Reconstruction and extension of the Sofia airport Who will pay the bill?

History

Sofia, the capital of Bulgaria, is situated almost directly in the centre of the Balkan Peninsula, thus placing it in a strategic position as far as transport is concerned. Two Trans European Corridors (TENs) - N4 and N8 - go through Sofia, and the city's airport is part of both corridors. Bulgarian NGOs argue against plans for its expansion, and the concerns about the airport's inappropriate position have a long history. From a technical and economic point of view, future development of this airport is unsustainable. Despite this, a General Master Plan for Reconstruction, Development and Extension of the Sofia Airport was developed by the British Company "Sir Halcrow and Partners" and adopted by the Bulgarian Government on November 12, 1996. The plan calls for the construction of new passenger and cargo terminals and a new runway, and presents two scenarios of levels of service concerning passenger capacity. The total cost of the project varies from USD 162,7 million for the low-passenger scenario to USD 254,7 million for the higher-level passenger scenario. The master plan's Environmental Impact Assessment was conducted and approved in September 1996. Arguments against the airport's existing location and its expansion were raised by local communities and NGOs during the EIA procedure, but were not taken into account. No alternative locations were discussed and assessed in the EIA report.

Despite of the EU environment acquis, the European Investment Bank approved a loan of EUR 60 million in September 1997 before the final project was drawn up. Several months later, in June 1998, additional financing of EUR 40 million came from the Kuwait Fund for Arab Economic Development, followed by EUR 7.6 million from Phare for technical assistance in project planning, design and supervision, and for airport administration. Phare involvement was justified with the argument that "...without Phare participation, providing technical assistance for Sofia Airport, the disbursement of first tranche under the finance contract with EIB will not take place." No final project existed at the time, but the scope of the airport's modernisation plans was decreased. The Phare grant covered only the design of the new passenger terminal and new runway, with the cargo terminal no longer mentioned in project documents. The lower passenger number estimate was chosen and the total project cost was estimated at EUR 184 million.

The development of this supposedly "high priority" project continued at low speed until a new financial supplement from the EU could be secured. In April 2000 the ISPA program approved a grant of EUR 50 million for the project. At that time the extension was still in the design process and the project's final EIA was not yet finished.

Problems

- The EIB is financing a project without assessing any alternative solutions. The airport's expansion creates a long list of environmental and other impact due to its proximity to homes and the Iskar River. Moreover, the ground under the existing airport is riddled with old mineshafts. Still, no alternatives were developed. Even the EIA report says that the present project is a "mono variant solution", which immediately calls into question the quality of the report. According to Bulgarian legislation any EIA concerning an investment project must includes a "zero" alternative. Despite this fact, no zero alternative was developed.

- The EIB approved funds for an undeveloped project. EIB financing, which was allocated before the project was developed, became a leverage for additional investment such as EU grants. It also was an element used by the Bulgarian Government to push ahead with the project without following strict environmental standards. The first EIB loans approved for the Sofia airport were for EUR 60 million in 1993 and 1994 for upgrading the air traffic system (which is part TEN). There has never been an EIA of the whole operations of Sofia airport. The existing two EIA reports assess the new runway the new terminal separately, which denies the public an overall picture of the airport's true environmental impact and makes it impossible to calculate the cumulative level of noise and gas emissions. The EIA report says that "the Ministry of Environment and Waters has not required and until now has NO reason to require the performance of an EIA for the whole facility of Sofia Airport", which is in clear violation of the EIA Directive and Bulgarian legislation on EIAs. Approval of construction under these conditions, without clarifying who will enforce regulations and how they will be enforced, is one of the bad practices in Bulgaria.

- The EIA process for the new runway was initiated in December 2000. The EIA report identified substantial faults in the water treatment system of the new runway and support facilities.

- Another issue not seriously taken into account is the effect of antifreeze procedures on the ground, surface water and soil.

- The new runway crosses the Via Aristotelis bird migrations route, another aspect not considered. This issue also directly relates to the risk of plane accidents. The airport's proximity to Sofia makes this problem hazardous not only for nearby inhabitants but also for the city as a whole.

