3.- Proposed justification for inscription

3.1.- Comparative analysis

ICOMOS does not consider that the comparative analysis justifies consideration of this property for the World
Heritage List. Criteria under which inscription is proposed

3.2.- The transnational serial property is nominated on the basis of criterion (v)
ICOMOS considers that criterion (v) has not been demonstrated

3.3.- Integrity and authenticity.
ICOMOS considers that the conditions of integrity and authenticity of the nominated property have not been met.

3.4.- Boundaries

ICOMOS considers that the proposed boundaries and buffer zone are adequate and are aligned with the legal protection and management system.

3.5.- Evaluation of the proposed justification for inscription.

ICOMOS considers that the comparative analysis does not justify consideration of the nominated property for the World Heritage List, and that criterion (v) has not been demonstrated. Since the criterion for justifying the proposed Outstanding Universal Value has not been demonstrated, attributes of Outstanding Universal Value cannot be identified and the integrity and authenticity (as defined by the Operational Guidelines for the Implementation of the World Heritage Convention) are not demonstrated.

4.- Conservation measures and monitoring

4.1.- Legal protection
ICOMOS considers that that the documentation, conservation measures, and monitoring of the nominated cultural landscape are adequate.

5.- Protection and management

5.1.- Legal protection
ICOMOS notes that it is not straightforward to determine the exact number of individually protected elements within the extensive area of Ribeira Sacra. ICOMOS considers that the State Party could implement more specific local controls on land use and development in the buffer zone, including building heights, materials, density and infrastructure improvements.

5.2.- Management system
A management structure has been established under the Directorate General of Cultural Heritage of the Xunta de Galicia and is coordinated by the Interdepartmental Commission of Ribeira Sacra.

5.3.- Visitor management
ICOMOS notes the well-developed tourism infrastructure and diverse range of visitor experiences that are aligned with the heritage values of nominated property. ICOMOS considers that the nominated property is potentially vulnerable to future tourism impacts and notes the work undertaken by the State Party to develop sustainable tourism for Ribeira Sacra, including actions associated with carrying capacities, traffic congestion, real-time monitoring of visitor flows, and ensuring that benefits flow to communities

5.4.- Community involvement
ICOMOS received information on behalf of a number of local community organisations from the Federación de Asociacións da Ribeira Sacra expressing strong concerns about the nomination. A range of issues were raised including the participation of local communities, the promotion of Ribeira Sacra for commercial and tourism purposes, and water quality and environmental protection problems. The circumstances for the residents of the nominated area are considered to be precarious due to demographic and economic factors, a lack of community infrastructure and conflicts with wine growers. In October 2025, the State Party provided a response to these points. ICOMOS notes the disparate community views about the benefits of World Heritage inscription, and encourages the State Party to continue its engagement actions and to listen to dissonant views.

5.5.- Effectiveness of the protection and management of the nominated property
In summary, ICOMOS considers that the legal protection and management system are adequate, although formal processes for Heritage Impact Assessment should be established. The management plan and sustainable tourism plan provide relevant strategies and actions for the onservation, safeguarding and presentation of the nominated property.

6.- Conclusion

The Ribeira Sacra Waterscape is a large organically evolved cultural landscape with both continuing and relict elements. It has a long history of land uses in the valleys and tributaries of the Miño and Sil rivers, and features steep slopes, micro-plots, agricultural terraces, hydraulic features, water mills and water energy features, as well as elements associated with centuries of monastic practices and intangible cultural heritage traditions. This nomination is the result of a lengthy period of research and development and was substantially revised following the withdrawal in 2021 of a nomination for Ribeira Sacra which was based on a different justification for Outstanding Universal Value, different criteria, and different boundaries.

ICOMOS appreciates the efforts of the State Party to provide heritage designation to this large area and the significant commitments made to the conservation and safeguarding of the cultural landscape. The legal protection and management system developed for the cultural landscape are clear strengths of the nomination, and the State Party and local communities have developed important initiatives for sustainable tourism. However, ICOMOS does not consider that a compelling justification for Outstanding Universal Value has been presented.

he State Party has conceptualised the nominated property as a waterscape in its title and in its promotion to visitors. Whilst agreeing that this is an interesting approach for those purposes, ICOMOS does not consider that the focus on the idea of “waterscape” as part of the comparative analysis and proposed justification for Outstanding Universal Value has assisted in specifically explaining what is distinctive and potentially outstanding about the nominated property.

ICOMOS considers that the comparative analysis does not support the consideration of the nominated property for the World Heritage List. This type of cultural landscape features a range of vernacular characteristics that are not altogether uncommon within the European region. More thorough research is needed to establish that this particular landscape can meet the requirement of criterion (v), to demonstrate that it is an “outstanding example”. In common with the previous nomination for Ribeira Sacra, the nomination presents features of a wide temporal and typological diversity which are all considered to contribute to the potential Outstanding

Universal Value. ICOMOS notes that there are many hundreds of potential attributes in various different typological categories (terraces, water mills, settlements, hydraulic works, etc). It is important to stress that a wide diversity of attributes is not necessarily a determinant of Outstanding Universal Value. Despite the additional information provided by the State Party, it is not evident how they fit together to form a coherent cultural landscape (including the relationships between them and over time), to express the potential Outstanding Universal Value. In addition, ICOMOS does not concur with the arguments made by the State Party about the inclusion of the 20th- century industrialised hydroelectric power stations, dams and reservoirs as proposed attributes. While these elements may be of local or national significance for their 20th-century design and/or industrial characteristics, the argument that they represent an organic evolution and continuity of local water-based energy production from the centuries of water mills and other hydraulic works is not accepted.

While the State Party is optimistic about recent demographic trends, past population decline has led to the loss of some attributes such as the farmed terraces. According to the State Party, the water mills became obsolete in the 20th century, and those that survive serve educational and heritage interpretation purposes.

ICOMOS appreciates that the work to fully revise the nomination of Ribeira Sacra has been energetically undertaken according to a different narrative, justification for Outstanding Universal Value and criteria. Nevertheless, gaps remain in relation to the revised approach.

Understanding the attributes (their location, historical context, inter-relationships and current state and condition) is crucial. For example, given the emphasis on the waterscape and water culture, it is of some concern that a clear analysis of the state of conservation of these elements has not been completed. Also, there is an emphasis on the importance of the intangible “water culture” of Ribeira Sacra, but despite advice about the existence of studies and publications, only brief information is available about these traditions and the communities or individuals that hold this knowledge.

While it is clear that there is a strong willingness by the State Party and its local partners to continue to work on the issues raised in this report, ICOMOS does not consider that the nominated property meets the requirements for inscription set out in the Operational Guidelines for the Implementation of the World Heritage

Convention. ICOMOS has concluded that criterion (v) is not demonstrated, and the conditions of integrity and authenticity are not met. There is a lack of breadth and depth to the comparative analysis and further work is needed on the documentation of the proposed attributes. ICOMOS considers that the nomination does not justify Outstanding Universal Value and cannot be recommended for inscription.
 
7 Recommendations

Recommendations with respect to inscription ICOMOS recommends that the Ribeira Sacra Waterscape, Spain, should not be inscribed on the World Heritage List.

Acceso al documento completo do ICOMOS: [Enlace-Web]