Environmentalists signal to the Eco-Minister about financial violations in public order “Development of a management plan for Pirin National Park for the period 2014-2023”

The most important examples of the violations cited in the opinion are:
1. “A digital elevation model with an allowance of 50sm in height and horizontally”, as required by the technical documentation, has not been presented. This model is key for the safety of visitors and life-saving actions.
2. Geodesic record of the buildings and the facilities with allowance of up to 3 sm., as required by the technical documentation of the assignment, needed for the cadaster maps, has not been presented in full. Out of 370 buildings, hundreds of kilometers of roads, electric power distribution lines, water conduits, sewerage and 1300 decares of ski tracks, only 42 cites have been recorded.
3. Voluminous and costly data are missing – for example, there is no whatever data about used waters by various users, updated data about climactic factors and analysis of the degree of protection and recovery of habitats, flora and fauna species as a result of the implementation or of not implementation of the envisaged plans and projects.
4. Primary data about forests management is missing, activity which comprises 1/3rd of the project’s total value.

Regardless of the striking omissions and failures, the publishing of the draft project for public discussion means that the Directorate of Pirin Park has approved, and the contractor has received 80% of the size of the contract, including the not fulfilled parts. The public debate, which will be conducted in Bansko on Friday, July 24 will also lead to final payment, and the State will not be able to require the fulfillment of the public order in quality and quantity described in the technical assignment.
The omissions uncovered so far show at best lack of institutional capacity at the Directorate of the National Park to evaluate and accept the public order, which does not exclude the possibility of purposeful and targeted actions for reducing expenses by the public order contractor.
The director of Pirin National Park as a contracting authority is informed and has accepted that the project for management plan allows for and includes:
1) construction of rope lines with length over 1000 meters
2) development and intensive fish breeding
3) development of sports and recreational complexes outside urbanized territories with total area over 20 decares. According to the last variant of the project of the plan, the territory of the park, which can be built up, increases from 0.6% to 73.8% or 123 times.

In this sense, the project of the contractor Proles Engineering OOD doubtlessly “sets a framework for development of concrete investment proposals within the scope of attachment 1 of Environment Protection Act (EPA)”, and as such is subject to mandatory environment impact assessment and assessment of compatibility with the goals of NATURA 2000. According to EPA and Biological Diversity Act (BDA) the environment impact assessment for these plans is done together with their preparation – a requirement which is now violated.
The Coalition reminds that it still has not got an answer in relation to the declared working days of the contractor. Ministry of Environment and Waters and Operative Program Environment were informed in 2014 that a part of the team preparing the management plan for Pirin participated also in the preparation of the management plans for Belasitsa Nature Park, Vitosha Nature Park and some other nature reserves, while the total days which the experts have declared to work on their contracts for 11 months are between 300 and 520 working days outside their regular labor contracts.

The Coalitions pointed out to the Ministry of Environment and Waters also problems in the organization of the public debate, the most important among which are:
- Regardless of the requirements of the assignment, where the contractor has to establish a suitable platform for presentation of commentaries, notes and suggestions electronically, such a platform has not been established.
- The requirement of the assignment “The choice of the place, the date and the hour for conducting the debate have to provide: sufficient time for arrival of the representatives from remote places; sufficient time for utterances; maximum participation of the public;” has not been fulfilled, wheras the contractor has chosen for the public debate a working day and envisages it to last between 10 and 16 o’clock in the town of Bansko. Thus, the low civil participation during the days of open doors in Bansko and Razlog, preceding the public debate, is indicative.

The suggestions of the Coalition to the minister include:
1. Conduct a check of the activity of the director of National Park Pirin Directorate
2. Conduct a procedure for assessment of the need for environmental impact assessment and assessment of the compatibility with the goals of NATURA 2000 of the project for a management plan of Pirin National Park
3. Stop the public debate procedure of the plan till the completion of the check on the violations of the assignment and the contract for implementation of the project, in view of upholding the financial interest of Bulgaria and the EU, which have invested in the development of the project.

There has not been any official reaction from the Ministry yet. In this case, it is its responsibility to protect the interests of the Bulgarian and EU tax payers and to ensure observance of the ecological laws by its structures.