Dear Mr. Figueras,

We are writing to you regarding the public consultation on the EIA report for Ljilin Motorway held in the period 27.09-04.10.2004. The residents of the affected locations (Bankja, Malo Buchino, Goljamo Buchno, and Sofia's regions . "Suhodol", "Lyulin", "Ivanyane", "Gorna Banya") totally rejected the EIA report and its conclusions. The residents of "Knjajevo" region demanded a real solution for the existing high traffic passing through their territory, rather than the proposed alternative. There are serious project deficiencies, which are not taken into account in the assessment prepared by the Expert Team of Mrs. Kochemidova, such as:

• Lack of real alternatives. The eight alternatives subject of the EIA report are only variations of one and same route all of which cause serious environmental problems. In the same time the proposed route do not fulfill the strategic objectives of the Ljulin Motorway, namely to reduce the traffic problems in the "Knjajevo" region and to serve the transit traffic. According the data in the EIA report the number of cars passing through "Knjajevo" region will continue to raise while another sensitive area will be destroyed;
• Damage on the Bankja National Resort. Pollution caused by Ljulin Motorway will have a detrimental impact on the Bankja Resort ^[1] due to the specific thermal inversions in the region. There is well-grounded evidence that the mineral springs in the town of Bankja and in the "Gorna Banja" region would be so affected that their usage will be limited and will even end;
• Fragmentation of the Resort Area. The proposed alternatives pass through the sanitary zone of Bankja causing fragmentation of the Resort Area. The three villages situated close by the motorway route will lose their potential for development as holiday zone for the capital.

The affected residents and NGOs asked the Ministry of Environment and Waters to reject the proposed route for the Ljulin Motorway ^[2]. They hope that this time the Ministry will take into account their concerns and revise the EIA permit.

Dear Mr. Figueras,

We understand the public importance from the development of transport infrastructure along the corridor Vidin-Sofia-Kulata. We are grateful that ISPA program provided grant money for the construction of the Ljulin Motorway. We are especially grateful that the EC have shown consideration of the public opinion and insisted on the implementation of EIA legislation in that project. However, we believe that ISPA should not disburse money for the project the way it is designed and promoted by the Bulgarian officials at the moment.

The Road Executive Agency (REA) was asked by the affected residents three years ago to develop alternatives to the Motorway construction. Since then we have seen neither steps for the development of a better route for the Ljulin Motorway, nor attempts for a open and honest dialogue with the local residents and other stakeholders. On the contrary, REA systematically have been neglecting public opinion and several times tried to substitute the outcomes of the public consultations, disregarding in this way the requirements of the EIA Directive and the Bulgarian law. Support from the EU institutions for such approach in project development will have serious negative impact on the democratic processes and public participation in Bulgaria.

Therefore we appeal to you not to make any further disbursements as part of the Financial Memorandum 2001-16-BG-PPT-004.

We hope that you will understand our arguments.

We would like to thank you for the attempts to improve that project.

We are looking forward hearing from you.

Sincerely yours,

Anelia Stefanova Environmental Association "Za Zemiata" (For the Earth)

On behalf of

BALKANI Wildlife Society
Andrey Kovatchev

Centre for Environmental Information and Education
Petko Kovatchev

Association "Ecoforum"
Prof. Radi Radev