Coalition 'Let Nature Remain in Bulgaria' declared participation in the meeting for establishing a consensual solution for the concession for the ski zone Bansko in Pirin National Park

1. From the Ministry of Regional Development and Public Works to make the
publicly available and present us with a working copy of all documents
related to the construction of all facilities on the territory of ski zone
Bansko, including but not limited to: a list of all sites in the ski area,
Detailed Site Development Plan, visas for designing, building permits,
usage permits for the facilities, cadastral map of the village of Bansko
and especially the part on the territory of Pirin National Park, cadastral
registers and data for each of the sites built in Bansko ski zone, the
documents of State ownership of the park and all buildings and facilities
in Bansko ski zone and all other documents which are relevant for assessing
the execution of the concession contract.

2. From the Ministry of Environment and Water Resources to make public and
to present us with a working copy of all documents related to the
construction of the territory of all objects of Bansko ski zone, including
but not limited to: a list of all sites within a ski area with information
whether or not they are included in the annexes of the concession contract
and management plan of Pirin National Park, Evaluation of Environmental
Impact (EEI) and environmental assessment, coordination letters under the
Protected Areas Act (PAA), letters / decisions pronounced on the EEI / EC;
letter / decision-rule under the BDA, PAA minutes of subsequent control
over the implementation of decisions by the EPA, BDA, PAA, minutes of
control of the concession agreed annual investment programs, permits for
water use and use of water bodies and annual reports for the used water
quantities, reference to the inspections carried out by the EEA, Regional
Inspectorate of Environment and Water Resources, and DB on the components
of environment and relevant protocols, acts of state-owned buildings and
facilities owned by the Ministry within the ski area, integrated plan for
the development of the ski area under concession contract, acts of
administrative violations in the ski area, penal provisions specifying the
details of the identity of the doers, the type of penalties that are in
force, the amount of the sanctions and all other documents which are
relevant for assessing the performance of the concession contract and
deposited in MEWR development projects for ski area in Pirin National Park.

3. From the Ministry of Tourism to make the public and our present us with
a working copy of all documents related to aid for the implementation of
tourist activity in the concessioned area, orders of categorization ski
tracks, orders for categorisation of the complexity and the safety of ski
slopes in the ski area Bansko, documentation deposited by Ulen AD under
these procedures, reference of the categorized sites with accommodation
and number of beds available in Bansko.

4. From the Ministry for Sports to make public and to present us with a
working copy of all documents related to financial aide provided from the
budget for international sports competitions and training programs for
children "Learn to ski" in the ski area of Bansko.

5. From the Bansko Municipality to submit a working copy of all documents
related to the constructions on the territory of all objects of Bansko ski
zone, including but not limited to: a list of all sites in the ski area,
all construction documentation and permits for the placement of objects ,
DDP, data for performed categorization of resting facilities in the town of
Bansko, the views and municipal projects concerning the development of the
ski area above the town of Bansko.

6. From Ulen AD to present a working copy of all documents related to the
construction on the territory of all objects of Bansko ski zone incl. those
mentioned above, as well as information in Article 8 of DK on preserving
preferential prices for ski passes, a reference for all paid royalties by
years, contracts for joint operation of facilities, all contracts with
third parties or companies having ownership in the ski area and influencing
the amount of the annual concession fee, for example the price of rental
cars owned by "Marengo Trading" LTD by years, the capacities of the
facilities, a list of the ownership of "Ulen" AD in the ski area, data for
all discounts on ski passes, data from the system SKI DATA for all visits
by years, information about the cost of the passes by year, data of joint
usage with third parties of buildings and facilities in the park, a
comprehensive development plan and investment program, the insurance
policies on the area of concession by years, data on disputes between the
granter and the concessionaire, if available due to different
interpretation and implementation of the concession contract under the
provisions in art. 23 and 24 and any other documents concerning the
contract for the concession, as well as plans and projects of the company
for the development of the ski area.

7. From the Ministry of Economy to present data on employment, number of
available beds per year for the town of Bansko, generated profit by
economic sector, to make public and to present us with a working copy of
all documents related to aid for the implementation of tourist activity on
the territory concession rendered by the MEET and orders to categorize
tracks issued by the Ministry of Economy, Energy and Tourism, including the
Court of Auditors and the National Revenue Agency regarding the
implementation of the concession contract or deposited in the Ministry of
Economy.

The above information will fill gaps identified by the Task Force in its
report and the draft of the Council of Ministers, namely:
- There are no "at least the spatial position and the limits of lying on
the concession area ski slopes, ski trails and the servicing lifts, cable
carts and other facilities and sites of tourism, sports and technical
infrastructure, as well as movable objects located on the concession area,
incl. adjacent areas and statutory easements in accordance with applicable
law "
- The undetermined "types of sites and adjacent territory"
- The undetermined "technical, quantitative and qualitative characteristics
of objects"
- There is a lack of available "evidences of property rights on objects,"
including no evidence of "bringing these objects as asset - state property"
- There is no detailed development plans for the sites.

In preparation for our participation in the meeting, we expect to receive
from you within a reasonable time also a list of invitees, agendas and
regulation on our participation.

With this letter we indicate a list of attendees from the Coalition "For
the Nature" in Bulgaria: eng. Toma Belev, Eng. Alexander Dunchev, Lyubomir
Kostadinov, Lyubomir Popyordanov, Andrey Kovachev and Andrey Ralev, Denita
Zarichinova.

With respect,

Toma Belev
Chairman of Association of Parks in Bulgaria

Andrey Kovatchev
Board member Wildlife Society Balkani

Lyubomir Popyordanov
Chairman of Bulgarian Association for Alternative Tourism
Sofia 2.03.2016.