The region Emine-Irakli is one of the last nine wild areas along the Bulgarian Black Sea coast with preserved nature, survived from the construction, which has taken over almost the entire coastline.
In 1994 a small protected area is declared, including the south part of Irakli beach and further south towards Emine cape, a total of 42.3 ha. The whole area Irakli - Emine is taken inventory of and defined as a draft-NATURA 2000 zone.
Updated: 31.08.2015
The region Emine-Irakli is one of the last wild areas along Bulgarian Black Sea coast with preserved nature, survived from the construction which has taken over almost the entire coastline. The site is protected area of NATURA 2000, and a part of it is protected area as per the Biological Diversity Act. Moreover, during the last nine years, Irakli has turned into a symbolic place for the civil movement in Bulgaria. Although on the territory of Nessebar Municipality there is no other beach with preserved nature, valuable river habitats and forests, here also surface a number of “investment” appetites and intentions, which would transform the exceptionally preserved natural heritage of Irakli into another seaside resort and concrete megapolis.
The plans envisage construction of the sole estuary and neighboring dunes, as well as the deserted agricultural lands on the terrace of the riverside and adjacent hills. This would lead to destruction of priority habitats and species in contradiction with the law and the public interest.
Nature protection value
According to European Commission, the zone Emine – Irakli is of significance for reaching the necessary coverage for a number of important habitats and species on the territory of the whole country or within the boundaries of the Black Sea biogeographic region. One essential part of them is meant for protection and is included in the Biological Diversity Act (Attachment 1). It includes estuaries, reefs, annual plants on coastal deposits, steep coastal cliffs, rife with endemic species, nascent mobile dunes, white-sand dunes, semi-natural dry grass and bush species on limestone, wet habitats of orchids, underwater or semi-underwater sea caves, Eastern forests of downy oak, riverside mixed forests, Pannonic, Balkan-Pannonic Turkey and Sessile oak forests, Western Pontic beech forests. In the zone can be found also a number of species from Attachment 2 of the Biological Diversity Act: Rosalia longicorn, Pontic shad, Alosa maeotica and Alosa tanaica (both known as Black Sea shad), Balkan Loach, European fire-bellied toad, European pond turtle, Hermann's tortoise, spur-thighed tortoise, four-lined snake, leopard snake, Eurasian otter.
According to the criteria of the European Commission, the site is of importance for reaching the necessary coverage of the following habitats and species for the Black Sea biogeographic region: around 50% of the coverage of Eastern forests of downy oak, around 20% of the coverage of annual plants on coastal deposit, around 10% of the coverage of reef habitats, steep coastal cliffs, rife in endemic species LImonium, Balkan-Pannonic Turkey and Sessile oak forests, around 5% of the coverage of habitats nascent mobile dunes, around 10% of the population of four-lined snake. The site is farthest north known habitat of leopard snake and one of its two known habitats in the whole Black Sea biogeographic region.
The region Emine – Irakli is one of the three coastal regions in Bulgaria, where the thermophilous oak forests form a long non-fragmented area of coastal habitats. This is the only place in Bulgaria, where the habitats of white-sand dunes form a habitat with thermophilous oak forests, in this case with Balkan-Pannonic Turkey and Sessile oak forests. This is one of the two sites along Black Sea coast, where habitat Eastern forests of downy oak reaches the coastal regions and joins habitats under code Steep Coastal Cliffs, rife with endemic species and/or annual plants thriving on coastal deposits. The site represents the last land point of the mountain chain Stara Planina – long mountain chain of 700 km of forest and mountainous bio-corridors and at the same time barrier cutting Bulgaria along the middle. The region is an important stepping stone bio-corridor along the coast of the Black Sea for the thermophilous fauna: four-lined snake, leopard snake, Hermann's tortoise, spur-thighed tortoise and other species along the migration barrier in the direction East-West of Stara Planina. The populations of Hermann's tortoise, spur-thighed tortoise are endangered on the territory of the site and have dwindled considerably as a result of their intensive food gathering, practiced in the past. Despite that, their habitats at present are in a good condition and there are excellent conditions for the recovery of the two species. The site is one of several of the kind in Bulgaria, where the otter still lives by the coast in rarely visited cliff coastal sections. Along the riverside of the small river in the central part the zone Irakli – Emine are created specific conditions, so that alluvial forests with rare characteristics can be monitored.
