To: Mr. Michel Barnier
/Commissioner for Regional Policy/
Jean-Marie Seyler
/Head of ISPA Unit, European Commission/
Mr. Dimitris Kourkoulas
/Head of the Delegation of the EC in Bulgaria/
Mr. Philippe Maystadt
/Secretary General of the European Investment Bank/
Mr. Peter Carter
/Environmental Coordinator Project Directorate, EIB/
Ms. Yvonne Berghorst
/Senior Information Officer, EIB/
Mr. Erik Meijer
/Euro parliamentary Group of the Socialist Party/
Mr. Erhard Busek
/Coordinator of the Stability Pact for SEE/

SUBJECT: "Reconstruction and Extension of Sofia Airport" Project

Dear Sir/Madam,

We are writing to you because we are seriously concerned about the development of the Sofia Airport project. We would like to summarise the main issues regarding the economic, environmental, health and technical implications of this project. We are aware that the European Investment Bank has not yet disbursed money for project implementation. For the reasons set out below, we ask that your agencies reconsider their support for this dubious project. Its financial sustainability is highly doubtful; it will not contribute to the agreed regional development objectives; and it will not benefit the people of Bulgaria. These funds can be put to much better use.

Economic aspects

The preliminary calculation of a12% Internal Rate of Return (IRR) in the original Stability Pact documentation was later decreased to 3.6% for the terminal and the runway, and without the ISPA contribution it is only 1.5%. The total cost of the project has increased from EUR 186 million to EUR 210 million. Of these funds EUR 100 million are loans to be paid back and more than EUR 60 million must be secured from the Bulgarian state budget.

This situation is totally in contradiction to the Transport Infrastructure Regional Study (TIRS), where it is clearly stated that an IRR of 12-15 % is acceptable, whereas, in over-indebted countries or in countries with limited reimbursement capacity, the actual opportunity cost of capital could easily reach levels of 25 or 30 %, or even higher.

According to the TIRS "For the time being all of the studied airports are suitable for the traffic volumes they attract, and need only in the mid term… to undergo modest improvements and modernisation... Sofia and Sarajevo airports have been reconstructed recently…" The passenger growth studies conducted in 1996 bear no resemblance to the current situation at Sofia airport. Due to privatisation, the air company "Balkan" went bankrupt, and according to the ISPA application form passenger numbers have decreased by 11%.

Construction of the terminal has just recently started in 2003, although no new analysis has been done to verify studies and calculations that now are seven years old. Based on analysis done by independent experts in Bulgaria, we question the relevance of the project now, compared to what was oreseen in 1996 when it was originally designed. Construction of a new runway is unnecessary given that the existing one fully satisfies the passenger flows. There is no valid reason to place the high burden of paying for this unsustainable, unnecessary project on Bulgarian taxpayers.

Environmental and health impacts

A thorough EIA for the whole expanded airport complex was never conducted, nor were alternatives properly assessed and taken into account. The existing two non-technical summaries of the EIA reports for Lot B1 and Lot B2 that were submitted to the Commission and the EIB state: "The Bulgarian Ministry of Environment and Waters has not required, and until now has seen no reason to require, the performance of a full EIA report". Thus, no studies have been done on the real cumulative impacts of the airport facilities, which violates both national and European legislation (Act on Environmental Impact Assessment, EIA Directive 97/11/EC).

The airport is situated in the city of Sofia, very close to communities, and thus poses serious problems for human health, due to the high levels of noise to which the citizens are exposed. According to the Health Risk Assessment Report (HRAR), conducted in addition to the EIA reports, the airport negatively impacts almost all functions, organs and systems of the human body (central nervous, cardio-vascular, digestive and endocrine systems). The report was supposed to show "the actual number of citizens affected by high noise levels living near the airport" and "to determine the sites that are covered by health protection standards within the Public Safety Zone". The experts admitted that meeting those two requirements is impossible because of the lack of a thorough EIA. The conclusion of this report says that the assessment was made based on indirect criteria.

According to the project description, one justification for the extension of the airport is that it will prevent aircraft from flying over the city of Sofia and thus will reduce noise levels. In the Health Risk Assessment Report experts recognise the opposite consequence - due to traffic growth, the number of affected citizens will be increased. Note also that a previous ban of flights over the city of Sofia was consistently violated; therefore citizens are convinced that no one can guarantee these new promises of future prohibited flights. In the determination of the Public Safety Zone, a contour of 60 dB(A) was used for daytime operation. There is no night contour because according to the HRAR no night flights are planned. Note that night flights were previously prohibited for a short time but soon were permitted under a Decision of the Ministry of Environment and Waters from April 2002.

