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Case, "Kaliakra" - Declaration of NABBS







                                                 National Association "Bulgarian Black Sea"


     NABBS members, as natural persons or as members of previous NGOs since 2005, raise the issue of the incorrect way of creating the protected areas in Bulgaria that are part of the European Network of Natura 2000 Protected Areas. From 2013, After the establishment of NADP, the NADC has informed the public and various governments that the Natura 2000 protected nature conservation NGO network in Bulgaria creates preconditions for a conflict between nature and man, nature and sustainable development, nature And the development of the regions. Conflicts are set, perhaps deliberately, when the Biodiversity Act (BSA) is being transposed, which transposes the Birds and Habitats and Species Directives into Bulgarian legislation.
          Incorrect translation into Bulgarian of Article 2 (3) of the Habitats and Species Directives: "Measures taken on the basis of this Directive shall take account of economic, social and cultural requirements as well as regional and local specificities". The original translation of Article 2 (3) shall be: "Measures taken on the basis of this Directive shall comply with economic, social and cultural requirements as well as regional and local specificities". This leads to a distortion of the basic principle in the establishment and management of the Natura 2000 ecological network. Thus, when establishing the Biodiversity Act, the living entities owning or managing properties on the territory of the future Natura zone are excluded.
          Why the "consultants" of the law-makers who have submitted the law have done so, gives an answer, ,,Article 10 paragraph 6 of the BDA (New, SG 52/2007) The Ministry of Environment and Waters shall send to The European Commission for approval of the list of protected areas under Art. 6, para. 1, item 1 and 2, adopted by the Council of Ministers. The European Commission is sent for approval and a financial evaluation of the necessary co-financing by the European Community of the measures envisaged for preservation and / or restoration of the favorable status of natural habitats and species in the protected areas under Art. 6, para. 1, adopted by the decision under para. 4. "
           The more square kilometers reported for protected areas (then in 2005-2007), the more money in the budget and the "nature conservation" NGOs involved in the implementation of the Biodiversity Act and the announcement of the zones. In order to have total power over the future protected areas, the "consultants" of the BDA also introduced Article 12, paragraph 7 of the BDA: "The order under para. 6 is final and not subject to appeal. ''. This, although contradicting the Aarhus Convention, not only excludes but also prohibits the public's access to justice in environmental matters related to the creation of protected areas.
        Such a provision does not exist in any EU country.
          After the "consultants" and the creators of the Biological Diversity Act created the ideal conditions for unhampered mining of 38.5% of the territory of the Republic of Bulgaria, the creation of the "minefields" themselves, called PAHs of Natura 2000, started. The first mine thundered in the three municipalities of Shabla, Kavarna and Balchik. There will be hundreds of mines that are already piling up and activated.
 This grotesque distortion of the good idea of ​​creating the network of Natura 2000 protected areas leads not to nature conservation but to absolute power by a group of "nature conservation" NGOs for discharging rights deriving from ownership of property falling under 38.5 % Of the territory of the Republic of Bulgaria. The average percentage of EU PAHs is 18% (data from Mr Juncker's report; this report also states that the construction of the Natura 2000 network in the EU is complete).
            Such a type of deprivation of rights deriving from immovable property-properties is also effected by the presence of Article 24, para. 5, item 2 and 3 of the Agricultural Land Conservation Act (LPAL). The abolition of the right to own permanent properties - urbanized by those who have urbanized estates before 2011 (when the provisions of Article 24 (5) (2) and (3) of the IPPC have been adopted) and not Have fulfilled their investment intention. They are the next mines that will explode, not in the territory of 38.5% of the Republic of Bulgaria, but in all its territory.
       There is a definite pressure for the existence of these provisions of the LPPO to be carried out by the same group of "nature conservation" NGOs. The purpose of the group is for the owners to re-start a re-routing procedure that requires entry and the group's sole power is to approve the EIA, EA or OS. Under these procedures, the laws of the Biodiversity Act, the EPA and other laws allow the use of unregulated practices entitled "Keeping Nature".
            "Nature Conservation" NGOs directly harm millions of citizens in the Republic of Bulgaria and do not really bring any benefits to nature or people, and for these reasons, which is a small percentage of their misbehavior, we do not consider it moral to talk with Them.
            NABBS is an equal member of the European Commission in the International Capital Coalition (NCC) based in London, a member of the European Association of Real Estate Owners (ELO), based in Brussels. Our members produce part of Bulgaria's Gross Domestic Product (GDP). "NGO conservation NGOs" are consumers of budgetary resources and funds of the European taxpayer.
   We are ready to share our experience with the Government of the Republic of Bulgaria and to help minimize the damage from blasts from the mining field Bulgaria, such as:

1. We propose rational emergency measures to neutralize the damages in the municipalities of Shabla, Kavarna and Balchik. Damage caused by the 'active' work of 'environmental NGOs'.
2. Preparation of a proposal for the amendment of the LPPO in order to eliminate the negative consequences on the social status of the Bulgarians from the existence of Article 24, paragraph 5, items 2 and 3.
3. Proposals for amendments to the BDA and EPAs, their secondary legislation, in compliance with the EC report on action for nature, people and the economy;
4.Starting of the procedures under the current Art. 16 of the BDA for the purpose of transposing the PHS into Bulgaria in accordance with the provisions of Article 2, paragraph 3 of the Habitats and Habitats Directive after correcting the translation from the original English into the Bulgarian language .
On behalf of the Management Board
Truly Yours,
Dimitar S. Kanariev
Chairman of the Management Board of
National Association “Bulgarian Black Sea”