Notification Ref. No 03/2024 to the attention of DG ENV Commissioner Virginijus Sinkevičius and Mr. Paul Speight

Dear friends,

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

On behalf of Balkanka Association, having the honor to express our deepest appreciation for the fruitful cooperation on environmental matters, allow me please to present our compliments to the receiving commissioner and especially to DG ENV of the European Commission in the light of our quite successful efforts towards the implementation of the European environmental Directives in Bulgaria, including the SEA and the Habitats Directives, the WFD and the Floods Directive.

Once again this notification is following up a kind letter Ref. ARES(2023) 8035636 – 24/11/2023 received from DG ENV of the Commission.

We share the new information in the attached file under a kind request by the DG ENV representatives at a meeting in Sofia, held on 04.10.2023, where we were asked to submit additional information concerning the Failure of the national authorities to comply with the requirements of the EU directives concerning the protection of the surface and groundwater water bodies’ status and the prevention of flood risks in Bulgaria.

In the attached document there is some additional News about the huge waste of EU funding wasted for the preparation of our new, already outdated River Basin Management Plans 2025-2027 in Bulgaria, prepared with the substantial „help“ of the International Bank for Reconstruction and Development, which is part of the World Bank Group. Actually, to our view the payment was substantial, while the help was more than questionable and disproportionate, to say the least.

As you all may know, our „new“ RBMPs 2025-2027, financed through OP Environment, were published for public consultation in Bulgaria on 31 March 2024 with at least a three years’ delay.

Under the circumstances – taking so much time for preparation, one would have expected that the published plans will be the best in the world.

Pitifully, after a thorough study of the published plans we were so unpleasantly surprised to find that the quality is less than zero.

In the attached file you can find our Objection conveyed to our local authorities, pointing out the deficiencies and mishaps discovered in Section 2 – Short review of the significant problems in water management of all RBMPs. These mishaps were made deliberately, following the Principle – No Problems – No Measures required to address them.

Now, please forgive us, because this time the attached document is in Bulgarian, but Bulgarian is an official EU language after all, while this time we really believe that it is in the best interest of DG ENV to check the facts as thoroughly as possible.

The reason is that the same facts we have alrеady shared with the European Public Prosecutor’s Office /EPPO/ in the light of the tons of EU money wasted for the huge delay and for the poor quality of these plans. EPPO is dealing exactly with that kind of waste of European funds and is carrying an investigation on the matter under a signal of ours at the moment. Of course, in the signal there is a little something for the idleness and lame reaction of DG ENV upon our numerous signals on the matter. We find that this makes DG ENV an accomplice to our local authorities in the waste of EU funding all of you were warned so many times to stop.

Anyway, having the honor to express our deepest appreciation for the fact that DG ENV has managed to file e law suit against Bulgaria for the delayed preparation of the RBMPs, we also believe that in the attached document there is evidence enough to convince DG ENV that the law suit should not be withdrawn, but on the contrary – the complaint in court

should be broadened on the basis of the poor quality of the plans.

Just because the attached document is in Bulgarian, here are just a few examples for the mishaps in English to attract attention of the interested DG ENV officers:

1. The reasons for the devastating drinking water crisis in the town of Pernik 2019 were not even mentioned and no measures to prevent repetition are proposed.

2. The same goes for the same crisis in the town of Svoge 2022, as well as for the crisis in the towns of Shumen and Burgas 2020.

3. Trans boundary pollution coming from the devastating mining areas in Serbia to the Dragovishtitsa and Timok rivers is not addressed at all.   

4. The Programmes of Measures /PoM/ do not specify the authorities supposed to fulfill them at all. Nobody knows which will be the competent authority for a given measure, even the authorities themselves.

5. In the PoM tables the column for the cost of the measures is empty and nobody knows the price and the financial source.   

6. The Financial Analysis of the water usage is based on data from the National Statistics in the period 2014-2017… Some revised RBMPs we have now published in 2024…, based on data from 2014?

7. A huge amount of supporting documents is not prepared and published for public consultation, regardless of the fact that they are referred to in the Programmes of Measures. For example – the Ordinance for the Residual flow /also called E-flow/ and the Ordinance for the design, dimensions and monitoring of fish passes, as well as many other supporting documents

And how a proper public consultation can be held when the cost of the measures is unknown? The ratio cost – effects may not be acceptable to anyone, you know, yet nobody knows anything about it!.

Anyway, these and many other mishaps in the „revised“ Bulgarian RBMPs 2025-2027 are described it the attached document, which we really hope that DG ENV will pay attention to this time, before the lawsuit is withdrawn from court!

As for the programmes of measures themselves, we will try to share another Statement in due course, because the new programmes are really funny, compared to the same programmes in the previous plans.

Based on all the above, we strongly urge DG ENV to put some efforts and to try their best to stop financing the Corruption on environmental issues in Bulgaria! The significance of environmental crimes is ranked fourth place in the world and it always happens in front of the wide opened eyes of the national and European authorities!

So, please this time don’t throw the attached Statement in your trash as usual, stay tuned for EPPO to get in contact with you very soon and have a nice time reading the document.

Thank you all in advance for your kind understanding and cooperation.

“Nature has all the time in the world, we do not”.

Kind regards