- The EIA report was approved in April 2001, subject to 20 conditions. During the public hearings, people living in the nearby area (around 1 km) expressed concerns about the noise level. As an adequate study regarding the noise effect had not been conducted, the Ministry of Environment demanded that project approval be conditioned on a Noise Protection Plan to be developed by the Sofia airport before April 2002. For some reason, this deadline was changed to April 2003. The airport administration promises that the project will be open to public discussion.

- There is no real prohibition on night flights between 11pm and 6am. Even now, although flying over Sofia is prohibited, the rule is violated every day. These prohibitions are described in the internal rules of the Bulgarian aviation authority and are listed in the MEW's Decision on the EIA as obligatory conditions for project implementation. Despite these written prohibitions the airport aviation administration refuses to take responsibility for aircraft flying over Sofia, claiming that the pilot is the one who makes the final decision about the plane's flight path!

- The EIA report fails to make a comprehensive assessment of the existing and future environmental problems stemming from the airport's operation, discussing only part of the extension project and even less for the entire airport. As an amendment to the EIA report, a separate study was conducted into the health risks for the public living in a specially determined Public Safety Zone. The study notes that its experts cannot assess the actual health risk because there is no EIA covering the airport as a whole, and the assessment of health risks is therefore based on indirect criteria. The experts state that "the determination of this Public Safety Zone can be possible only if an EIA report for all airport facilities exists, because this is the only way to assess the cumulative effect of all real and potential factors on public health."

- Another partial EIA report was done in July 2001 for the second part of the airport modernisation - the new Passenger Terminal. Although the Deputy Minister of the Environment stated that the report should assess the existing problems and examine the impact of the new terminal, the report did not fulfil that condition. Its assessment of the waste treatment system and the central heating system discovered substantial problems and violations of environmental standards. As with the runway, construction of the new terminal was allowed with numerous conditions.

- Another very important issue is the incinerator operating on airport property. Bulgarian law outlaws the import of waste from the aircraft and states that this waste must be incinerated on airport grounds. The incinerator does not meet environmental standards, however, and since there is not enough waste to utilise the incinerator's full capacity it is constantly turned on and off, a process which releases more toxic cancer-causing dioxins.

- Lack of public accountability. The MEW decisions highlight many times that public participation is an obligatory condition in the development of the project. Public participation means the participation of the local inhabitants, public and environmental NGOs and other interested parties. Since the very beginning of the project, Bulgarian NGOs tried several times to present their opinion to the responsible Bulgarian authorities. Two statements were submitted to the Ministry of Environment and Waters concerning the Environmental Impact Assessment reports but these were not taken into account. The Ministry of Environment and Waters even denies designating the NGOs as an interested party in the case and denies them access to some public documents. Full transparency and public participation had been promised but in practice even the most affected citizens are aware neither of the documents nor of the current status of the project. Article 19 from MEW's decision N20-5/2001 requires a Public Control Action Plan to be developed determining the participation of the interested parties. A letter from the Ministry of Transport and Communications suggests that the environmental NGO Za Zemiata make proposals for the content of the Action Plan. At this stage in the development of the project, Za Zemiata has not received full documentation, meaning that the group was unable to make an adequate proposal. Za Zemiata recommends instituting a Consultative Committee according to European standards, which includes the participation of the affected citizens, interested parties and experts. In the already developed Action Plan the group's recommendation were not taken into account. Article 19 and item 5 of the Action Plan state that the airport administration is obliged to inform the district administration about the implementation of each project stage and each condition of the Ministry, as well as levels of noise pollution and increased control over flights over populated areas. This plan was signed on the April 30, 2002 by the minister of transport and communication, the vice minister of environment and waters, the executive director of Sofia airport, the mayors of the Poduene, Slatina, Kremikovtzi and Vrajdebna municipalities and the representative of the Initiative Committee of the Citizens of Sofia against Sofia Airport. In practice, district offices have no actual documentation concerning the project that is available to the public. The airport administration, however, assures us that this Action Plan is already being implemented. According to item 6 of the Action Plan, informational meetings in the MEW should be held every last Friday of the month. The mayors of the districts near the airport either were not informed about these meetings or received an invitation three months afterwards (!) they began. NGOs are not invited to these meetings. So far, only ONE of the foreseen meetings was actually held, because the responsible Bulgarian authorities do not bother to attend. As an excuse, they say that "there is still nothing to boast about".
Items 1, 2 and 3 of the MEW's Decision require the determination of the Public Safety Zone (60 dB) around the airport. Any houses in the expert-determined zone would have to be demolished and the inhabitants compensated. No legislation exists to stipulate how this Zone is to be determined or how people should be compensated. In most cases, they do not receive true compensation for the loss of their homes. On the technical side, the Zone fails to accurately measure noise impact since it studies only the new runway parallel to the old one. The distance between them is 210 metres, meaning that the Public Safety Zone should probably be extended southwards by that distance. No compensatory or health measures are planned for the people living around the Zone.

