When the people of Stara Zagora in Bulgaria talk about European money it is not with the excitement typical of new member states. It comes instead with deep concern. The people of Stara Zagora do not want the 'development' being offered by the Bulgarian government, keen to spend EU money on a massive incineration complex for hazardous waste.

An angry crowd gathered recently in front of the Ministry of Environment and Water (MoEW) in Sofia. But the government did not listen. Manoela Georgieva, the deputy Minister, said: "This project is very important to us because we've already invested too much money and we now expect to be financed by ISPA!"(1). The Ministry is set on riding roughshod over the views of local people and ignoring the alternate proposals on the table of using non-combustion technologies or a developing a decentralised system for the treatment of hazardous waste.

The construction of two hazardous waste incinerators only two kilometres from the nearest village, Kovachevo, and very close to four other villages will be the result of the centralised planning for the treatment of hazardous waste in Bulgaria. The National Hazardous Waste Centre (NHWC) will be sited in an already polluted area where three thermal power plants and three open coal mines are operational - the region of Stara Zagora. A three phase construction of the centre is envisaged over a 15 year period. During the first phase (2004-2007 at a cost of EUR 55,5 million) a 15 000 tonnes/year incinerator(2) will be built. The Bulgarian government is keen to get a large part of the cash from the EU with a grant through ISPA(3) funds (covering 50% of the project) and the other 50% from the European Investment Bank (EIB) - a low interest loan.

Legal problems

The story starts in 2000 when the Bulgarian government tender for the preparation of the NHWC project was won by the consortium of Danish Chemcontrol and German Fichtner. By May 2001, the procedure for public discussions of the preliminary Environmental Impact Assessment (EIA) report was opened. Yet, approval of the EIA report by the MoEW Supreme Environmental Expert Council (SEEC) was given only one day after the public hearing - removing the legal right of the participants to submit additional statements up to 14 days after the hearing. The glaring weaknesses of the EIA report exposed during the hearing could not thus be challenged. By the end of May 2001 the project had been submitted to ISPA for financing.

But the local people - by now organised into committees in the five nearest villages - continued to oppose the project and with the support of NGOs, appealed direct to the EU ISPA programme. The European Commission rejected the project, deeming it 'unready' from an economic point of view and recommended an investigation into dioxin contamination risks. The Bulgarian Ministry has not taken any steps to look into the dioxin risks to local people and the environment. Instead a redesigned proposal has been submitted: instead of one incinerator there are now two proposed. Rationale given: reduce the economic risks of the project.

Environmental problems

In March 2004, the Ministry of Environment invited several NGOs to a meeting on the project and promptly ignored all concerns:

• Alternatives to incineration technologies have not been considered, although NGOs submitted proposals for noncombustion technologies in 2001 and again in 2004. The "alternatives" mentioned by the Bulgarian government (Pyrolysis, Plasma techniques and Waste gasification) are in fact "Incineration technologies" according to EU Directive 2000/76 on waste incineration. EU directives state that incineration (and landfill) are the least best options for sound waste management.
• The project is not economically viable. Even with 50% financing from ISPA, the project will not produce enough revenue for reinvestment when the lifetime of the equipment expires. What's more, the risk is that such a subsidized system will create economic incentives for the import of hazardous waste into Bulgaria from EU countries. The fees proposed are of 27-40% less than the European average for waste treatment.
• A decentralised system for the treatment of hazardous waste has not been considered. The centralised system proposed, far from the main sources of hazardous waste, will also mean increased risks for those that live alongside the transport routes, from the large quantities of hazardous waste being moved. No assessment of this impact has been undertaken. Moreover, in some of the project documents it is clearly stated that: "Due to the present difficult financial situation in Bulgaria it must be expected that it will be difficult to encourage waste generators to send the accumulated waste to the centre" and "For Bulgaria, we expect the collection of newly generated waste to start very slowly and then within 5-8 years to reach a capture rate of up to 80%"(4).
• The Environmental Impact Assessment (EIA) states that there won't be any health risks for the local people and the environment except in an eventual emergency situation. Yet no data is provided on the current levels of toxic substances in the local area and no data has been sought or is foreseen for blood, breast milk and food. This lack of data and the unwillingness of the Ministry to collect it calls into question the conclusion that there are no health risks for local people.
• There is a conflict of interests within the Ministry of Environment and Water. The MoEW is the project investor, the eventual issuer of the legal permit to operate, and, through its local structure, will oversee the health and safety of the operation including any accidents.

Public participation blocked

More than 21 000 people live in the 10 kilometers zone around the proposed site. They had only one month in which to access the only available paper copy of the EIA report. A request (through the Joint Initiative Committees of the affected villages and NGOs - Za Zemiata and CEIE) for one copy of the EIA report for each of the seven locations was ignored. And on September 9 and 10 public hearings were conducted in just two of the seven locations affected: Radnevo and Nova Zagora, despite a request for five additional hearings. Requests for greater access to information have also been ignored. Unfortunately, Bulgarian law does not require that public demands and statements be taken into consideration. After the September hearings, NGOs and local Committees submitted over 30 pages of comments to the MoEW yet in the resolution of the Supreme Environmental Expert Council (SEEC), 7 October 2004, approving the EIA report, it is stated that no comments had been submitted (sic)! Further, while the Muni-cipality Council of Rad-nevo had voted against the project in January 2004, during the public hearings in September 2004, the Mayor of Radnevo stated that the Municipality had given a positive appraisal to the EIA report.

Local people and authorities united

Since then, the chairs of all permanent commissions of the Radnevo Municipality Council have met and have confirmed their opposition to the project. There is virtually no positive feeling about the project from the local municipalities. That coupled with the resistance of the local people, united in a Joint Initiative Committee against NHWC, gives hope for the local community united against the central powers. More than 3000 signatures have been collected against the project and on 7 October a protest in front of the MoEW during the SEEC session led to the submission of a letter to the European Commission (DG Environment and DG Regional Policy) and the European Investment Bank, appealing to the European institutions not to finance the project.

It's up to EU

The final decisions of the European Commission and the EIB are not yet known. The people of Bulgaria can but hope that someone will listen to them. Welcome to the European Union Stara Zagora!

Magda Stoczkiewicz
Friends of the Earth Europe - CEE Bankwatch Network  

References:

(1) On June 24, 2004 an official meeting between representatives of MoEW, the Delegation of EC to Bulgaria, CEE Bankwatch Network, CEIE, Za Zemiata took place at the MoEW.

(2) In the new project proposal there are two incinerators planned to be constructed: one for 15 000 tonnes/year and another for 30 000 tonnes/year. The second incinerator is planned as additional and the construction is for 2015. In the first project proposal (year 2000) there was one incinerator for 40 000 tonnes/year.

(3) Instrument for Structural Policies for Pre-Accession (ISPA) is one of the EU financial instruments to assist candidate countries in their preparations for accession.

(4) Waste Survey under PHARE project BG 9810-02-01 (003)- Preparation of the ISPA Application Form for the project "Establishment of National Hazardous Waste Centre"