A Chronicle of One Substituted Inspection

Press announcement of Let’s Save Karadere, a coalition of citizen’s initiative.

In relation to nature protection causes, NABBS is the twin of the counter-protests, organized by unknown persons, often through paid participants, with the purpose of misleading the public into believing that the status quo is a just cause. Although NABBS claims it represents small and medium sized businesses, their representatives have not taken part in its events. The initiative of the Ministry of Agriculture and Food begins as a policy for more effective management of forests, then - inspection of illegal construction. It ends preposterously – instead of inspection of illegal construction, the sites where tents are situated are listed.

So, how does it happen that a routine inspection is debased so by an organization, established with the purpose of diverting public attention from the core problems at the Black Sea Coast and in the forests – which are illegal construction, large-scale logging, poaching, arson, and illegal dump sites, in order certain circles to continue building their wealthy complexes, which have nothing in common with sustainable development of tourism?
In order to answer this question, Let’s Save Karadere civil initiative will insist:
• Executive Forest Agency (EFA) to answer the question why only the suggested by NABBS “sites” were inspected.
• EFA to engage with completion of the inspection and inspect the sites suggested for inspection by BBF too. (http://forthenature.org/documents/1002 )
• As per Access to Information Act (AIA), EFA to present copies of the inspections order, protocol of the conducted inspections, signed by all stakeholders, as well as all accompanying documents from the very initiating of the inspections to their findings.
• Regarding the post factum announced goal of the inspection – protection of forests from fires, EFA to answer whether the owners of the forests, private or public, were inspected if had fulfilled their obligations as per Ordinance No8 on the requirements and regulations for protections of forests from fires. What the results of the inspection are.
• In the instance of Karadere, EFA to conduct an inspection of the legality of the procedures for change of use of the forests in the area, which at the moment figures as plots with neighbouring properties, street, yard, a part of an urbanized territory for separate construction.
Free camping is another issue. Let’s Saved Karadere will gladly participate in the public discussions on it – honestly and with real arguments.
Here we present the chronology of how the initiative was substituted and debased by NABBS, and the serious problems left aside:
• On September 20, 2015, Deputy Minister of Agriculture Georgi Kostov presents to environmental organisations the adopted measures for more effective forest management. One of the measures is that mayors have to be notified about planned logging and this information is to be made public. In the announcement to the media uploaded on the site of MAF, there is not a word about camping.
• On September 21, 2015 the so-called National Association Bulgarian Black Sea (NABBS), in distributed announcements to media it has influence on, changes the topic of the meeting and announces loudly the intentions of the institutions for full ban of wild camping. However, it is questionable in what capacity NABBS participated in the meeting of Ministry with environmental organisations and how long institutions and media will close their eyes and legitimize pseudo civil organizations and pseudo civil initiatives.
• On September 24, 2014, Let’s Save Karadere civil initiative sends a letter to MAF and EFA, in which it calls for institutions to disregard the change of the focus of the meeting and expresses readiness for cooperation in relation to eventual measures for restriction of negative practices along the forest territories adjoining the beaches. There has been no response to these letters, as well as no refutation either.
• On October 2, 2014, Let’s Save Karadere civil initiative and seven more organisations – environmental NGOs receive a letter from EFA with information about upcoming inspections of forest strips, adjoining beaches, based on “more frequent illegal camping signals”. In response, Let’s Save Karadere expresses readiness to take part in the inspection with its representatives, as well as to take part in future initiatives on this ussue.
The correspondence ends there – an official notification from EFA for a special inspection, as intended in the initial letter, has not been sent yet.
• On June 26, 2015, only one of the initially notified NGOs – Bulgarian Biodiversity Foundation receives a subsequent letter from EFA. Besides it, the letter is addressed also to NABBS, which does not figure as a receiver in the first letter – probably because it sent the initial so-called “more frequent signals”. The subject of this letter from EFA is: “Illegal construction at the Black Sea Coast”, and the agency requests one of the two organizations to send suggestions for concrete regional sites, which they wish inspected.
• In a letter No ИАГ-24424/14.07.2015, NABBS sends a list with sites where people do wild camping
• In a letter from July 22, 2015, BBF sends a well-grounded suggestion for inspection of illegal construction sites in Strandzha, Irakli and Nessebar Municipality.
• The inspection is implemented in the last week of July 2015, but only the sites from the list of NABBS are inspected! The list of illegal construction from BBF is not checked. The night inspections are conducted in an arrogant and stressful for the people way – who are treated as criminals, without any legal ground.
• An official protocol with the conducted checks with signatures from all who were present is due to be prepared. Available is only a draft document dated July 28, 2015, in which the enumerated findings of the inspection are ludicrously insignificant on the backdrop of the fanned up for the media issue proclaimed “destruction of the Black Sea Coast by wild camping people”.
• The result of the illegal construction inspection is eventually a listing of the sites where tents are situated. On July 30, 2015, EFA publishes in its site an announcement for the media, which is not only incorrect (the term “illegal construction” is fallacious in legal terms and out of the context), and is wholly in the spirit of ordered press announcements by the so-called association in question.
• The order of the executive director of EFA about the inspections, cited in the above mentioned protocol, has not been shown or sent to the stakeholders, and is missing from the site of the agency, where in principle all documents are published.
• The result of the same inspections of MEW, sent as a press announcement to the media on July 31, 2015, is that no violations were recorded and information boards of protected areas were installed.

Let’s Save Karadere