Vitosha is in danger - The oldest Nature Park on the Balkan Peninsula may become a ski resort

2. Violated procedures:

• The investor has made a project for SPUP in the spring of 2008 in the Regional Inspectorate of Environment and Water (RIEW) in Sofia, without the assignment being approved by the Sofia Municipality and the State Forestry Agency (SFA)


• RIEW Sofia launched an environmental assessment procedure of the project, although it provides for violations of the Management Plan of Vitosha Nature Park, and although there is no project approved by the Sofia Municipality.

• "Vitosha Ski'' AD announces a public consultation on the reports on environmental assessment and evaluation for compatibility with Natura 2000 in October 2008, although there is no approval of the project by the Sofia Municipality. The reports are provided to the public without expert's signatures required by ordinance and with the absence of experts at site. The access is provided at the lower station of Simeonovsko lift.

• The project for developing of SPUP Aleko ski area has been submitted in Sofia not untill January 2009

• The investor claims that he has received the approval of the project with a direct order by the chief architect with ref. № RD-09-50-736/2009. It was requested according to the ''Public information access'' law but it was not obtained. A law suit has been brought for a silent refusal of access to the information. At the internet site of the Directorate of ''Architecture and Urban Planning" of the Sofia Municipality in the section « Orders » and

« Documents » to date there is no such document.

• The most probable reason for this command to be hidden, is the real date on which it was issued.

On May 29, 2009 at a meeting of the Council of Experts in ''Architecture and Urban Planning " the project for the development of SPUP was discussed, and on June 18, 2009 ''Vitosha ski" AD announced the public consultations on the environmental assessment reports. That shows that from May 29 to June 18 (for 20 days) happened the following:

• The project is adjusted to develop a structure plan

• A structural plan itself was developed

• Reports for environmental assessment and evaluation of the compatibility of the plan were developed.

• A law suit has been initiated against the decision of RIEW-Sofia to start the procedure for environmental assessment. Iissuing an official opinion on the environmental assessment and any advance of the procedure would be illegal during an opened case.

3. Already carried out violations of ''Vitosha ski" AD without penalty being taken:

• On the entire stretch of track ''Vitoshko lale'' and in the area of the ''Stone River'', at the foot of the peak ''Malak rezen'', above the lift station "Vitoshko lale", with the use of explosives, a total of 400 stones with dimensions between 0.5 and 3.5 cubic meters are removed and transferred.

• There is a new ski route practically already built at the foot of the ''Malak rezen'' peak.

• Using heavy construction equipment and explosions, stone rivers and grass vegetation in an area of about 18 ha are destroyed. Habitats from the Natura 2000 and ''non-renewable rock formations'' (the so called ''Moreni'') are destroyed.

• In October 2008 a warning was submitted to Sofia City Prosecutor's Office.And in November 2008 new detailed additional evidence were handed over to them.

• On July 20, 2009, eight months later, when checking in the registry of the Sofia City Prosecutor's Office, it became clear that no decision on the prosecutor's case had been made.

4. How the Bulgarian State supports ''Vitosha Ski'' AD:

• Absolute lack of adequate action and reactions by the prosecution

• Ministry of Environment and Water of Bulgaria (MoEW) does not express any opinion on the violations in Vitosha Nature Park from last fall and did not stop the procedure in environmental assessment, despite of the strong controversy with the plan for management of Vitosha Nature Park.

• The previous leadership of SFA has not sought for the charges owed by ''Vitosha ski " AD for the use of state forests. By a letter from the SAF-Sofia, it is clear that the fees for 2008 were paid for the use of state forest fund.These payments are for the period January - April 15, and are amounted to BGN 5005,-

• Fees for use of state and municipal land on which the facilities are have not been paid. Under the Tariff of fees in the SAF, Forestry Act (adopted by Decree № 202 of 11.08.2008), the ''Vitosha Ski'' AD should pay an additional "Fee for placement of temporary facilities and facilities for doing business in the forests and lands from state forests, falling within the resorts and nature parks in the amount of BGN 1.20 per sq.m/day.

• Ski lift "Zaeka" is given for free use by the State Agency for Youth and Sports to the Bulgarian Ski Federation, but it is included in the price of the common Aleko ski card.

• Chairman of the Board of Directors of ''Vitosha ski"AD Georgi Bobev is Vice Chairman of Bulgarian Ski Federation. In 2008-09 years the federation has received public funds from the State Agency for Youth and Sports (SAYS) training children in skiing.

This good idea was vitiated because the Bulgarian Ski Federation assigned ''Vitosha Ski'' AD for the training without the obligatory procedures under the Public Procurement Act.

5. Conclusions and demands:

• The project ''Aleko Ski Area'' is made by ''Vitosha Ski'' AD, which is owned by offshore company with unclear ownership and origin of capital.

• The project ''Aleko Ski Area'' has never been publicly presented, regardless of the requirements of the Law on Environmental Protection.

• Illegal construction has begun "in peaces" in the autumn of 2008 with the plow of the track "Laleto'' and building a new ski route between ''Laleto'' and the so called ''Sinya pista''.

• All this reminds very much the case with the ''Bansko ski zone'' in Pirin built several years ago in a similar way with many violations of procedures and laws. There is a link connecting between the concessionaire of the ski zone Bansko "Ulen AD'' and ''Vitosha Ski'' AD – a common person in the management of both companies.

• The previous government's actions and inactions assisted and tolerated the violations of laws in Vitosha Nature Park. We turn to the new government with a request to terminate the procedures relating to the ''Aleko ski area'' which is presented by ''Vitosha Ski'' AD. We count on the new government to demonstrate their will to meet their intentions to end the abuses of public resources and to to enhance the collection of state debts, and to enforce the laws.

Translated by: Yavor Naydenov