To: Mr. Erik Meijer
Member of the Green party in the
European Parliament

SUBJECT: WRITTEN QUESTIONS TO THE COMMISSION CONCERNING THE RECONSTRUCTION, EXTENSION AND DEVELOPMENT OF SOFIA AIRPORT PROJECT

Dear Mr. Meijer,

We would like to thank you for your interest in the environmental issues related to the Sofia Airport project and that you have addressed the Commission with detailed questions. We consider Mr. Barnier's answers on the behalf of the Commission to your questions unsatisfactory and would like to express our comments on them.

1). Mr. Barnier says that "in all such developments a balance has to be struck between the need to improve airport infrastructure and the potential effects on the local environment and population". According to us the improvement of mobility and the encouragement of the economic development is not under question. But if we really want to find the balance this means that large infrastructure projects should be implemented on the base of obligatory general rules and standards for nature protection and residents' health protection, which is not made in the Sofia airport case.

2). The Bulgarian authorities have never submitted the full text of the Environmental Impact Assessment final report to the Commission and in fact it has never been translated into English. We were told by the airport authorities that they have submitted to the Commission only 10 pages non-technical summary of the EIA report for LOT1 - new terminal and related facilities and 10 pages non-technical summary of the EIA report for LOT2 new runway system and related works. Thus, the Commission could not have real vision about the quality of the EIA report. Further more the both mentioned EIA reports do not assess the cumulative negative affects of the all airport facilities on the environment and on the population, which is definitely not in compliance with the Council Directive 85/337/EEC as amended by the Council Directive 97/11/EC. On the other hand, it's not in compliance with the Bulgarian legislation on EIA too.

3)Mr. Barnier stated that "NGO and local people concerns were incorporated in the development consent procedure" . We are absolutely sure that the EC is not at all aware neither for the protocols from the public consultation, nor for the statements of the NGOs and they have never been translated into English. In fact NGOs and local people are those who have raised numerous times their concerns and standpoints in front of the Bulgarian authorities but with no result. We could translate and provide you with the above-mentioned documents to show you that public comments are not incorporated in the development consent procedure.
The following story is a perfect example how "incorporated" requirement for public control over the project development actually took place. Point 19 of the Ministry of Environment and Waters Decision on the EIA report says that an Action plan for public control must be developed. Such a Plan was developed but in practice it is not implemented at all. The Plan contains the responsibilities of the airports administration and Bulgarian authorities. The plan foresees full monthly information about: the implementation of the project by each stage, the implementation of each condition of the Ministry Decision, levels of noise pollution, increased control over the flights over populated areas. Another condition is the performance of every month meetings among authorities, majors of the near by municipalities and a representative of the Initiative Committee of the citizens of Sofia against Sofia airport for discussions and solving the problems that arise during the implementation of the project. This Action plan is signed on the 30th of April 2002 by the Minister of transport and communication, Vice Minister of environment and waters, Executive director of Sofia airport, majors of "Poduene", "Slatina", "Kremikovtzi" and "Vrajdebna" municipalities and the representative of the above-mentioned Initiative Committee. NGOs are not allowed to attend these meetings. So far, only ONE of the foreseen meetings was performed because the Bulgarian responsible authorities don't attend them. There is no actual information about the implementation of the project in the information centers of the municipalities.

4). The same above mentioned Initiative Committee started a case in the court against the negative effects of Sofia airport. According to the Bulgarian legislation while a court case is running the construction works cannot start. On the 22nd of October 2002 the construction works on the airport project started although the court has not made a decision, which automatically means that the construction works are illegal.

5). Mr. Barnier's comments notes that "safeguards are put in place to ensure that the legal requirements, especially with regard to the environment, are fully met by the beneficiary". What exactly means "safeguards" and are they really present? What are the conditions under which financial assistance is granted, which Mr. Barnier mentions in his answers, as we were never told about them?

We would like you to pay once again attention to the contradictory issues - flights over the city of Sofia and the night flights. We are constantly told that they are prohibited and in the same time we constantly witness a violation of these prohibitions.

We want to assure you that you could refer to us for any further information and clarification. We really appreciate and rely on your commitment for cooperation and hope our joint efforts for achieving implementation of the environmental standard in Sofia airport extension will continue in future.

Sincerely yours,
Keti Medarova
Za Zemiata/CEE Bankwatch Network