To: Mrs Dolores Arsenova
Minister of Environment and Waters

S T A T E M E N T
by
Environmental Association "Za Zemiata" and Center for Environmental Information and Education
regarding the EIA documentation on the project National Hazardous Waste Centre

In connection with the forthcoming release of the Environmental Impact Assessment Report we consider that the following measures should be undertaken by the investor - Ministry of Environment and Waters:

1. The EIA documentation plus Conceptual design and other relevant studies and analysis must be made available in the national language.
2. The EIA documentation should be available in all affected villages not only at the municipalities of Radnevo and Nova Zagora - especially in Kovachevo, Pet mogili, Mlekarevo, Radecki, Polski Gradec, Novoselec, as well as on the places that will be affected by the transport of hazardous waste (especially near important drinking water resources and natural protected areas).
3. The EIA documentation must be available in a convenient place (e.g. city hall, info centres, where people can freely see it and study it).
4. The EIA documentation should be available in electronic form for easy and no cost copying.
5. The EIA process must be advertised in both the national and local media. Press releases alone do not guarantee coverage.
6. Detailed alternatives must be included in EIA.
7. Preparation meetings with the local initiative committees must be done before conducting the public hearings.
8. Participants from the investor, funding institutions and EU Delegation should be at the public hearings.
9. Audio recordings of all public hearings must be done and made publicly available after hearings.
10. Detailed responses on the comments and remarks from the public meetings as well as from written submissions should be provided within 30 days of receipt. Should the investor require a period longer than 30 days to respond, the group or person who has made the comments should be informed about the delay and notified of the exact date by which the comments will be answered.
11. Assessment of the risk and environmental impact of transporting hazardous waste trough the national routes network should be done, as the waste will come to NHWC from different parts of the country.

We hope our comments will be taken into consideration and we are grateful for your understanding and contribution.