The main manipulation in the statements of Yulen Jsc, also adopted in the position of MEW is that the contract has 3 figures and 3 areas that do not coincide. According to us, there is no discrepancy, the smaller areas are part of the larger ( a logical ratio, a part to the whole, an elementary logical conception). The aim of the Ministry is to explain why part of the facilities and sites built by Yulen Jsc are outside of the concession area - the area under the assessment of environmental impact, the area defined by the Structural Plan of the territory and The Management Plan of Pirin NP and the area under concession is 99.55 ha. The Ministry of Environment and Water aims to conceal the guilt of Yulen Jsc and their own, because they have allowed the construction of facilities and sites outside the concession and in the public land in Pirin NP.
What do these 3 figures mean, where do they come from and why have they become an obstacle for Yulen Jsc?
99.55 ha – The maximum area of all ski tracks, ski lifts, facilities, car parks, etc under Article 1.1 of the concession contract between MEW and Yulen Jsc. This area is included in the graphic map as a maximum territory allowed for proper use in compliance with the Structural Plan of the territory of the rural area “ Ski zone with central point Bansko”. This Structural Plan of the territory is approved by the mayor of Bansko municipality ( Order № 09-13 , 1st March 2001 – check below).
The Bansko ski zone concession contract allows only this territory to be deforested, used and facilities and buildings to be erected.
100, 31 ha – the sum of the area of all ski tracks, ski lifts and facilities in The Structural Plan of the territory (2001 year). It contains a graphic map of all allowed sites and the area they can use. Pay attention to the figures below, “Balace of the territory”
8 ski facilities – 15.39 ha
9 ski tracks for alpine disciplines – 80.67 ha
10 ski tracks for ski run – 4.25 ha
The sum of the above figures is 100.31 and this area includes the concession area – 99.55 ha. According to Article 1.1 of the concession contract the facilities of Application 1 in the contract are included and some of the facilities in Application 2 are excluded. In other words, 99.55 ha is the area that can be used by the concessioner and the area of 0.76 ha is an opportunity for other owners to use this land.
818.46 – is the territory inside Pirin NP, enclosed by 252 coordination points as an outside border in Application 1 of the concession contract and its maximum area is 817.19 ha (in compliance with the judicial and technical expertise - case 7521/2011 of the Supreme Administrative Court) plus 1.27 ha outside the park, an area where the cabin lift and the ski road to Bansko town are built. This is the area of the so-called concession scope, in this area it is permissible to built facilities and sites with an area of 99.55 ha, but in its other part it is territory not subjet to building-up. According to the Structural Plan of the territory 2001, 818.46 ha is a territorial unit with an interference in Pirin NP. It includes forests, lawns, rivers, roads and other territories, as well as the buildings, facilities and ski tracks.
1474.62 ha – the area that has been investigated. This term is used for the scope of the geographic territory used for the preparation of the Structural Plan of the territory. This SPT is only part of the investigated territory, but it is restricted in the area of 1474.62 ha with a red stippled line and this is
obvious from the graphic map of the Structural Plan of the territory. This territory includes the zone around the holiday house of the Council of Ministers and the not-constructed ski track there, the lift Cyrna mogila and others. This territory of 1474 ha includes the area in Pirin NP enclosed by the 252 coordinating points under concession with the size of 817.19 ha, as well as 600 ha forest, which are not included in the concession contract with Yulen. Facilities of Yulen Jsc must not be built in those 600 ha forests, but instead the government can give them for concession to another concessioner (for example for the development of alternative tourism – horse riding, alpinism, etc).
In fact, the pressure that the concessioner Yulen Jsc exerts in order to make an amendment in the text of the concession contract aim to change the area of the concession and to include the area of the whole Structural Plan of the territory , i.e. the 1474.72 ha, not only the 99.55 ha. Some of the built facilities and the newly planned are outside the area of 99.55 ha and even outside the area of 818.46. Such examples are the ski tracks Shiligarnik 2, ski lift Zhelezni most- Platoto, the end stations of ski-lift Platoto and others.
More information about the figures concerning the balance of the territories in Bansko ski zone can be found in the maps of the Structural Plans of the territory of ski zone Bansko from 2001 and 2004, prepared by architect E. Levkov and approved by the municipality of Bansko
The Structural Plan of the territory 2001
The Structural Plan of the territory 2004
Detailed information for the law violations in ski zone Bansko in Pirin NP
Lawful analysis and facts
What do the figures in the position of Ministry of Environment and Water indicate and is there a contradiction in the concession contract of Bansko?
