Jamsil Woosung, Jayang 7 to press ahead with reconstruction despite sunset deadlines

A growing administrative consensus is taking shape in Seoul that urban renewal zones actively moving forward should not be dissolved simply because they missed a statutory sunset deadline — a shift that is also expected to ease the procedural burden on projects that had been rushing to file implementation plan approvals before the clock ran out.

According to industry sources, the Seoul Metropolitan Government has decided to keep the Jayang 7 zone in Gwangjin-gu alive and continue the project rather than dissolve it when its sunset deadline arrives Monday. The zone received its association establishment approval in October 2021 and has had its deadline extended once, but has yet to file for an implementation plan approval. It is currently revising its renewal plan to expand the zone's boundaries.

Under normal circumstances, association-led renewal projects that fail to advance to the next stage by the legally set deadline become subject to sunset dissolution. The Jayang 7 association had feared exactly that outcome, but the Seoul Metropolitan Government said it would weigh the overall progress and viability of the project before deciding whether to dissolve the zone.

Because the plan revision process is genuinely under way, the association can continue that process without having to extend the existing deadline again or rush to file an implementation plan approval based on the current, unrevised plan.

The association submitted a revised renewal plan last year and this year completed public notice, a residents' briefing and a consultation with the Gwangjin-gu council. It is now working through the steps required to bring the plan before a Seoul Metropolitan Government review committee.

"This is a measure to minimize unnecessary administrative procedures and waste," said Lee Ji-won, head of the Jayang 7 Reconstruction and Renewal Association. "It is the result of demonstrating that the project is progressing normally."

A similar approach was taken earlier at the Jamsil Woosung 1, 2 and 3 complexes in Songpa-gu. Jamsil Woosung's once-extended sunset deadline passed in June before the association had completed its implementation plan approval filing. The association explained to Songpa-gu that the project was moving forward normally — including through an integrated review process — and the district did not initiate separate dissolution procedures. The project has since continued on its existing track.

The approach stands in contrast to projects that scrambled to file implementation plan approvals based on their existing renewal plans just to beat the sunset clock.

The Jeongbichang Jeonmyeon 1 zone in Yongsan-gu filed for implementation plan approval using its existing renewal plan in order to meet the deadline, while separately pursuing a plan revision. When a renewal plan changes after an implementation plan approval has already been filed, the project must go back and revise the implementation plan to reflect the updated design — meaning sites that filed early to beat the deadline can end up repeating the same administrative steps for the same project.

That dynamic is expected to change, however, as the Seoul Metropolitan Government has signaled in successive cases that projects demonstrably moving forward do not need to file a pro-forma implementation plan approval simply to avoid sunset dissolution.

A similar determination has reportedly been made for the Jeonong 12 zone in Dongdaemun-gu. That zone received its association establishment approval in January 2022, had its deadline extended once, and must now file for implementation plan approval by Jan. 13, 2027.

"We received an official communication from Dongdaemun-gu indicating that, given the current state of the project, the zone is not subject to sunset dissolution," a Jeonong 12 association official said. "We do not plan to seek a separate deadline extension or file a preemptive implementation plan approval."

The decision reflects the fact that the association has been advancing follow-on administrative steps — including filing for an integrated review as it prepares the implementation plan — and has recently begun procedures related to contractor selection.

Not every zone that misses a sunset deadline will automatically be allowed to continue, however. The Ministry of Government Legislation's interpretation also makes clear that each case must be assessed individually, taking into account the project's progress, the reasons for any delay and its prospects going forward.

"Given that the purpose of urban renewal is to improve deteriorated residential environments, it is not reasonable to dissolve zones across the board, including those delayed by unavoidable circumstances," said Kim Je-gyeong, director of Tumi Real Estate Consulting. "The sunset system was introduced by the Seoul city government in 2012 and has been applied mainly to associations established after that point, which has raised longstanding fairness concerns relative to older associations."