Threat
In 1997, after the procedure of the Environment Impact Assessment (EIA), the Territorial Management Plan (TMP) of Nessebar Municipality is approved. It envisages the construction of Irakli resort complex in the zone of Irakli beach on a territory of 75 hectares of agricultural lands. The EIA report which gives justification to the plan of the Minister of the Environment, does not contain a single word about the existence of CORINE biotopes site or of protected habitats in the region. Till 2005 there is not a single step or investment intention on execution of the plan. An overall detailed master plan of the planned in 1997 resort zone is not initiated either. Meanwhile the overall indicators on construction in Nessebar Municipality, approved in 1997 by the Ministry of the Environment and Water, have long been violated. According to the then-approved TMP of the municipality, not more than 1100 hectares of agricultural land and forests are envisaged for construction, with not more than 20% density of construction on them. On the whole in the Municipality, these indicators are utterly violated with the appearance in the last years of the mega-elite complexes type Manhattan in the zone from Nessebar to Eleni.
Despite everything, in 2005 the owners of abandoned agricultural lands near Irakli beach deposit in the Regional Inspectorate of the Ministry of the Environment and Water in the city of Burgas a number of requests for assessment of the necessity of EIA for construction of hotels and villas. This type of construction proposals and development in the region as a touristic complex continue to be deposited in the institutions even today – the last investment proposals for which there is information as per the Access to Information Act included more than 6 properties with envisaged construction consisting of over 40 “single-family houses”, hotels, parking lots, stores, and others by the firm Emona 2000.
Many other proposals for the region of the Natura 2000 zone can be found appearing now and then on the site of the MEW. Most of the proposals are broken into small parts, so that each one is less than 10 decares. This is the threshold as per Art.92, par. 1 and Attachment 1, item 37a) of the Environment Protection Act (EPA) under which the Environment Impact Assessment (EIA) is not mandatory. Thus presented the information, the necessity of EIA for each investment proposal for construction is reviewed (as per Art.93, line1, item1 and Attachment 2, item 12 of EPA) by the Director of the Inspectorate separately. One can suspect that like in 1997, now too some of the investors have “forgotten” to mention in their paperwork the existence of protected habitats under Attachments 1 and 2 of the Biodiversity Protection Act (BPA). For all of these proposals the Director of the Regional Inspectorate decides that EIA needs not to be conducted. If accidentally the practice of deciding according to EIA is applied, then the fact that the investor will choose and provide the funding for the “scholar” on the environmental impact assessment predetermines the outcome. So far, the Directorate of RIEW - Burgas has systematically refused access to the documentation, with which are taken coordinated decisions, in defiance of the number of written enquiries based on the Environment Protection Act, which reflects in its ecological information part the Aarhus convention and the corresponding European Directive.
Vulnerability of the protected zone to touristic construction.
The main threat at the present moment is the plan for development of the new seaside resort Irakli, situated on the territory of the only estuary and its adjacent dune habitats. The plans envisage construction on the abandoned extensive agricultural lands on the terrace of the river and on the nearby hills. The territory between these lands and the adjacent thermophilous forests and dunes is an important habitat of the species living in this area - four-lined snake, leopard snake, Hermann's tortoise, spur-thighed tortoise. The construction will annihilate immediately these habitats and can lead to considerable fragmentation of the region. Moreover, the sole estuary of this place and the whole of the riverside vegetation and the habitats of the species that go with it - European pond turtle and otter will be destroyed.
The re-establishment and support of extensive agricultural practices in the abandoned agricultural lands (pasture, extensive vineyards and gardens), and not their building-up, is of huge importance for the protection of basic habitats for species as leopard snake, Hermann's tortoise, spur-thighed tortoise, and others.
Law Violations
The coordinated decisions for new construction in the zone of Irakli beach issued by the Director of RIEW-Burgas are in harm of the public interest, and are in direct violation of Bulgarian legislature. In the first place, with the decision not to be performed EIA on construction for lots under 1 ha, the requirements of Art.93, par. 4,item 1 of the Environment Protection Act are ignored. The Director of RIEW had to take account of the cumulative effect when there is more than one investment intention and in connection with the threshold of 10 decares indicated in Attachment 1, item 37a of the EPA to require EIA for every following proposal, which together with the preceding ones exceeds this threshold. Moreover, according to Art.93, par.4, item 3 of the EPA, he had to require EIA also for all investment proposals for construction, regardless of their territorial scope, if they relate to: protected by law territories and habitats; mountain and forest areas; wetlands and seaside zones. Such is the case with Irakli – a seaside zone, it has wetlands – estuary of a small river and the river itself, there is a riverside forest and the agricultural lands are surrounded by forests. There are protected habitats, and for that probably RIEW was not informed by the investor.
