A signal to the Chief Prosecutor of the Republic of Bulgaria
The National Association "Bulgarian Black Sea Coast" (NABBS) sends a signal to the Chief Prosecutor of the Republic of Bulgaria Sotir Tsatsarov that "The guide for identifying the habitats of European significance in Bulgaria", which is the official document working in the field of identification of the reference (basic) for Bulgaria natural habitats from Annex 1 - Directive 92/43 / EEC, is forged in the process of declaring priority habitats and areas of the NATURA 2000 network.
It is about the Kavarna crisis "Ponto-Sarmatian steppes", whose existence is not only inexplicable and unjustified for state institutions and local communities, but also completely illegal. A check of NABC experts raises doubts and questions that the emergence of the Ponto-Sarmatian steppes in Bulgarian legal peace is the result of documentary fraud, for which a criminal procedure has been taken against Bulgaria and a verdict of the court in Strasbourg has entered into force.
The chronology is as follows:
In 2005, with the signature of Minister Dolores Arsenova, the management of the habitats in the country, given our accession to the EU, was approved. In this Guide Code 6290, West Virginian steppe bears - as a small habitat, non-priority and not of European significance, ie. is not threatened by extinction. The determination of this habitat is based on the academic works of Bondev, Tsonev and others.
Given this fact, there were no indications in 2005 that areas with such habitats could become subject to drastic restrictions. Accordingly, investment projects in the Kaliakra region start in a period of economic upturn.
In fact, in 2009, whose instructions were unclear, the Manual was changed, and in the place of the "Western Pontic Pestilence Steppes" with code 6290 suddenly appear anonymously, without author and without any scientific justification, the Ponto-Sarmatian steppes with code 62C0 - An "asterisk" habitat. It covers almost 25 000 decares and creates preconditions for drastic limitations of human activities in the area of Primorski Dobrudja.
The main suspicions of misconduct come from the fact that nowhere in the revised 2009 manual. it is not described which expert and on what scientific data has included the Ponto-Sarmatu steppes with code 62C0. For what reason, by whom, how and why, the Ponto-Sarmatian steppes, which are not typical of our country, have been identified as a priority habitat 62C0?
Another thing that can be seen is that in the preamble of the revised 2009 manual, the Western Papyrus Steppes 6920 habitat is still present, which is described and included in the guide by the researcher Veska Rusakova.
Another important fact is that such habitat is not included in any text that served as the basis for the management.
Based on the doubts raised, the National Association "Bulgarian Black Sea" filed a signal to the Chief Prosecutor to investigate suspicions of replacement, falsification and / or unlawful and unjustified changes in the "Guidance on Habitat Designation of European Importance" the following negative consequences for Bulgaria arise:
- Payments in criminal proceedings and conviction and sanctions by the European Commission
- A wave of lawsuits against the state under the State and Municipal Liability Act for damage to thousands of landowners and contractors in the area who have suffered hundreds of millions of lost profits and damages.
- General damage to the state is already measured with millions of euros, without taking into account the losses of owners of land and projects affected by fraud.
We, from the National Association "Bulgarian Black Sea Coast", insist on revealing who has illegally replaced West Pontian steppe habitats with code 6290 with the priority habitats of Ponto-Sarmatian steppes with code 62С0. In order to understand the truth, it is necessary to make explanations from: the ministers who have led during this period of the environment and water, the heads of directorates and the experts from the Ministry of Environment and Water, the scientists who have been registered as having worked out the habitats in the two guides since 2005 . and 2009, as well as by the then Green Balkans and WWF-Danube-Carpathian program managers, as well as the editors and correctors of the issued guides.
Public disclosure of the above facts will help landlords and investors to understand, apart from the state, who else to direct their fair tangible claims for losses and lost profits, apart from criminal responsibility.
-Famximil of the 2005 Habitat Identification Guide of European Importance. signed by Minister Dolores Arsenova. It does not include the "Ponto-Sarmatian steppes" with code 62CO as a priority habitat.
-Faximile from the falsified "Guide to Habitat Designation of European Importance" from 2009, where "Pontos-Sarmatian steppes" code 6290 as a priority habitat are included in place of "Western Pontic Grass Steppes" with code 6290.
National Association "Bulgarian Black Sea"