or information on the proposed marina in Studenčišča Marsh; - list of medium and large-scale projects, including private, public and state- driven projects (documents to be provided depending on the level of progress : TOR’s, appointed firm, budget, concept note or draft project design if available and sketches/maps and state of their approvals) and of their location within the property; - zoning on the current master plans of the municipalities within the property; - zoning of the Management Plan as transparent layers on orthophotos of the territory (if updated) in PDF format at high resolution to facilitate zooming; - results of the joint project with the Albanian University of Agriculture in Tirana (Norwegian funding) on water quality 2012-2015 and 2015-2019, in particular monitoring on water quality and lake eutrophication; - last study done on invasive species by Hidrobiological Institute (2017); - ppt presentation(s) given to the Mission in January 2020; - study on the impacts on the lake of diverting the Sateska River ; - list of priorities for the demolition of illegal buildings in the National Park, including a map (if available), in particular the number of buildings per zone as well as photographs of (illegal buildings in) the village only reachable by boat, Trpejca; - annual work plan of the National Park, including information on the entrance fees (e.g. connection to cease the logging); - memorandum with the mountaineers’ club and any additional information, if available; - draft of the 2020 management plan for the National Park, when available; - biodiversity monitoring plan being developed for the National Park, including information on invasive species; - information on 4x4 tourism activities (who are companies allowed to carry out activity, do they have licenses, how many cars, frequency of activities, any restrictions/obligations to follow, etc.);

- written evidence that the government refused to share information about the property being discussed during government sessions (“classified information”) (mentioned during meeting with NGOs);

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- information on licenses for fish farms, including whether there are any illegal fish farms and the procedure to remove them (if available); - design and feasibility study of the EU Corridor VIII Railway as well as a map showing both the A2 highway and the railway and of any other infrastructure that is planned to be located in the property; - tender to analyze alternative railway route proposal (when available): - details of the project for the free economic zone currently under construction in the property (e.g., drawings, dates of approval, process of approval, EIA non-technical summary report); - power point presentation and further information on UNDP funded project on redirecting the Sateska River (timeline, funding, etc.); - IUCN ECARO evaluation study of the natural and socio-economic values of Ohrid Lake and Studenčišča Marsh (when available); - Order of temporary protection of the Studenčišča Marsh issued by Minister of Environment and its recommendation by city of Ohrid (when available); - Monitoring Manual proposal study for the Lake developed by GIZ; - EU feasibility study to closure and remediate dumping sites (incl. Bukovo) and its draft costing study (when available); - Information on GEF funded project to protect/rehabilitate Crn Drim River (timeline, funding, drawings).

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ANNEX 3. STATEMENT OF OUTSTANDING UNIVERSAL VALUE OF THE PROPERTY

Brief synthesis

The Lake Ohrid region, a mixed World Heritage property covering c. 94,729 ha, was first inscribed for its nature conservation values in 1979 and for its cultural heritage values a year later. These inscriptions related to the part of the lake located in North Macedonia. The property was extended to include the rest of Lake Ohrid, located in Albania, in 2019.

Lake Ohrid is a superlative natural phenomenon, providing refuge for numerous endemic and relict freshwater species of flora and fauna dating from the tertiary period. As a deep and ancient lake of tectonic origin, Lake Ohrid has existed continuously for approximately two to three million years. Its oligotrophic waters conserve over 200 species of plants and animals unique to the lake, including algae, turbellarian flatworms, snails, crustaceans and 17 endemic species of fish including two species of trout, as well as a rich birdlife.

Situated on the shores of Lake Ohrid, the town of Ohrid is one of the oldest human settlements in Europe. Built mostly between the 7th and 19th centuries, Ohrid is home to the oldest Slav monastery (dedicated to St. Pantelejmon) and more than 800 Byzantine-style icons of worldwide fame dating from the 11th century to the end of the 14th century. Ohrid’s architecture represents the best preserved and most complete ensemble of ancient urban architecture of this part of Europe. Slav culture spread from Ohrid to other parts of Europe. Seven basilicas have thus far been discovered in archaeological excavations in the old part of Ohrid. These basilicas were built during the 4th, 5th and beginning of the 6th centuries and contain architectural and decorative characteristics that indisputably point to a strong ascent and glory of Lychnidos, the former name of the town. The structure of the city nucleus is also enriched by a large number of archaeological sites, with an emphasis on early Christian basilicas, which are also known for their mosaic floors. Special emphasis regarding Ohrid’s old urban architecture must be given to the town’s masonry heritage. In particular, Ohrid’s traditional local influence can be seen among its well-preserved late-Ottoman urban residential architecture dating from the 18th and 19th centuries. The limited space for construction activities has led to the formation of a very narrow network of streets.

