Following up the latest official communication exchanged between Balkanka Association, Sofia, Bulgaria and some EIB/EBRD Divisions in regards to both banks investments in hydropower in Bulgaria, I am delighted to share with all of you the following brand new, very important information.
1. Environmental Impact Assessments in Bulgaria.
In the light of the discussion on the EBRD Environmental and Social Policy /ESP/, which was held on 28 February in Belgrade, I really hope it will be remembered that we have stressed the point on the poor quality of all kind of EIA and AA reports prepared for hydropower undertakings in our country.
The main reason being that investors are paying for the reports, as we have also shared with both banks decision makers in our written statements and positions concerning all kind of ESP and/or Guidelines on sustainable hydropower development so far.
Just yesterday our statements on the poor quality of those EIA/AA reports were confirmed by the European Commission in the following communication called "March infringements package: key decisions". Please check section 3. Environment:
http://europa.eu/rapid/press-release_MEMO-19-1472_en.htm
Regarding the Environmental Impact Assessment issues, here is a short citation:
In Bulgaria, certain elements regarding screening decisions, Environmental Impact Assessment reports and information to the public do not adequately reflect EU standards, and the monitoring of projects with significant adverse effects falls short of requirements.
2. Failure to comply with the Habitats Directive
For 2018, the July infringements package: key decisions - Section 4. Environment can be found here:
http://europa.eu/rapid/press-release_MEMO-18-4486_en.htm
Here is another citation extracted from the key decisions in 2018:
Commission asks BULGARIA to improve implementation of EU nature legislation
...... The issue was first identified a decade ago, and although Bulgaria has since taken some measures to address the issue, this structural problem persists and the Commission regularly receives complaints about plans and projects that are authorised on the basis of inadequate assessments, or even in the absence of appropriate assessments.
You already know one of the complainants /that's us of course/ and of course most of the projects in view are for hydropower. To forward the above formal notice the EC was provided with the necessary proof on the matter, obviously.
Now, I can assure all of you that a significant part of the conclusions of the Commission are based on one initial Complaint and nine consecutive supplements of Balkanka Association lodged with DG ENV of the EC in the last three years. Actually these EC letters of formal notice are the first step in the long run to several infringement procedures, which are inevitably coming our way. Please, rest assured that some of the cases were financed by EBRD and EIB either directly, or through FIs, because the problem addressed in our complaints is horizontal and applicable to all hydro undertakings in Bulgaria.
For more information, all our complaints can be found in the following link, having in mind that Complaint Annex 4 is based on mining in Bulgaria and Complaint Annexes 8 & 8A are based on mining and hydropower enterprises in both Bulgaria and Serbia - these are focused on the ecocatastrophe in Bosilegrad - Kyustendil. All the other complaints are focused on sustainable hydropower developments. Here is a link to the page in our HPP platform, where the complaints are uploaded:
https://dams.reki.bg/Docs/Files?setlang=en
The file names always start with EU_Complaint _ and I hope that both EBRD and EIB will be able to find some of the projects they have financed, as well as our comments on the poor quality of their EIA/AA reports.
3. Failure to comply with the Water Framework Directive
Here is a very interesting report on the issue:
You can find the recommendations for Bulgaria on page 3, as well as the following short citation:
Based on the findings emerging from its 2nd RBMPs, Bulgaria is particularly encouraged to:
· Improve its own monitoring capacities with a view to lower its dependence on expert judgment for assessing the ecological status/potential of its water bodies.
· Base the use of exemptions under Article 4(7) on a thorough assessment of all the steps as required by the WFD and transparently indicate, in all RBDs, which are the justifications for invoking the exemptions under Article 4(7) WFD.
Please note that the report above holds general findings and recommendations only. It is not part of an infringement procedure so far, but one day it will be for sure, I promise.
IMPORTANT
Please check the second recommendation marked with the red dot once again. This one is solely addressed to four future projects of big dams in Bulgaria - three of the Gorna Arda Cascade /the projects were abandoned/ and the Yadenitsa dam - which is our greatest concern at the moment /apart from the Bosilegrad - Kyustendil ecocatastrophe/. The exemptions under Article 4(7) were justified in the East Aegean RBMP in violation of the legal base, which for the Yadenitsa dam is a proven fact in one of our complaints.
Therefore, we will highly appreciate if EBRD and EIB check whether the Yadenitsa dam in Bulgaria falls within their future plans to receive any kind of financing. I have asked this question some two years ago and am sorry to repeat it, but quite a time has passed already and there might be some change. Once construction starts, it will be too late then, I'm afraid.
If any of the banks will ever be involved in this particular project, please let us know, just to give us a chance to share our concerns about the huge seismic risk, including proof on the matter. In this way the decision will be taken after checking the relevant risk assessment information available.
Finally, here is the greatest news from last week - earlier in 2018 we had the opportunity to inform both EBRD and EIB that all their hydro investments in Bulgaria are illegal, due to the fact that the intakes are built up in the riverbeds, considered to be public state property, without any kind of building lease or concession contracts.
Last week the news came from the National Construction Control Directorate that a brand new small Hydro just recently built and finalized was not approved and was denied permission to start operation for not having such a contract. Moreover - the government refused to sign such contract and that plant will stay like a monument for good, while the illegal intake will be removed in accordance with the law, of course.
The plant has no name so far, but it is built on the Oshtavska River and the developer is "Electro Invest BG" Ltd.
We hope that the EBRD or the EIB have not financed this particular plant.
At the same time, if any of the banks still has some clients in Bulgaria whose plants are currently under construction, we also hope that developers will be advised to halt construction until the necessary permits are received, otherwise a lot of money will be wasted in the end. The state policy towards hydropower here has changed, you know.
As of today, judging from the action taken by the National Construction Control Directorate, the legal case is crystal clear as well.
Getting back to the environmental assessment issues in the end, I'm afraid that in the rest of Balkan states all EIA assessments are ten times worse than in Bulgaria - for Macedonia and Serbia I can guarantee that, based my personal experience.
Therefore, I really hope that some necessary conclusions will be drawn in due course.
And I also hope the both EBRD and EIB will find the above information useful and will withdraw from any future hydropower projects not only in Bulgaria, but in the entire Balkan region. It seems to us that there is a growing reputational and financial risk to be taken into consideration for all that hydropower craziness around the Balkans, while in Bulgaria the payback time has come. In Bulgaria things will get much worse once the EC opens the Water Framework Directive infringement procedure, which is inevitable. Then the most destructive hydro plants will have to be decommissioned and that is a promise too.
Sorry to have taken so much of your time, but I felt that the news is important enough to be shared with all of you.
Balkanka Association, Sofia, Bulgaria
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