The impacts of the airport on the environment were falsely determined to be insubstantial in the EIA reports. They did not take into account the actual impacts connected with operating this airport. According to the EIA reports there were 61,600 citizens adversely affected by noise during the summer and 81,000 people during the winter of 1999/2000. There are a number of emission sources of atmospheric pollutants (the aircraft gaseous emissions, exhaust gasses from the roadways and parking lots), which will definitely increase due to the growth of air and road traffic. The functioning of the Sofia Airport has serious negative impacts on surface and ground water due to de-icing and anti-icing procedures, there are insufficient facilities to collect and purify wastewater from aircraft servicing, and ineffective functioning of the existing drainage system. There is a threat of direct leakage of wastewaters into the Iskar River, which the new runway will cross via a bridge. The runway and its associated bridge will cross the important Via Aristotelis bird migration route.

Independent ICAO experts and runway planning engineers (signatures below) conclude that the EIA report is not an accurate assessment of threats posed to public health and safety. In this connection one must note the first Ministry of Environment and Waters Decision N12 on EIA of the project for reconstruction of the Sofia airport dated August 10, 1993, which "accepts as the number one priority human health and citizens' safety while the Sofia Airport is in operation." During the past 40 years, there have been 6 airplane crashes and 2 other serious accidents with airplanes in the Sofia region. The same independent experts also have found that the location of the new terminal is inappropriate, bearing in mind that the ground under the existing airport is riddled with old mineshafts, thus making the project's price go higher.

Public participation and access to information

Although many times highlighted, public participation was never really present as this project was developed. NGOs were never acknowledged as an interested party and are not included in the development of plans for environmental protection and mitigation measures. Some of the local municipalities "Vrajdebna", "Poduene", "Vasil Levski" and "Hristo Botev", and affected communities (Initiative Committee for citizens Protection of the Activities of Sofia Airport - IC) were informed from time to time about the project, but rarely were their concerns taken into account. Other municipalities like "Hadgi Dimitar", "Krivina" and "Suha reka", which are also seriously affected by the airport facilities, have never been contacted at all.

We attach a copy of a Declaration from Bulgarian environmental NGOs, signed at the National Conference of Bulgarian environmental NGOs, who conclude that the project for the Extension of Sofia Airport is financially and environmentally unsustainable. That Declaration calls for the responsible financing institutions not to disburse the money and not to allow the project to be implemented.

Bulgarian authorities have signed a Memorandum and a Program for Public Control together with the Chairman of the above-mentioned Initiative Committee and several of the municipalities. Recently, the IC began a court case in response to violations of the conditions contained in both documents. The affected citizens also filed cases in court for not receiving satisfactory compensation for their demolished homes (case pending). They had been promised financial compensation for their land, but recently were compensated only for the portion of their lands included in the Sanitary Safety Zone. The local people were also promised new jobs, but since launch of the construction, none of them has been offered employment.

For all of these reasons, we call upon the European Commission and the European Investment Bank to reconsider their support for this dubious project. The people signing this letter below submit that its cost is higher than its benefits, and that it will further harm local people and the environment while not generating the income stream needed to pay back the loans. We also submit that the way the project has been planned, evaluated and approved has violated EU, EIB and Bulgarian laws and regulations. The issues surrounding the extension of the Sofia Airport affect our livelihoods and future. We demand that you address the concerns we have listed above, and expect to hear from you soon.

Sincerely yours, Keti Medarova, Za zemiata/CEE Bankwatch Network
/project coordinator/

Anelia Stefanova, Za zemiata/CEE Bankwatch Network
/national coordinator/

Petko Kovachev, CEIE/ CEE Bankwatch Network
/national coordinator/

Ivona Malbasic, CEE Bankwatch Network
SEE coordinator

Emil Kolarov, Initiative Committee for Citizens Protection form Sofia Airport Activities
/chairman/

Prof. D-r Simeon Nedialkov
/Professor of environmental studies/

Prof. Pencho Penchev
/President of the Institute for Sustainable Development/

Arch. Pavel Popov
/Municipal advisor, designer and town planning expert/

Arch. Georgi Radonov
/Architect/

Arch. Ljuba Miladinova
/Architect/

Aero Eng. Hristo Zlatanov
/Runway planning and ICAO expert/

Eng. Iordan Kolev
/Navigator and ICAO expert/

Eng. Venelin Hristov
/Runway planning expert/