Dear Mrs. Wallstrom,

We are writing to you with a deep concern regarding the future development of the Ljulin Motorway project. The new consultations with the public were held within the period October 11th - 15th, as requested in the p.8.3 from the ISPA Financial Memorandum for "Liulin Motorway" (2001 BG 16 P PT 004). However, we consider that the Road Executive Agency carried the process out in full disregard with the Bulgarian and EU standards for Environmental Impact Assessment (EIA) procedure.

As a result, we would like to highlight a few striking examples of the weaknesses and problems in the Environmental Impact Statement (EIS) and the consultation process.

The revised EIS assessed only one route ("brown + blue"), while the previous EIS (2002) considered six alternatives. We would like to recall that the fisrt EIS (2001, covering only the "blue" and "brown" variant) was rejected by the local people and the Ministry of Environment and Waters because not all of the existing alternatives were assessed equally. In fact, the six alternatives for motorway alignment and the previous EIS (2002) has never been discussed with the affected citizens. The right of the public to participate in the decision making process was clearly undermined when the route of the Ljulin Motorway had been selected.

The project was not adjusted to mitigate the negative impact on the environment. The "brown + blue"route was approved on July 23, 2002 with a decision of the Ministry of the Regional Development and Public Works (MRDPW, No RD-02-14-611), clearly undermining the outcomes of the running EIA procedure. "Once the route is accepted by the MRDPW no changes are possible" stated Mr. Denev, the leader of the EIA's expert team, during the public consultations. "Personally, I would like to see some changes and compromises in the project, but is not possible" he continued.

The public was not provided with sufficient information before the meetings. The EIS were sent and presented to the population by the majors only in the villages of Malo Buchino and Ivaviane (two of the six hearing venues). However, the EIS did not contain design plans of the route proposed. The "Ljulin" Initiative commette requested additionally the plans of the "brown + blue" alternative from the Roads Executive Agency (REA). The REA sent the map one day before the public hearing. Furthermore, the plan did not show the location of the tunnels, bridges and viaducts and the company that created the design plan, used an old map, on which the expansion of human settlements within the last few years was not shown.

The Major of District "Ovcha Kupel" who received the EIS report as well, denied the citizens of Suhodol access to it and demonstratively threw it at the table during the pulic hearing. The major also declared that memos from the metings and statements of the local people should be revised personally by him. Such a practice is in contradiction to the existring Bulgarian laws.

It became clear that the Ljulin motorway will be used more as a first-class city road than as a transit motorway. At the same time, it will not eliminate the pollution and the traffic problems in Knjazhevo, the neighbourhood where the heavy traffic for Pernik and Kulata currently passes. During the heraings in Knjazevo the citizens raised the question: "Will our living conditions improve if the "Ljulin Motorway" is constructed?" The experts were honourable enough and did not lie. The situation in Kniazhevo would not improve, it would get even worse: the traffic expected in 2020 would be 2,5 times higher than the current one. Then the local people asked why such expensive construction works have to be carried out.

The latest news is that the City Council of Sofia Municipality rejected the project. However, the acception or rejection of the project is not within the competence of this body, although this decision shows recognition for the local people's opinion. Eng. Deliana Sechenska from the Sofia City Council called the motorway "a Motorway-killer", based on the abundance of curves in combination with high viaducts and low projected speed, which would surely be exceeded. Mrs. Sechenska had pointed out the difficulties in the construction of such facility from engineer-geological point of view a year before. Moreover, the previous EIS also highlighted the problematic maintenance of such a motorway during the winter. What is most striking, is that the motorway will be even useless almost half of the year, as the traffic needs to be redirected when temperature inversions occur (according to the decision of the MOEW).

These examples demostrate the unwilligness of the Bulgarian authorities to take into account the public opinion and to conduct concrete measures to mitigate the impact of the project on the environment (as requested in point 8.3 from the Financial Memorandum (FM). Thus, the Road Executive Agency once again demostrated a lack of respect to the conditions stated in the Financial Memorandum for the Ljulin Motorway. Therefore, we encourage the EC to make an in-depth review of the EIA procedure and FM accomplishment. For your convenience, we enclose the Statement of the citizens of Malo Buchino village and the Appeal for the Salvation of national climatic and balneotherapeutical complex Bankya (signed by 22 prominent Bulgarian scientist and doctor of medicine). In the forthcoming week we will provide you with the memos from the public hearings and profound assessment of the EIA procedure and the EIS using the EU best practices guidelines. Additionally, the new information regarding the EIA procedure on the Ljulin Motorway will be regularly uploaded on the www.zemiata.org/bw/ljulin.

Dear Mrs. Wallstrom,

We would like to clarify that we do not object to the Ljulin Motorway as an initiative, as we are fully aware of the need for transport infrastructure development in Bulgaria, part of the accession process. However, we consider that ensuring the democratic and environmentally sensitive approach in decision making process is equally important for the Bulgarian membership in the EU. The Bulgarian civil society believes that the EC has a crucial role in promoting the best practices in environmental and social rights protection in Bulgaria, and especially through projects funded by the EU programs. We accepted the conditions under p.8.3 from the Ljulin Motorway FM as an evidence for the EC recognition of the importance of public consultations. The Bulgarian civil society believes that the EC will not support the construction of the Ljulin Motorway until the project is prepared in full compliance with the EU and Bulgarian legislation.

We are looking forward hearing from you and would like to thank you in advance for your support.

Sincerely yours,

Slavena Arsova / "Ljulin" Initiative Committee Sofia 1618, p.box 208 Tel./ fax: + 359 2 955 95 93, e-mail: ik_lyilin@abv.bg

EA "Za Zemaiata" (For the Earth) / Anelia Stefanova Sofia 1000, p.box 975 Tel./ fax: + 359 2 980 41 09, e-mail: anelias@bankwatch.org

Wildlife Society "Balkani" / Andrei Kovachev Sofia 1164, Dragan Cankov Boulevard 8 Tel: +359 2 963 14 70, e-mail: balkani@bluelink.net

Center for Environmental Information and Education / Petko Kovachev Sofia 1303, Sofronii Vrachanski Str. 17 A, fl.3, ap.9 Tel./fax: +359 2 989 27 85, e-mail: ceie@iterra.net