Dear Sir/Madam,
We are writing to you with regards to the recent development of the project for "Ljulin" motorway. On the 11th of June the attached joint letter of our Initiative Committee together with the Association form "Suhodol" was sent to 50 stakeholders.
On the 26th of July we received a letter from Road Executive Agency (REA), which says that: "According to article 95, line 1 from the Environmental Protection Act, we announce that in relation to the Environmental Impact Assessment (EIA) report of the "Ljulin" motorway, the REA starts a new EIA procedure and public consultations about the scope and content of the EIA."
In the next letter, dated 9th of July, we were invited to a "meeting with the team who has developed the EIA report, to explain us the scope of the revised assessment and to clarify the procedure for the performance of public consultations (in compliance with the article 9, line 3 from Government Decree N 59/2003, EIA Regulation). The meeting was held on the 17th of July. It was attended by representatives of other non-governmental organisations. Neither before the meeting, nor during the meeting we were not given any materials, which we could read. We first thought that we will have the opportunity to discuss alternative routes of the motorway, but this was not the reality. At the meeting was present only the leader of the EIA team, who had to change only some of the things in the report?! On the next day in the morning another meeting took place among the representatives of the REA, the Mayors of the Villages of Goliamo Buchino, Malo Buchino and Ivaniane. The Mayos of Goliamo Buchino and Ivaniane were asked where they would like the connections of their villages to the motorway to be situated. As if connections among the residential areas are constructed, the Mayors will stop disturbing the developing process. The Mayor of the Village of Goliamo Buchino was offered two connections. Nothing was offered to the Village of Malo Buchino since their Mayor strongly opposes the whole project. The Mayor of the Village of Ivaniane was told that the route of the motorway is slightly distant from the village and she accepted this. This automatically means that the route is closer to the Village of Malo Buchino! There, the viaduct is situated in a way that it will be exactly above people's heads.
Probably, you already have information about these meetings. We would like just to underline the fact that no new decisions were made. The REA did not change their position at all and it is not clear to us why they have pretended to start the procedures again. We insist that all responsible institutions must organise meetings with non-governmental organisations and a meeting of the National Expert Council for urban and regional policy must be held. We have documents showing that other professional organisations are also against the construction of this route (architects, urbanologists, etc.). Unfortunately, the state denies to communicate with stakeholders. A meeting with the Ministry of Finance was promised to us in the beginning of November. Now, even less people are aware of the what exactly "Ljulin" motorway is - the connection of Pernik with Sofia, part of the Trans-European Corridor N4 or part of the road Sofia - Plovdiv - Svilengrad. On the front page of the EIA report is written that "Ljulin" motorway is part of the the corridor Sofia - Turkey, E-79. E-79 is the road Sofia - Greece. Is it really necessary to be a motorway, when the functions of the corridor will be taken by another section of the road, connected with the Petrohan tunnel?
We are aware that you are well informed about what is happening in Bulgaria and we appologise for challenging the Bulgarian state authorities, but there is no excuse for their own activities.
We appealed the decision of the Supreme Administrative Court, and we lost the case. Now, we are going to appeal the decision of the Sofia municipality, which approved the new Plan of Sofia, which includes all three Trans-European Corridors. By the way, on page 222 of the EIA report is stated that "the concept is totally wrong and needs revision".
Here, eventually your opinion is requested, but just for the procedure, and then who is taking it into account?
The coming traffic from Belgrade and going south to Kostinbrod will be diverted to the new motorway, which goes towards Pernik and connects with "Struma" motorway. However, this connection will be ready when the tunnels and bridges through Petrohan are ready. Until then, the traffic in south direction will take the new "Ljulin" motorway. This is a road that in future will only reduce the traffic through Vladaia and "Tzar Boris, the Third" boulevard.
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