- Sustainability of the project. Original estimates in 1998 stated that the project had an 8-8.5% Internal Rate of Return (IRR). Later, the EIA reports showed that environmental standards were not included, leading to an underestimated project price. The possibility thus exists that project costs and IRR were underestimated with the aim of making the project more self-sustainable. Furthermore, opening of a new and modern airport in Greece capable of serving 10 million passengers a year calls into doubt the economic benefits of an expanded airport in Sofia. The EIB, however, is not interested in any further investigations. The Bulgarian government will receive the loan and the people of Bulgaria will have to pay it back.

On June 18, 2002 the Bulgarian NGO Za Zemiata/CEE Bankwatch Network sent a letter describing the project's environmental problems and its negative effect on the nature and the public to Peter Carter, Environmental Coordinator Projects Directorate of the EIB, and to interested members of the European Commission. In his July 2002 reply, Mr. Carter assured that "the EIB closely monitors the project to make sure it will meet all relevant EU legislation and international standards." He also very politely encouraged the NGOs to continue their efforts to ensure that Bulgarian authorities take such concerns into account. Za Zemiata honestly appreciates his eloquence and will continue asking how much longer Bulgarian taxpayers will have to pay for EIB unaccountability.
Meanwhile, Erik Meijer, a member of the Greens in the European Parliament, expressed his interest in the environmental issues related to the Sofia airport project. Za Zemiata provided him with detailed information and Meijer then raised these concerns in written questions to the European Commission. Michel Barnier, on behalf of the Commission, answered each question very briefly, saying that the Commission is well aware of the project's development. He stated that the Bulgarian authorities have submitted all required documents and an Environmental Impact Assessment report, which is in compliance with Council Directive 85/337/EEC, as amended by Council Directive 97/11/EC. When Za Zemiata asked the Bulgarian authorities to provide them with the documents, it became apparent that the Commission had in fact two 10-page long non-technical summaries of the two existing EIA reports, instead of full translations. Therefore, the Commission could have no real idea about the quality of the EIA report. Nevertheless, the Commission continues to claim that it is monitoring the project and that everything is in compliance with European legislation and standards. In one of his questions, Mr. Meijer asks about the solution to the numerous problems related to the environment. In response he received one sentence affirming that the Commission knows about them.

The previously-mentioned Initiative Committee of the Citizens of Sofia against Sofia Airport began a court case about the airport's negative effects on the population. According to Bulgarian legislation, no construction work can start while a court case is running. Still, on October 22, 2002 construction began before a final verdict had been reached, automatically making the construction illegal.

Meanwhile, local people have taken the initiative to address their concerns about the environmental situation and the health risk of living next to the airport to the Bulgarian authorities, listing their problems and demands. They have begun gathering signatures against construction of the new runway. Za Zemiata insists that meeting high European standards for nature protection and public health be made obligatory conditions for implementing this project. For this reason, the organisation actively supports the local initiative and is helping them with signature gathering. Za Zemiata will also present their concerns to the European institutions responsible for the development of the project.

For more information:
Keti Medarova
Za Zemiata/CEE Bankwatch Network
keti@bankwatch.org