What is missing in Government’s proposal on Bulgarian Black Sea Park

This is probably due to the chosen approach of neglecting consultations in preparation of the proposal during the last year. Some of the most significant lapses are:

1. The applied maps designating the borders of Bulgarian Black Sea National Park differ, which is extremely unprofessional on part of the MEW on account of such an important proposal.
2. The protected area includes properties, which are part of towns and villages and inhabited places, which cannot be established as protected area as per Art. 18 of Protected Areas Act.
3. The proposal contains inexplicable lapses on account of some of the most important ecosystems, biotopes and landscapes on the Black Sea coast: large territories around Irakli, Emona and Kara dere, the shores of Durankulak lake, the dunes on Shablenska tuzla, the steppes at Kaliakra around Balgarevo village, parts of Kamchiyski sands, parts of Pomorie lake, Pasha dere, the lakes Vaya and Mandra, part of Ropotamo, the dunes at Koral, etc. It is quite incomprehensible how a part of a lake or wetlands is protected.
4. The proposal does not include any area of the aquatory of the Black Sea.
5. The proposed ordinance for establishment cites laws and administrative bodies, which were revoked decades ago, and have been nonexistent for over 15 years.
6. The proposal includes also some territories with less natural value or with already damaged landscape – which unnecessarily burden the proposal in terms of total area, and thus allow for potential motives for rejecting the proposal.

Let Nature Remain in Bulgaria coalition thinks that such an accumulation of mistakes and lapses aims but at failing the idea of establishment of a new national park, and is continuation of MEW’s long-term policy for barring the processes of establishment of large protected areas and instigating confrontation in society.
Let Nature Remain in Bulgaria Coalition recommends enlarging the consultation process on announcing the fourth national park in Bulgaria with conducting public debates in Sofia, Plovdiv and Ruse, which are centers of science and academics with high potential to contribute to the process, the motivation, and the scope of the park. This corresponds fully to the decision of the National Assembly – the development of a proposal for the scope and borders of Bulgarian Black Sea National Park to be based on all-encompassing public debate.

Let Nature Remain in Bulgaria Coalition thinks that the public debate should be cancelled and organized again with corrected documentation at a month’s notice.
Let Nature Remain in Bulgaria Coalition thinks that properties falling in populated areas and inhabited places, small separate properties, as well as the territories of natural parks Strandzha and Golden Sands should be excluded from the scope of the future park. The park should include comparatively larger compact and unfragmented territories, protecting complexes of preserved ecosystems and biotopes at Black Sea region.

The existing reserves, maintained reserves, archaeological reserves, protected areas and natural landmarks should serve as backbone to the park, while keeping their borders and regimes. Territories in which construction is prohibited or restricted as property which is not envisaged for urbanizing within the urban plans of municipalities or in which construction is prohibited through normative act as with dunes or forest territories subject to swapping as per the Forest Act can also be added. The park shall also include mostly territories which are state property by law as Black Sea aquatory, lakes, lagoons, firths and wetlands, seaside beaches unused by resorts or inhabited places, sand dunes and islands.

In view of the hard financial situation of the state, Bulgarian Black Sea Park is not to be established as park of national importance, which requires procedures for forced appropriation of non-state property. A program for buyout and compensation of landowners and owners of forests with high natural value, which property to be gradually annexed to the park, should be developed in parallel. The program may be co-financed from EU funds, for which there are existing opportunities.
The state should get back those territories by Black Sea coast, which have been privatized illegally.
Establishment of new protected areas is supported by 75% of Bulgarians, and protecting Bulgarian Black Sea coast from building up – by over 80% of Bulgarian citizens. Boycotting the park idea is not a solution to Black Sea problems. And it is interesting to see tourism business starting to realize that too much construction is not profitable.
Let Nature Remain in Bulgaria Coalition reminds that Bulgaria is one of the countries with least share of its territory included in protected areas – little over 5%. In comparison, 15% of Europe’s territory and 17% of EU’s territory have been under protection. All of the twenty most developed economies have protected at least 1/10th of their territories, and Germany is ahead with having preserved more than half of its territory in protected areas.