Re: Ljulin motorway in Bulgaria - state and perspectives

We, the undersigned representatives of citizens' initiative groups, non-governmental organizations (NGOs), professional associations and independent experts:

• Concerned about the blockage of the process of public analysis of costs and benefits from the construction and exploitation of Ljulin motorway (Dragichevo - Sofia ring-road between Suhodol and Philipovtzi);
• Recognizing refusal of the Minister of Environment and Waters to issue a new permit, based on the new Environmental Impact Assessment (EIA) procedure of Ljulin motorway, in accordance with Article 8 point 3 b) of the Financial Memorandum between Bulgaria and the European Commission (ISPA measure 2001 BG 16 P PT 004);
• Taking notice of the continues attempts of the Ministry of Regional Development and Public Works (MRDPW) and Road Executive Agency (REA) to ignore the problems for the environment and health risk for the inhabitants of the regions surrounded the route of Ljulin motorway (200 000 inhabitants) and for whole City of Sofia (around 1,3 million inhabitants), thus insisting on an unacceptable solution;
• Realizing that the route for Ljulin motorway that has been accepted both by REA and MRDPW will not lead to the decreasing of the traffic trough the current road Vladaja- Knyajevo but, in opposite, in a mid-term prospective the traffic on the mentioned direction will be kept stable and even will grow;
• Anxious about the approaching deadline for the beginning of the constructions (according to N+2 rule);
• Worried about lack of adequate links between the development and objectives of the Common Urban Plan (CUP) of Sofia and specific projects part of the Plan, such as the Ljulin motorway;
• Giving our support to the concerns and protests of different NGOs, professional associations and citizens' initiatives against the proposed CUP of Sofia;
• Taking into consideration Decision No 129 from 13.10.2003 of Sofia Municipal Council;
• Underling once more time that Bulgaria does not have an integrated national transport policy;
• Recognizing that lack of Strategic Assessment for the network of Trans-European transport corridors on the territory of the country and region (South-Eastern Europe);

and

• Agreed that the prohibition for participation of representatives of citizens and of the interested public of Sofia in the National Expert Councils of MRDPW (2002-2004) led to hasty and not well-considered decisions,

We gathered on an Alternative Expert Council to discuss possible solutions for development of the process and procedures around Ljulin motorway. Representatives of local administration, regional administration, Municipal Council of Sofia, interested Ministries (MRDPW, MoEW) and institutions (REA), etc. have been invited to participate. The Council took place on April 07, 2004 in Sofia.

After discussion the participants united themselves around the following requests, decisions and recommendations to the respective representatives of the Bulgarian government responsible for the development of the project.

1. The Minister of Environment and Waters should issue a negative EIA Decision based on the last (revised) EIA report from 2003 due to significant violations of the procedures for public participation, mass negative opinions of the inhabitants, NGOs and professional associations and the existence of enough evidences for potential heavy negative impacts on certain components of environment and harmful impacts on the health of the inhabitants from the area and from Sofia.

2. The Minister of Regional Development and Public Works should stop the procedures for further approval of the Ljulin motorway route (blue + brawn alternative) as well as already started preparatory procedures.

3. The Minister of Regional Development and Public Works should open a new procedure for designing of routes in the region situated on west side of Sofia. These solutions should be in accordance with the following general and obligatory requirements:

1. The planning of the solutions should include alternative scenarios that have to be subject of a Strategic Assessment under the standards of EU (with analysis of ecological cores, ecological corridors, buffer zones, ecological infrastructure as well as the correction and restoration of the environment).
2. Scenario that decouple the transit traffic from the traffic to and from Sofia in South-Western direction ("south-eastern entrance of Sofia") and that divert the transit traffic far from Sofia should be assessed. Such scenario should be able to propose complex solutions, oriented toward sustainable development of the region and therefore should be assessed with priority.
3. No construction of motorways should be allowed within or nearby the health resort zone of Bankja and the settlements that are organically linked with this zone (such us Malo Buchino, Ivanjane, Suhodol, etc.). Such construction will lead to fragmentation of the territory and additional pollution and harmful impacts on the nature and inhabitants.
4. The widening of the existing road Knjagevo-Vladaja-Dragichevo should not be accepted as single solution of the problem.
5. There should not be definition, assessment and prioritizing of the transport goals for the region beforehand. Such definition and design of the tangible scenarios and alternatives should happen on the ground of wide public consultations.
6. Biological links (corridors) between Vitosha and Ljulin mountains should be saved.

We recommend that the development of the region situated on west side of Sofia to become a subject of an Environmental Development Program. The regional and local authorities from City of Sofia, Pernik and Sofia regions should be involved in the design of such Program

4. The Minister of Finances should start negotiations with the respective representatives of the European Commission in order solutions that will save the already agreed funding with the Financial Memorandum between Bulgaria and the European Commission for Lyulin motorway to be discovered until new transport decisions in the area are in place.

We consider that the aforementioned recommendations represent a compromise solution that gives an ability for analyzing and taking into account all positive and negative aspects of the future transport infrastructure in Western and South-Western direction of Sofia and suggests a procedural solution for the existing cul-de-sac.

We declare our readiness to give our support to the institutions if they started to work in the recommended direction.

This statement is open for support to other NGOs, professional and other public organisations, citizens' initiatives, institutions, local and central public authorities as well as for support from citizens.

April 07, 2004
Sofia

Center for Environmental Law
Association of the Architects in Sofia
Centre for Environmental Information and Education
Green Euro-zone "Ljulin"
Initiative Committee "Ljulin" (Malo Buchino, Bankya, Ivanjane)
Union of the Scientist in the Transport
Green Party in Bulgaria
New Art Design
Environmental Association "Demetra"
Balkani Wildlife Association
Association of the park and landshaft specialists in Bulgaria
Environmental Association "Za Zemiata (For the Earth)"
Environmental Association "Tetida"
Bulgarian Lepidopterological Society