National AssociationBulgarian Black Sea

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The Ministry of Environment and Water (MOEW) has proposed for public discussion a draft amendment to the Biological Diversity Act (BDA). These changes aim to introduce order in the management of Natura 2000 protected areas. Since the establishment of the zones to date, land owned by state, municipalities and private properties have been stolen and leased to the green octopus.

Every newly-discovered "environmentalist" could "find" primary data, such as a step from a beetle beetle or a lynx extinct lived 1200 years ago, and publish a "scientific report" in Slaveyche. This "undeniable" scientific information was submitted to the MOEW, the primary data being owned by the "environmentalist" and not given to the MOEW. This has led to the massive falsification of NATURA 2000 sites, and the "green" organizations responsible for this have skillfully introduced these "primary data" into commercial turnover and racketeering against the state, investors and landowners. The submitted proposal for an obligation for the persons and organizations that collect and analyze "primary data" on the habitats and species to submit them to the MOEW prior to their use, provokes fear and panic in the so- environmentalists, because they will reveal their entire scheme of absorption of colossal funds, and the primary data is owned by the owner of the property, not the collectors who entered the property without permission.

The amendments to the law set out the criteria that non-governmental organizations must meet in the field of environmental protection. They must work on the territory of at least two RIEWs and have at least three years of experience in this field. In addition, NGOs must demonstrate transparent governance to ensure that their membership is not only informed but also involved in decision-making. They should not have obligations to the state or municipalities where they are established. Regional non-governmental organizations will have to meet the same conditions. These criteria, according to NABBS, are rather low. Property owners have the material and moral right to protect nature, and nature without "environmentalists" can, but "nature conservationists" can not. This change has also embarrassed green nature privatists. TV shows are "we are very, we are strong" and the elections are shown as 0.5%.

The Ministry of Environment and Water more than two years ago organized a public debate on how to manage the Natura 2000 protected areas. Representatives of ministries, municipalities, regional governors, branch organizations, representatives of owners and users of properties, environmental NGOs, representing green and so on. The Minister of the Environment, together with experts, proposed two types of Natura 2000 management approach. The multi-stakeholder experts and stakeholder representatives, unanimously invited (with the exception of NGOs representing green and subsidized by foreign foundations and countries) that the most appropriate choice is at local level that private, municipal and state property included in Natura 2000 sites be managed by district administrations with the help of regional stakeholder committees.


Very strange how the RIEW was elected in the current amendments to the Biodiversity Act as regional authorities for the management of NATURA 2000 zones. It is clear that RIEWs will develop management plans themselves, will implement them themselves and will be checked themselves because the RIEW is the competent authority for the control of environmental protection in Bulgaria. The draft law also provides for the establishment of regional stakeholder committees involving representatives of local and regional authorities, regional bodies or regional representatives of industry, employers 'and other sectoral organizations, regional bodies or regional representatives of owners' organizations or land users or resources in NATURA 2000, regional non-governmental nature conservation organizations and others.

In the MoU, following the 11-year membership in the EU, the MOEW itself acknowledges that the Habitats Directive does not require Member States to introduce prohibitions on activities in protected areas. Practice shows that such a policy rather creates a negative attitude among stakeholders, towards nature conservation. In the other EU Member States, this approach does not apply.


Despite this confession, the Ministry of Environment and Water does not propose to abolish the anti-constitutional text of the law, which prohibits an administrative act of the Minister from appealing to the Bulgarian court - the prohibition (imposed on private property) is final and is not subject to appeal. In addition, the MoEW continues to disregard the provision in the European Natura 2000 Directive which states that there should be a CONTRACT between the State and the owner of the property if it is imposed prohibitions or restrictions aimed at conservation. Nature is a very expensive thing. Society wants to enjoy it. Part of this nature is privately owned, so society is obliged to pay the owner of the land for the nature preserved by him. Other forms of relationship-owner-ownership are either the theft of property or Bolshevik-totalitarian practices.


It is not possible to achieve the sustainable development set out in the amendments to the law - achieving economic development, ensuring a living standard and preserving and improving the environment in the future if the local communities do not have the right to decide the development of the protected area themselves their territory, and regional environmental inspections to control conservation.

The proposed amendments to the BDA are a stepping stone in the right direction, not turning NATURA 2000 into a green-octopus zoo, but being the best place for living and living.

National Association "Bulgarian Black Sea"



NABBS's position has been published in the following media: