[Exclusive] SH Objects to Deferral of Sewoon 4 District Review: "Resume Deliberation and Disclose Reasons"

SH Protests National Heritage Agency’s Deferral of Preservation Plan
"Validity Cannot Be Denied Solely on Uncertain Possibility of Annulment"
Sewoon 4 District Faces Another Suspension… Re-review Unlikely
Seoul City versus Central Government Conflict Intensifies, Prolonging Sewoon Redevelopment

Seoul Housing & Communities Corporation (SH), a city-run entity under the Seoul Metropolitan Government, has formally objected to the central government's decision to defer the preservation plan for relics in the Sewoon 4 District. SH maintains that, since the project authorization from the competent district office has already been granted, this is not an issue that warrants a review deferral. The standoff between the Seoul city government and the central government regarding development in front of Jongmyo Shrine has been ongoing for several months, with the central government currently conducting a legal review for possible ex officio annulment.

According to the urban renewal industry on September 9, SH, the entity in charge of implementing the Sewoon 4 District project, recently objected to the National Heritage Agency’s decision to put the plan for the preservation of buried cultural heritage on hold, claiming that such a decision is 'contrary to relevant laws.' SH has requested that the agency disclose the specific reasons and criteria for its decision and promptly resume the review process.

The left photo shows the scene in May 2023 when excavation was in full swing ahead of the redevelopment of Sewoon 4 District in Seoul, and the right photo shows this summer's scene where construction has stopped and only weeds have grown. Photo by Huh Younghan

A view of Jongmyo Shrine and Sewoon District 4 in Seoul. Photo by Yonhap News

Previously, the National Heritage Agency decided to defer the “preservation plan for relics within the Sewoon 4 District Urban Environment Improvement Project site” at a meeting of the National Heritage Committee last month. The committee members agreed that a re-review should take place after modifications to the project implementation plan are finalized.

SH protested this decision. In an official objection letter recently sent to the National Heritage Agency, SH explained, "The implementation plan for the Sewoon 4 District project has already been authorized and publicly announced, making it final." SH continued, "The validity of this authorization remains in full force," and further argued that "World Heritage Impact Assessment compliance orders and related administrative litigation have no bearing on the validity of the authorization order."

In Jongno-gu, the competent district, the former head of the district office from the People Power Party announced the project implementation approval for the Sewoon 4 District redevelopment on June 19, just prior to leaving office. The current head of Jongno-gu from the Democratic Party is now reviewing the legality and administrative appropriateness of the approval, but as of now, the authorization still holds legal force. SH has also argued that an administrative disposition is considered effective unless it is annulled by the competent authority, asserting that the existing authorization cannot be denied simply due to the uncertain possibility of future cancellation.

SH has again demanded that the National Heritage Agency disclose the specific basis and criteria for its deferral decision and promptly resume the deliberation process. SH explained that it has complied with all relevant requirements raised at the 2024 meeting of the Cultural Heritage Committee (currently the National Heritage Committee), when it was requested to submit a more detailed preservation plan at a later date.

The preservation plan includes relocating the village gate (Imun) within the relic site to an open area on the east side, and moving ancestral remains (structures beneath the surface) and drainage systems. There is also a proposal to expand an existing space for displaying excavation materials and install the exhibition area on basement level one. These structural plans were agreed upon by the local residents as well.

Due to the recent decision by the National Heritage Agency, the redevelopment of Sewoon 4 District faces yet another suspension crisis. Unless deliberation by the National Heritage Committee and the approval by the National Heritage Agency Chief for the completion of excavation are granted, no construction can commence on the site. For now, the National Heritage Agency must incorporate SH's feedback and initiate a re-review process, but the likelihood of this happening currently appears low.

The National Heritage Agency maintains that conducting a World Heritage Impact Assessment first is a priority. It has officially notified the Seoul Metropolitan Government and Jongno-gu to implement measures necessary for the protection of Jongmyo Shrine and its historical and cultural environment. However, the Seoul Metropolitan Government contends that, as Sewoon 4 District is located 180 meters away from Jongmyo Shrine and lies outside the legally designated preservation area for the historical and cultural environment, there are no legal issues.

The conflict between the Seoul city government and the central government appears likely to drag on for an extended period. In March, the National Heritage Agency reported SH to the police, alleging illegal activities such as drilling at 11 locations within the Sewoon 4 District site without the agency chief's approval. It also requested that the Seoul city government issue a corrective order to cancel the modified project implementation approval for the district and is now considering further follow-up actions.

Recently, it has been reported that the National Heritage Agency also requested the Ministry of Land, Infrastructure, and Transport (MOLIT) to withdraw the approval for the modifications to the Sewoon 4 District project implementation plan. The head of the National Heritage Agency does not qualify as the relevant administrative authority as defined under Article 188 of the Local Autonomy Act. Since the Ministry of the Interior and Safety has designated MOLIT as the supervising ministry for this local administrative matter, the National Heritage Agency intends to induce a cancellation of the authorization through MOLIT.

An industry official in the urban renewal sector commented, "Relevant laws grant the supervising minister the authority to issue corrective orders or forcibly annul approvals, but the Sewoon renewal project ties up citizens’ property rights and relates to numerous urban management issues that require cooperation between the government and local authorities to resolve. Even if the government pushes forward with compulsory enforcement, ongoing lawsuits are very likely, and the Sewoon redevelopment will likely require a much longer resolution period."

Residents of Sewoon District, including the Sewoon 4 District Residents' Representative Council, have protested the government's move to suspend development. The Asia Business Daily

This content was produced with the assistance of AI translation services.