Dear Sirs,

We are writing to you with deep concerns regarding the preparation of the National Hazardous Waste Centre project in Bulgaria. The Ministry of Environment and Waters (MoEW) first initiated the project in 2000. Fortunately at that time the project was not approved for financing by the ISPA program as there was.a serious violation of EIA procedure regarding public hearings and public participation and also violation of the Bulgarian Law for Protection of Environment.

In 2003 the Ministry started a new preparation of the project in spite of strong opposition from local affected people. The Centre is planned to be constructed approximately two kilometres away from the nearest village - Kovachevo - in the most polluted region in Bulgaria. Near the proposed site there are three thermal power plants "Mariza East-1,2,3" and three open coal mines "Mariza East" Ltd in operation.

Many of the people living in the area already suffer from different types of health problems as a result of the existing high levels of pollution and they are very worried about the possible health impact of the proposed Centre. They do not want to be exposed to new pollutants and seek a decent life for themselves and their children. Nevertheless, the position of the local people has been totally neglected in the past and there is a risk that this will happen again now.

On March 15, NGO representatives were invited to discuss the scope of the EIA report. Za Zemiata and CEIE submitted a statement asking for an analysis of the alternatives to incineration and of the cumulative effect of the toxic substances (especially dioxins) on humans in the region of Stara Zagora, as well as a detailed analysis of the health risks and cumulative effect of toxic substances on the villagers from the nearest five villages to the Centre site

The Ministry of Environment and Waters is the project sponsor as well as the institution which approves the EIA report. This creates a potential conflict of interest within the Ministry. Therefore we regard it as very important that your institution pays particular attention to the EIA consultations. We consider this to be very crucial as we have found significant gaps after reviewing the Feasibilty Analysis and the Conceptual Design of the project. For that reason Za Zemiata initiated a meeting between Ministry of Environment and a EU Delegation. At the meeting conducted on June 24 we raised our basic concerns:

The project is politically driven: the Ministry of Environment openly talks about the need to get ISPA funding as soon as it is possible which raises questions about the quality of the project.

• Alternatives to incineration technologies have not been considered at all, although we submitted a list of alternative technologies for the previous project proposal (2001).
• We have concerns about the economic viability of the project. For example, even with 50% of the ISPA grant, the project is not able to produce enough revenue for reinvestment when the lifetime of the equipment expires.
• A centralised system of treating hazardous waste in Bulgaria has been chosen and no other scenarios have been proposed in the documents.
• There is no background information about the current levels of toxic substances in the region and no measurements of blood, breast milk and food have been carried out or are planned. Health risk assessment would not be relevant because of the lack of data.

Problems with public participation

• The previous approach of the Ministry of Environment is of major concern. In the beginning of May 2001, the procedure for public discussions of the preliminary EIA report was opened. Public hearings on the report were conducted on May 20 in Radnevo and on May 21 in Beglej. Approval of the EIA report by the Expert Council of the Ministry of Environment and Waters came on May 22, one day after the public hearings. In this way the right of the participants at the public hearings to submit statements was violated and the weaknesses of the EIA report were found during the public discussions. At the end of May the project was submitted to ISPA for financing.
• The residents of the affected villages are also worried that the Ministry will conduct the public hearings during the summer months of July and August when most of the villagers are cultivating their lands and thus it will be very difficult for them to review the EIA, participate in the hearings and submit statements. Therefore, the residents are asking for public hearings to be conducted in all five villages, not only in two municipalities.
• There are no public hearings or information distribution about the project envisaged for the towns and villages that will be affected by the increased transportation of hazardous materials.

In light of the situation outlined above, we appeal to the European Investment Bank, DG Regio and DG Environment to pay special attention to this project, its public hearings and the whole EIA procedure.

We hope that our appeal will receive due consideration and we would like to thank you in advance for your understanding and support.

Yours sincerely,
Ivaylo Hlebarov

Za Zemiata (For the Earth) / CEE Bankwatch Network
p.box 975
Sofia 1000
Bulgaria
Tel/fax: +359 2 851 86 20,
Email: hlebarov@bankwatch.org