On the Lin Peninsula, in the west of the Lake, the Early Christian Lin church, founded in the mid-6th century, is related to the basilicas of Ohrid town in terms of its architectural form and decorative floor mosaics, and possibly also through liturgical links.

Although the town of Struga is located along the northern shores of Lake Ohrid, town life is concentrated along the banks of the Crn Drim River, which flows out of the lake. The existence of Struga is connected with several fishermen settlements on wooden piles situated along the lake shore. A great number of archaeological sites testify to origins from the Neolithic period, the Bronze Age, the Macedonian Hellenistic period, the Roman and the early Middle Age period. Similar pre-historic pile dwelling sites have also been identified in the western margins of the Lake.

The convergence of well-conserved natural values with the quality and diversity of its cultural, material and spiritual heritage makes this region truly unique.

Criterion (i): The town of Ohrid is one of the oldest human settlements in Europe. As one of the best preserved complete ensembles encompassing archaeological remains from the Bronze Age up to the Middle Ages, Ohrid boasts exemplary religious architecture dating from the 7th to 19th centuries as well as an urban structure showcasing vernacular architecture

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from the 18th and 19th centuries. All of them possess real historic, architectural, cultural and artistic values. The concentration of the archaeological remains and urban structures within the old urban centre of Ohrid, in the Lin Peninsula, and along the coast of Lake Ohrid as well as the surrounding areas creates an exceptional harmonious ensemble, which is one of the key features that make this region truly unique.

Criterion (iii): The property is a testimony of Byzantine arts, displayed by more than 2,500 square metres of frescoes and more than 800 icons of worldwide fame. The churches of St. Sophia (11th century), Holy Mother of God Perivleptos and St. John Kaneo notably display a high level of artistic achievements in their frescoes and theological representations, executed by local as well as foreign artists. Ancient architects erected immense basilicas, which were to serve as models for other basilicas for centuries. The development of ecclesiastical life along the shores of the lake, along with its own religious architecture, frescoes and icons, testifies to the significance of this region as a religious and cultural centre over the centuries. The similarities between the mosaics of Lin church in the west of the Lake with those of the early basilicas of Ohrid to the east, reflect a single cultural tradition.

Criterion (iv): The Lake Ohrid region boasts the most ancient Slavonic monastery and the first Slavonic University in the Balkans – the Ohrid literary school that spread writing, education and culture throughout the old Slavonic world. The old town centre of Ohrid is a uniquely preserved, authentic ancient urban entity, adjusted to its coastal lake position and terrain, which is characterised by exceptional sacred and profane architecture. The architectural remains comprising a forum, public buildings, housing and sacred buildings with their infrastructure date back to the ancient town of Lychnidos (the former name of the town). The presence of early Christian architecture from 4th to 6th centuries is attested by the lofty basilicas of Ohrid and the small church of Lin. The Byzantine architecture of Ohrid with a great number of preserved sacred buildings of different types from 9th to 14th centuries, is of paramount importance and contributes to the unity of its urban architecture.

Criterion (vii): The distinctive nature conservation values of Lake Ohrid, with a history dating from pre-glacial times, represent a superlative natural phenomenon. As a result of its geographic isolation and uninterrupted biological activity, Lake Ohrid provides a unique refuge for numerous endemic and relict freshwater species of flora and fauna. Its oligotrophic waters contain over 200 endemic species with high levels of endemism for benthic species in particular, including algae, diatoms, turbellarian flatworms, snails, crustaceans and 17 endemic species of fish. The natural birdlife of the Lake also contributes significantly to its conservation value.

Integrity

The property encompasses all of the features that convey the property’s Outstanding Universal Value in relation to natural and cultural criteria.

Main threats to the integrity of the property include uncoordinated urban development, increasing population, inadequate treatment of wastewater and solid waste, and tourism pressure, as well as a number of other issues. In addition, pollution from increased traffic influences the quality of the water, which leads to the depletion of natural resources. The highly endemic biodiversity and natural beauty of the Lake are particularly vulnerable to changes in water quality, and there is alarming evidence of a growth in nutrients threatening the oligotrophic ecology of the Lake. This oligotrophic state is the basis for its nature conservation value, and action to tackle this threat must be a priority.

