What are the problems with the eco-ministry's wetlands and Natura 2000 projects under the Recovery Plan

Raya Lecheva

Coalition "For nature to remain in Bulgaria" considers it unacceptable to refuse important projects for water, rivers and wetlands, laid down in the Recovery and Sustainability Plan. Environmental organizations announced this in a letter to the media. Already a week ago, the Minister of Environment and Water, Julian Popov, explained that the Eco-Ministry will abandon one of the projects under the Recovery and Sustainability Plan, related to the protection of ecosystems and wetlands.

Experts from the Ministry of Environment and Water explained last week that it is not about the whole project, but specifically about the wetlands, most of which are privately owned and in order to carry out activities in them, special permission is needed from their owners. That's why time is needed, explained the Eco-Ministry. In addition, additional communication with the European Commission is required, which may further delay the implementation of the entire project. With regard to the project to develop the specific objectives for the Natura 2000 areas, the eco-ministry said that they are working to fulfill it, because these are our most important commitments made in connection with the protection of the European ecological network.

According to the Coalition, however, the Ministry of the Environment and Water is considering implementing a project and a half instead of the three originally planned. Two are for biodiversity and climate, one for water, and the already approved or the three in total exceeds BGN 200 million. The Bulgarian recovery plan was approved in April 2022. According to the regulation on the recovery mechanism, according to which funds are allocated for investments, activities can be carried out until August 2026. Although all projects under the Plan have a commitment to set aside 30% of the funds for environmental activities, only two are targeted projects with the Ministry of Environment and Water as a direct beneficiary.

At the moment, because of the new section required by the member states under the update of the regulation, RePower EU, there will be talks with the EC, so where shorter deadlines are scheduled, they can be renegotiated. In March of this year, after inquiring about what was happening with the projects, WWF received a letter from the MoEW saying that they were working to make the projects happen. Half a year later, the news about the rejection of projects comes out publicly. Other ministries have already announced procedures and are working on them, environmental organizations are worried.

What's at stake in the planned logging project to restore key ecosystems?

The project envisages the creation of one new and restoration of 6 damaged wetlands, incl. The Dragoman swamp, the Chair Lakes and the Vitosha peatlands, etc.; Removal of artificial barriers at 400 km. rivers; Purchase of 285 ha of privately owned properties for the restoration of key climate ecosystems, preparation of a GIS layer of wetlands in Bulgaria. It is important to note that funds are committed to manage the entire project and individual groups of activities so as to take minimal capacity from the ministry's administration. The activities are aimed entirely at practical results, they fulfill objectives simultaneously for the protection of nature, water and adaptation to climate change. The removal of barriers, for example, is a measure that has been in the PURB for years, but has not been implemented. For years, the MoEW has not had a layer of wetlands.

The project on the objectives and measures of the protected areas

The main task of the other biodiversity project is to develop the conservation objectives and measures of the Natura 2000 protected areas. The Ministry is determined to fulfill it, although there is not much time left for it. In order to be fully implemented and not to waste time on public procurement, this project should be carried out by the scientists and experts of academic institutes such as BAS. This will avoid the blunder of the previous reporting of the conservation status of species and habitats from Natura 2000, when, due to long-term appeals, our country was left without field studies.

The Public Procurement Act allows public authorities to commission scientific developments directly. The project for an integrated water quantity management system envisages the creation of an automated system for real-time measurement of the available water resource in water bodies, the amount of precipitation, quantities of water used by all users and the quantities of water released into the rivers. This would give a clear idea of which user, how much water is used or discharged, and whether the environmental obligations are respected in this use of the water bodies. Building the system would shorten disaster response times and improve control over the use of water resources. This information is key to properly planning climate adaptation measures and to stop network losses and theft. The last task is particularly important, given the fact that systematically, for over 10 years, network losses have been 60%. However, the Minister of Environment and Water, Julian Popov, commented on BNT that it is also possible to give up, because there is already such a monitoring system in the Ministry of Education, Culture, Sports and Science, and separately the BAS is also working in this direction and duplication of activities could occur, it was happening then clear from his words.

Environmental organizations will propose solutions to implement the projects in their entirety

On August 23, with NGOs from the Ministry of Environment and Water, they announced that they had not categorically given up on the ecosystem restoration project. Representatives of the coalition have committed to propose activities that can be implemented in the remaining deadlines and have already submitted an official letter with these proposals, the Coalition commented.

A key objective of the Recovery and Resilience Facility, apart from economic support post-Covid-19, is to support the green transition, with the regulation requiring 37% of the recovery plan budget to be earmarked for activities to address climate change. This also includes investments in biodiversity protection. However, the emphasis in the Bulgarian plan fell entirely on climate activities, and the initial budget for biodiversity activities was 0.23% of the entire plan budget. After adding the ecosystem restoration project, biodiversity funding rose to 1% of the plan's budget. Although negligible in the background of the general plan, Bulgaria was given as a good example of a country from Central and Eastern Europe that has committed funds to nature protection.

The Environment Program 2021 - 2027 also has funds earmarked for biodiversity, worth less than 10% of the entire program budget. There, activities are already planned and ambitious – they include nature conservation measures in Natura 2000 protected areas, outside protected areas, as well as urban greening. However, the legislation treats nature projects in the program almost like construction projects, lacks the flexibility needed to work with living systems, and besides, this axis has not been a priority until now.

The results of these problems are there - already the second financial period, the funds are not used enough. With 3 months remaining until the end of the OPE 2014-2020, only 42% of the biodiversity funds have been used. Therefore, the idea of transferring the activities to the new PES 2021 - 2027 is not particularly convincing even for those who propose it.

There were also concerns about the duplication of funds - what is covered by the Environment program and what by the Recovery Plan. They are unfounded: the new "Environment" program itself envisages that the activities in the PVA are complementary to the activities under the PES, and avoiding duplication is done on the basis of the relevant codes of habitats, target species and protected areas, commented the Coalition "To Remain Nature in Bulgaria".