Complaint to the Implementation Committee of the Espoo Convention, concerning breach of articles 2 and 3, and notification to the attention of EC – president Ursula von der Leyen, and to the affected party Greece

OFFICIAL USE

Dear Mrs. Losasso,

Dear friends,

My name is Dimiter Koumanov and I have the honor to be responsible for the environmental protection activities of Balkanka Association, Sofia, Bulgaria.

I really believe you remember our joint efforts in the case of the illegal mining activities in the region of Bosilegrad – Serbia, undertaken few years ago, and thank you very much for the fast reaction in the case of the new mine in the region of Strumitsa, North Macedonia

However, currently there is a new big threat for the Arda and the Byala reka River Basins, coming this time from Bulgaria, where a new huge gold mine „Tintyava“ is about to be developed soon. In brief, this new mine will operate in line with the best medieval practices dating back to the middle of the previous century.

Additionaly, another new mine – „Ada tepe“ currently is operating in breach of the agreement of the affected party – Greece, and there are new mining exploration intentions almost fully covering the territory of two municipalities adjacent to the Greek border.    

So, please be so kind to find attached our new official Espoo Convention complaint form on several mining activities in Bulgaria, in the region of the Eastern Rhodope Mountain, close to the border with Greece.

Party of origin in this case is Bulgaria and affected parties to the Convention are Greece and, to our view – the EU itself, because the Union is party to the Convention too.

Therefore the Complaint is shared for information with all parties concerned. Apart from the Implementation Committee of the Convention, the other recipients should take the attached documents only as a Notification, but the large scale of the infringement has driven us to believe that the case should be taken to the attention of EC President Ursula von der Leyen. Such things should not happen in the EU in the 21st Century.

Due to the limited space in the official form, full description of the case is shared there in a link, as we did it in the Bosilegrad and in the Strumitsa mine cases.

Apart from the Convention Implementation Committee representatives, the other recipients can download the complete Complaint from the same link here:

https://dams.reki.bg/uploads/Docs/Files/ESPOO_COMMITTEE_COMPLAINT_TINTYAVA.pdf

We also kindly urge the Implementation Committee and the European Commission to take prompt action and the necessary steps towards proper implementation of the Espoo Convention, because we have no other hope.

We remain ready for cooperation and to submit additional information, as well as to answer any possible questions.

Thank you in advance for your understanding and cooperation

Kind regards
Dimiter Koumanov
Senior Environmental Advisor
Balkanka Association, Sofia, Bulgaria

ANSWER

Subject: RE: Complaint to the Implementation Committee of the Espoo Convention, concerning breach of articles 2 and 3, and notification to the attention of EC – president Ursula von der Leyen, and to the affected party Greece

Dear Mr. Koumanov,

Thank you for your message and its attachment which has been brought to the attention of the Implementation Committee and will be considered at its fifty-seventh session (Geneva, 29 August – 1 September 2023).

Please note that Ms. Elena Santer has moved to another position in the organisation and is not dealing with Espoo matters anymore.

Kind regards,

Elisabeth Losasso

Elisabeth Losasso
Environmental Affairs Officer
(Espoo) Convention on Environmental Impact Assessment in a Transboundary Context
and the Protocol on Strategic Environmental Assessment

Environment Division
United Nations Economic Commission for Europe

e-mail: elisabeth.losasso@un.org
Phone: +41 (0) 22 9174231

Palais des Nations
8-14 avenue de la Paix
CH – 1211 Geneva 10, Switzerland