The integrity of the town of Ohrid suffered to some extent, as several houses built at the end of 19th century were demolished in order to exhibit the excavated remains of the Roman Theatre. The overall coherence of the property, and particularly the relationship between

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urban buildings and the landscape setting of the Lake, is vulnerable to the lack of adequate protection and control of new development.

Authenticity

The town of Ohrid is reasonably well preserved, although uncontrolled incremental interventions have impacted the overall form of the monumental urban ensemble as well as the lakeshore and wider landscape. These are also vulnerable to major infrastructure projects and other developments.

Concerning the religious buildings around Ohrid, important conservation and restoration works have been carried out since the 1990s. Conservation works on the monuments in the region have been thoroughly researched and documented, but some have impacted the property’s authenticity. The icons and frescoes are in good condition and kept in the churches. The originally residential function of some buildings has changed over time, as have some of the interior outfitting of residential buildings, which were altered to improve living conditions. While reconstructions often used materials identical to those used at the time of construction, new materials have also been used on occasion, which presents a threat for the authenticity of the property.

The Lin church and its context is vulnerable to lack of protection and, inadequately controlled conservation and development. At the western side of the Lake, the support the buffer zone offers to the Lin peninsula and the landscape setting of the Lake is likely to be ineffective as a result of a lack of adequate protection and development control.

Protection and management requirements

The Natural and Cultural Heritage of the Ohrid region has several layers of legal protection afforded by both States Parties. In the North Macedonia part of the property, the protection of cultural heritage is regulated by the Law on Cultural Heritage Protection (Official Gazette of RM No. 20/04, 115/07), by-laws and a law declaring the old city core of Ohrid as a cultural heritage of particular importance (Official Gazette of RM No. 47/11). There is currently no specific national protection for cultural sites located in Albania. The protection of natural heritage is regulated by the Law on Nature Protection (Official Gazette of RM No. 67/2004, 14/2006 and 84/2007), including within and outside of protected areas. There is also the Law on Managing the World Cultural and Natural Heritage of the Ohrid Region (Official Gazette of RM No. 75/10). In Albania, the Pogradec Terrestrial/Aquatic Protected Landscape (PPL) was legally established in 1999 to protect both terrestrial and aquatic eco-systems, and covers the entire area of the property and its buffer zone. The States Parties have also signed several agreements for management and protection of the Lake, for instance the 2003 Law on Protection of Transboundary Lakes. Legal instruments need to be kept updated and implemented to protect the property.

The property is managed and protected through a range of relevant management documents, and an effective overall management plan is a clear long-term requirement. The “Physical Plan of the Republic of Macedonia” [sic] of 2004 provides the most comprehensive long-term and integrated document for land management, providing a vision for the purpose, protection, organization and landscape of the country and how to manage it. In Albania, the management plan for the PPL is of a high-quality, and a Protective Landscape Management Plan was developed in 2014, with the objectives to strengthen management, increase habitat protection and conservation, develop touristic and recreational use, and encourage the development of sustainable agriculture and socio-economic activities. This includes a five- year Action Plan (2014-2019) that aims to start remedial measures through strengthening management and cooperation and improving the legal framework. The Plan proposes to exclude the urban areas and the areas where intensive agricultural practices take place around the towns of Pogradec and Buçimas from the zoning of the protected landscape. To

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this Management Plan has been added a World Heritage Supplement (2017-2027) that sets out systems to strengthen the management of the extended property and its buffer zone. This supplement covers both cultural and natural heritage in terms of threats and necessary actions. These plans need to be effectively implemented and updated regularly. Deficiencies have been noted in the general implementation of urban and protected area planning regulations and plans in both States Parties, which need to be addressed in full.

In North Macedonia, the property is managed by two ministries (the Ministry of Culture and the Ministry of Environment and Physical Planning), via three municipalities (Ohrid, Struga and Debrca), although the municipalities legally do not have the authority to protect cultural and natural heritage. The Institute for Protection of Monuments of Culture and Museums in Ohrid has the authority to protect cultural heritage, and the Natural History Museum in Struga is responsible for protecting movable heritage. The Galichica National Park is authorized to manage natural heritage within the park as a whole, and part of the cultural heritage located within the territory of the Park. The Institute for Hydrobiology in Ohrid is responsible for the continuous monitoring of the Lake Ohrid ecosystem, the research and care for Lake Ohrid’s flora and fauna, as well as the management of the fish hatchery, also to enrich the Lake’s fish stocks. In Albania, a management committee is proposed that is a modified version of the Committee for the Protected Areas. This will consist of representatives of the key government agencies covering both culture and nature, with the National Agency for Protected Areas having a central responsibility in relation to nature conservation matters, and a representative of a citizen’s initiative.