With these coordinated decisions the Director of RIEW-Burgas violates the engagements that Bulgaria took at the EU membership negotiations for protection of potential NATURA 2000 sites by means of all necessary administrative measures, since he has not taken account the existence of natural habitats of conservational value and of habitats of species in potential NATURA 2000 site. Their impairment endangers with impairment the protected zone, the entirety of the network and with non-performance regarding Bulgaria’s obligations to submit till the date of its membership in the community a complete proposal on NATURA 2000. These obligations of Bulgaria are directly bound also to the obligations towards the Council of Europe and the Bern Convention. A detailed description of the framework of these obligations is given as an attachment.
The violations of Bulgarian and EU legislation on the part of the “investors” attempting to implement construction on the territory of the area are permanent, some have already been tried and convicted for destruction and re-cultivation, some have been levied a distrain or have been sanctioned by the Ministry of Public Works for violations, but on account of the permanent appetites for construction in the protected area and unsatisfactorily functioning state the civil society has to be vigilant all the time and to protect the nature of the remaining wild beaches.
The first six years of the campaign
In May 2006, hundreds of letters were sent to the Ministry of the Environment and Water calling for official stopping of the construction in Irakli based on NATURA 2000. There are various protests in Sofia, Stara Zagora and Varna, and counter-protests by owners and “investors” on the land of the village of Emona. More than 30 non-governmental organisations and informal organisations in the coalition “Let Nature Remain in Bulgaria” initiate mass street processions for nature protection. In 2007 after Bulgaria’s accession to the EU, the territory is supposed to be under the protection of NATURA 2000, but the Government delays the processing of the documentation on Irakli with a few months. In July 2007 after a flooding in the Municipality of Nessebar, one of the “investors” in the region destroys the river of Vaya, felling the trees in the protected riverside forest – a habitat of tens of protected species and raises a dike. The lot of Swiss Property is situated in immediate vicinity. In October 2007 without EIA and assessment of the impact on NATURA 2000, Swiss Property begins greenfield illegal construction and sale of apartments. This provokes new protests. On January 30, 2008, the regional department of the Ministry of the Environment and Waters issues an order for stopping the unauthorized construction of a hotel by it. On account of the estuary and the river of Vaya with its adjacent forests, after an appeal for “Saving Irakli”, EC initiates a punitive procedure against Bulgaria, the requirement to the Bulgarian Government being to re-cultivate the bed of the river and to remove the dike, which was built illegally by the Municipality of Nessebar and the investor; Instead of initiating a procedure for re-cultivation of the protected area, the regional department of the Ministry of the Environment and Water issues a decision on December 19, 2008, with which coordinates the construction of the hotel after conducted procedure as per Art. 6 (3) of Directive 92/43 after construction has already begun (in violation of this article, which requires the impact of a project to be assessed before an activity is conducted and before it is authorized). A long judicial procedure is initiated with an appeal submitted and conducted by the Bulgarian office of WWF Danube-Carpathian Programme. The final decision at the highest instance is from July 2012. It declares the construction illegal. The fight with the illegal construction by the offshore firm continues for six years till in 2012 SAC declares illegal the construction activities and orders the project of Swiss Property to be removed, and the region recovered. New investment proposals continue to be submitted regularly to the institutions and the municipality.
More on Irakli:
A complete recap of the first six years of the campaign “Let’s Save Irakli”
Full chronology of the civil campaign for saving of the wild beach Irakli
The information is updated in February 2016, and is supported also by the projects “Participation for Nature”, which is funded with the financial support of the NGO Program in Bulgaria under the European Economic Area Financial Mechanism 2009-2014. The project is conducted by Bulgarian Biodiversity Foundation in partnership with Za Zemyata (For the Earth) Environmental Association and BlueLink information network.
Gallery: Parents and children in Stara Zagora took part in a creative way in the national protest “The Mountain and the Sea are in the Heart”
http://forthenature.org/gallery/385
Gallery: First protest for the protection of nature since the National Liberation stirs Tryavna (29.01.2013)
http://forthenature.org/gallery/383
Gallery: Thousands turn out in defense of nature again (17.1.2013)
http://forthenature.org/gallery/382
Gallery: LET’S SAVE IRAKLY FROM THE REMAININGS OF THE SEASON
http://forthenature.org/gallery/298
Gallery: Clean-up of Irakli May 22-24
http://forthenature.org/gallery/158
Gallery: Clean-up of Irakli May 22-24
http://forthenature.org/gallery/161
Gallery: Protest in front of the Parliament without Members of Parliament 19.12.2008
http://forthenature.org/gallery/106
Gallery: The Committee on Petitions in Sofia 30.10.2008
http://forthenature.org/gallery/100
Gallery: Speak up for nature
http://forthenature.org/gallery/93
Gallery: Appeal for Irakli
http://forthenature.org/gallery/39
Gallery: Kiss for Irakli
http://forthenature.org/gallery/38
Gallery: Irakli..Where is the river, where is the forest?
http://forthenature.org/gallery/37