Jean-Marie Seyler,
Member of the European Commission
Head of Unit F2: ISPA and pre-accession measures
Rue de la Loi 200
B-1049 Brussels
Belgium

SUBJECT: Reconstruction, Development and Extension of the Sofia Airport

We are writing to you in regard to the ISPA Monitoring Committee Meeting held in Sofia on the 27th of November 2002, where the issues related to the implementation of the "Reconstruction, Development and Extension of Sofia Airport" project were discussed. We would like to present to you some of our concerns that have not been taken into account by the responsible authorities, so far.

We are aware that the European Commission considers the Environmental Impact Assessment procedure completed and clearly stated at the ISPA Monitoring Committee Meeting held in Sofia that the two EIA reports are in full compliance with the EU legislation for nature protection. We emphasis that the two EIA reports separately assess the impact of the new passenger terminal and the new runway. Thus, they do not show the cumulative effect of the airport's overall functioning of the existing and future airport facilities on the environment and City of Sofia. Moreover, the EIA report was the basis for the development of the Health Risk Assessment, which was conducted in April 2001. The Health Risk Assessment and the recently developed Preliminary Noise Protection Plan were made in addition to the two EIA reports. In the Health Risk Assessment the experts stated that: "any determination of a Public Safety Zone would be possible only if an EIA report for all airport facilities is created, because this is the only way to assess the cumulative effect of all real and potential factors on public health. Thus the health assessment is based upon indirect criteria."
One of the obligatory conditions in the Ministry of Environment and Waters' Decision on approving the EIA report was to develop a Noise Protection Plan, which had a deadline of April 30th, 2002. For some reason, this deadline was changed to April 30th, 2003. So far, a preliminary Noise Protection Plan has been conducted. According to point 7.1 and 7.2 in the MoEW's Decision, this Plan must show the "the real number of over-noised citizens, living near the airport" and "to determine the sites that are subject to health protection within the Public Safety Zone". The experts confessed that the meeting of these two requirements is very difficult because of the lack of thorough EIA. Thus, the data provided by the Districts' Administration differs totally from the expert data, which was used in the Noise Protection Plan. An expert from the Ministry of Health stated that Sofia Airport administration must require the performance of a thorough EIA.
We agree that there are some very positive commitments and efforts for an adequate implementation of the project regarding the requirements for environmental and public health protection. But the facts, mentioned above, once again prove that the lack of a full EIA makes any development activities and efforts senseless.
Other issues that we would like you to pay serious attention to are the access to public information and documentation, public participation and the transparency of the whole process of project development and implementation. We have several times stated that the concerns of all stakeholders are very rarely taken into account by the responsible authorities. As you may remember, "Za Zemiata" (For the Earth) pointed out at the ISPA Monitoring Committee Meeting the violation of these principles as one of the largest problems of the project development and implementation. As a response to this statement Mr. Vladimir Jekov, Sofia Airport administration, announced that on the next day there would be a meeting with all interested parties to show them the Preliminary Noise Protection Plan. Za Zemiata was not aware of this meeting. No other NGOs were invited. A representative of Za Zemiata unofficially attended the meeting. Among other participants were the Mayors of SOME of the most affected Districts, the Chairman of the Initiative Committee to protect the citizens from Sofia Airport, representatives from the Ministry of Environment and Waters, Ministry of Health, Ministry of Transport and Communications, Sofia Airport and the expert group that developed the Plan.
The Mayors of the Districts were sent invitation letters for the meeting, but the Plan's documentation was available to them for only one hour the previous day, thus they did not have the opportunity to submit their statements regarding the content of the Plan. Written statements were submitted only by the General Air Administration, Sofia Airport, Regional Environmental Inspection and the Ministry of Environment and Waters. During the meeting, the Plan was presented by the expert group. Afterwards there were many questions from the participants, which were left unanswered because, according to the Chairman of the meeting from the MTC: "This is an Expert Council, not a discussion". Thus, the conclusion of the meeting was that the expert group must take into account the remarks from the submitted WRITTEN statements. This is one of many examples of how the stakeholders' questions are left unanswered and unexplained, and their standpoints are not incorporated in the project development. NGOs are not recognised as interested parties and are deprived of the right given by the Aarhus Convention to participate actively in public affairs.

We consider that a balance has to be struck between the need to improve transport infrastructure and the potential effects on the local environment and population. For this reason we call for the conduction of adequate studies showing the real impact on public health and consequently ensure that the necessary mitigation measures are undertaken. We insist on strengthening public participation and guaranteeing the access to information of ALL stakeholders during project development and implementation procedures and activities.

Sincerely yours,

Keti Medarova
Za Zemiata(For the Earth)/ CEE Bankwatch Network

Anelia Stefanova
Za Zemiata(For the Earth)/ CEE Bankwatch Network