Integrated management of natural and cultural heritage through a joint coordinating body and joint management planning are urgently needed to ensure that both the natural and cultural values of the property are conserved in a fully integrated manner. Given the vulnerabilities of the property related to the development and impacts of tourism, the management requirements for the property need strengthening and new cooperation mechanisms and management practices must be put into place. This may include re-evaluating the existing protected areas, and ensuring adequate financial and human resources for management as well as effective management planning and proper law enforcement. Whilst transboundary management mechanisms are set up on paper, these need to be actively and fully operational, on an ongoing basis, in order to ensure the transboundary cooperation required to secure the long-term future for Lake Ohrid. Adequate budgets also need to be provided, beyond the aspirations set out in the management documents for the property. Effective integration and implementation of planning processes at various levels, cross-sectorial cooperation, community participation and transboundary conservation are all preconditions for the successful long-term management of Lake Ohrid.

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ANNEX 4. MINUTES OF THE FIRST MEETING OF THE TRANSBOUNDARY WATERSHED MANAGEMENT COMMITTEE FOR OHRID LAKE

Watershed Management Committee for the Ohrid Lake

First Committee Meeting January 17, 2020

The first meeting for the establishment of Watershed Management Committee for the Ohrid Lake between the Republic of Albania and the Republic of North Macedonia was held on 17.01.2020 in the premises of the Municipality of Ohrid.

It was attended by members of government and local government representatives of both countries. Representatives of the non-governmental and civil society from Republic of North Macedonia also attended.

The meeting was opened by the Mayor of the Municipality of Ohrid Dr. Konstantin Gjorgjievski who greeted the participants.

Minister Edmond Ademi - Chairman of the National Commission for UNESCO in Northern Macedonia also addressed. He underlined the importance of establishing this Committee as one of the key UNESCO recommendations and wished it a successful meeting.

At the very beginning of the meeting, the Secretary of the National Commission for UNESCO in Albania, Mr. Sokol Gjoka, also addressed the importance of the cooperation between the two countries in order to implement all the recommendations of UNESCO. He nominated the Mayor of Municipality of Ohrid Dr. Konstantin Gjorgjievski to be Chair of the Committee. This proposal was unanimously adopted.

The Mayor of Ohrid nominated the Mayor of the Municipality of Pogradec, Mr. Ilir Xacoli for Secretary of the Committee. This proposal was unanimously adopted.

The following items were also on the agenda of the meeting.

1. Adopting the Rules of Procedure for the Committee

2. Coordinate agendas and approach for WHC/ICOMOS/IUCN Reactive Mission (January 2020)

3. Discuss and priority areas for the joint management for 2020

4. Discuss fundraising options for a joint cross-border project between the two countries and the World Heritage centre/UNESCO

5. Determining date and location for the second Committee meeting.

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Regarding the first point - Adopting the Rules of Procedure for the Committee, Mr. Sokol Gjoka proposed in the Rules of Procedure section that says "Lake Ohrid" to be changed to "Ohrid Region" in order to specify the landscape.

This proposal was adopted by the members of the Committee.

After the first point, there was a proposal from the NGO “Front 21/49” regarding the meetings to be held,to be able to maintain them through digital communication if one is unable to attend them in person.

This proposal was rejected by members of the Committee on the grounds that the seriousness of this body as well as the whole process must be taken into consideration. The Committee would hold meetings twice a year and other members would be duly notified so that they could attend in person.

Regarding Article 16, a representative from NGO “Front 21/49’’ suggested that it should be amended, or added, if one of the organizations / institutions is unable to attend, with an official letter being able to replace it.

This proposal was also rejected by the members of the Committee on the grounds that the decision on the members of the Watershed Management Committee for the Ohrid Lake was made and adopted at a government session and there is no possibility of authorizing other persons as deputy members.

Concerning the second item, the agenda of the UNESCO Reaction Mission was finalized. The UNESCO Reaction Mission visited the two countries at the end of January.

Regarding item 3, a representative of the NGO Front 21/49 commented that the priorities of this newly formed body must be the 2017 UNESCO recommendations and pay particular attention to them.

Item 7 discussed the financing of future projects between the two countries in relation to Lake Ohrid Conservation.

The next meeting of the Watershed Management Committee for the Ohrid Lake discussed under item 8, the members of the committee decided that it would be at the end of May / beginning of June in Albania.

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