To MEW
CC: European Commission - Directorate Environment
Dear Madams / Sirs,
1. At the meeting in Borovets on May 13, 2003 we informed the delegates of the European commission about the violations done by Roads Executive Agency (REA) during the preparation of the EIA reports for the "Liulin" Motorway . Those included blocking of the objectively prepared EIA report in March 2002 from discussion within the Supreme Environmental Expert Council and preparation of a falsified EIA report from August 2002 and violation of the procedure, concerning public discussions of the final EIA reports. The executive director of REA, Mr. Dikovski accepted the findings and took on the task that the agency amends the violations, done and prepare a new and objective EIA report, following the guidelines of the Bulgarian and European Environmental Legislation.
2. Concerning these decisions, REA, being an investor in the project, invited us for a meeting on July 17th 2003 with a letter No 08-00-878/09.07.2003, in which the subject of the meeting was stated to be "defining of the scope of the revised EIA". We responded to the invitation and to out huge dismay instead of holding consultations for defining of the scope and content of the new EIA report, REA proposed for discussion the EIA report from August 2002. It was clear that, we have been mislead to participate in the discussion of an old and well-known to us EIA report, not a report which is being planned for the future!
3. Moreover, the investor denied mentioning in the documentation the EIA report from March 2002, prepared by eng. K. Kochemidova and contributors, in which the "green" and "striped green" versions were suggested to be most appropriate. The inclusion of that information source would have clearly refuted the conclusions of the experts in the August version of the report. The investors behaviour in that case is a blatant violation of article 95, par. 2, section 8 from the Bulgarian Law for the Protection of the Environment.
4. At the meeting held on July 17th 2003 was present the new expert, responsible for the preparation of the new EIA report, docent Denev. He agreed to meet with us in order to discuss the EIA report from March 2002 together with our written analysis of the violations done with it. Later doc. Denev changed his mind and cancelled the appointment. The actions of doc. Denev, who mislead us and did not regard the appointment is simply immoral. His action directly violates section12 from decision No 74-18/2001 of the Minister of Environment and Waters. With that decision, the experts preparing the EIA report for "Ljulin" Motorway were recommended to meet with the impacted individuals in the duration of the consultations.
5. Moreover, in the revised EIA report, doc. Denev states (page 7), that he has not been introduced to the other six alternatives of the route. It was clear that he has prepared the revision of the EIA report without considering the recommendation of section 3 from decision No 74-18/2001 of the Minister of Environment and Waters, which is a basis for the development of each of the following EIA reports. Section 3 from the decision referred to demands from the authors of the EIA report that "all alternatives of the "Ljulin Motorway" route are described and assessed, including the zero one". From the very beginning doc. Denev has been aware of the fact that REA is not giving him the assignment to prepare a new EIA report. He does not deny that he explored only and solely the road variant already chosen. This fact is confirmed by doc. Denev's admission, documented in the protocol from the meeting on July 17th 2003. Violating the cited decision, doc. Denev confirms the falsified EIA report from August 2003.
6. With regard to the unlawful performance of REA and doc.Denev, we decided to put forward the objectively prepared EIA report from March 2002 in the Ministry of Environment and Waters as a independent information source (entree No 48 00 410/25.08.2003)
7. Madams / Sirs,
In the revised version of the report the authors mention that at the approval of the EIA report from August 2002, the procedure has been violated (p. 3). Further on they accept that report and reconfirm its conclusions. In order to assess the objectiveness of the revised report it is necessary only to explore one of its major sections - "Atmosphere and atmospheric air", p.15 - 24 and p.65 - 83. It is visible that a huge amount of computerized calculations for estimation of the atmospheric pollution have been carried out in the area most close to the motorway. The calculated results are accepted as a definite proof for the level of expected pollution in the adjacent area, from which the conclusion is drawn that there is danger of atmospheric pollution.
We firmly disagree with the conclusions, drawn from those calculations, on the following basis:
8. According to the revised EIA report, the days with thermal inversions in region of the road-track are estimated to be approximately 55 % of the days of the year (p.20). Typical for those days is that "in a state of inversion the air, rich of toxic elements, cannot leave the centre of the emission. It remains there and the amount of the polluters is permanently increasing - smog with high concentrations of toxic and harmful for population elements is formed" (see A.Heince & G. Reinhard, S, UI, 2000, p. 59 - 60). In the report the question how that type of pollution corresponds with the estimations done remains without answer.
9. In order to reply to that question, our expert helped us to clarify what "smog" means. Under the influence of the nitric oxide, emitted by the engines of the motor vehicles, the oxygen from the air and the sun radiation, huge concentrations of ozone develop in the atmosphere. The ozone further intensively (due to its high reactivity) interferes with the exhausts carbohydrates, present in the motor vehicle emissions. The biggest part of the unburned carbohydrates are slightly toxic or harmless. As a result of the reaction with the ozone, they turn into high poisonous and carcinogenic substances. Therefore in a state of smog, huge amounts of poisonous and carcinogenic substances can be developed in the ground atmosphere that could be many times over the concentrations cited in the revised report. (see J.M. Bokris, Chemistry of the Environment, 1982., p. 201 - 203)
10. This secondary atmospheric laboratory is called smog. Such conditions would exist in the region of the resort complex Bankja according to the revised EIA report every second day of the year. We have to assert that even if smog develops in only 2-3 % of the days in the year, the town of Bankja (report area A) would lose its importance as a balneology resort. The sanitary resort area B (Malo Buchino, Ivaniane, Gradoman) would lose the prospect of developing as a healthful region of the Bulgarian capital city.
11. Due to concerns for over pollution, in its EIA report form March 2002 eng. Kochemidova recommends the "green" and the "green striped" routes, according to which the motorway is far enough from the resorts Bankja and "Gorna Bania".
12. On page 19 in the revised EIA report is stated that the transfer of atmospheric air in the sanitary area "B" of the resort complex of Bankja is from west to east. If so, why the most inappropriate of all routes - one which goes around Malo Buchuno village in three directions - northwest, west and southwest is selected? At a distance of 150-200 meters. In that village live permanently 700 people, and together with the villa area their number jumps to 1400. If a that route is accepted the village would be doomed to slow destruction, and the people living inside it to serious health problems.
13. The arguments and data, stated above show that the statement in the revised EIA report (p. 21) that the explored section of Liulin motorway would not lead to substantial pollution increase in settlements from the Bankja resort complex is not justified. Such statement is groundless and wrong. The computer calculations, carried out by the team of Mr. Denev, do not refer to the creation of smog in the atmosphere, which is the major threat for the settlements from the Bankja resort complex. This is confirmed by the written in section 21 from Decision No 32-15/2002 of the Minister of Environment and Waters, that "organization for diverting the traffic from "Liulin Motorway" during periods of permenent temperature inversion must be created".
14. Likewise, the rest the issues, explored in the revised EIA report are either exaggerated or wrongly presented. It is not necessary and also possible to list all of them. Still here are some:
We cannot agree with the statement that from environmental point of view the impacted settlements are relatively preserved (p.1, row 7th). On the contrary, the villages from the guarded zone "B" from the resort complex of Bankja are the most unpolluted spot in the plain of Sofia , which is proved by data from previous reports. With the construction of the motorway, this region would be subjected to the levels of pollution typical for large cities and even higher.
The statement from p.7, that the construction of the "Liulin Motorway" along the chosen route track is economically viable is completely wrong. The estimation of approx. 150 million euro surpasses the amounts calculated for the other road alternatives, from the preliminary study of "Putproekt". There the construction expenses for the "green" alternative are estimated to be 125 million euro.
The statement form p.11 that the appropriated for the construction of the highway lands are non irrigational and infertile is not true for the region of Malo Buchino and Ivaniane. The fields are category IV and V, which is highest quality land for the region and they have secured the self-sufficiency of the local population for hundreds of years. The statement that those lands are remote from the protected areas ignores the fact that the latter are part of the guarded area "B" of Bankja resort.
The problem with landslides is underestimated in the chosen route track, (p.34, 90-92, 94). On the preceding reports, much more data is available which counter the revised one on that issue.
Underestimated is the problem with the mineral springs, located east from the town of Bankja and in the region of Malo Buchino village (p.36).
15. The stated above characterizes the revised EIA report as non-objective, misleading and "made to order". That has been underpinned by the act of ignoring of decision No 74 -18/2001 of the Minister of Environment and Waters for equal estimation of all seven route alternatives and of unwillingness to analyse the EIA report from March 2002. Such manner violates the spirit of the Financial Memorandum, contracted with the European Commission and obstructs the implementation of the decisions taken during the Borovets meeing with the delegates of the Commission.
Concerning the reasons listed above, we, the citizens of Malo Buchino village, firmly disagree with the suggestion that "Liulin Motorway" goes along the route track, marked as "brown + blue" variant.
Madams/Sirs,
In order to avoid the situation, created at REA's fault, we, the citizens of Malo Buchino village consider that there are two harmless route variants and suggest one of them to be selected.
The first of them is the construction of the motorway west from the town of Bankja, according to an existing design. Thus the Sofia would also be saved from additional pollution, having in mind that the concentrations of highly toxic carcinogenic pollutants there are much above the safe-bearing.
The secondis east from the guarded area "B" of Bankja resort, along the "green" and "green striped" route alternatives. For that there is a prepared EIA report from March 2002.
We suggest to the Higher Environmental Expert Council" to accept one of those options and enable the utilization of the funds allocated by the European Commission in Bulgaria.
October 8th 2003
Malo Buchino Village, Sofia
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