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F I N A L

SER Environmental Report Strategic Environmental Review of the

Development of Wind Power in Bulgaria

Prepared for:

Bulgarian Ministry of Economy, Energy and Tourism (MEET)

Prepared by: ENVIRON Iberia, pm&E, POVVIK AD

Date: June 2010

Project Number: ES11BUL001

F I N A L

Acknowledgements The content of this report was significantly improved by the contributions of many people from various institutions and organizations. We would like to express our gratitude to Petar Shurulinkov, PhD (Institute of Zoology (IZ) at the Bulgarian Academy of Science (BAS)), Stoycho Stoev (Bulgarian Society for the Protection of Birds (BSPB)), Dobromir Dobrinov (Green Balkans Federation), Andrey Kovatchev (Balkani Wildlife Society), Hristo Pedashenko, PhD (Institute of Botany (IB) at BAS), Svetla Bratanova, PhD (Central Laboratory for General Ecology (CLGE) at BAS), Ventcislav Delov, PhD (Biology Department at the Sofia University), Nikolay Karaivanov (IZ at BAS), Petar Yankov, PhD (BSPB), Valeri Georgiev ( IB at BAS), Zhivko Bogdanov (World Wildlife Fund (WWF) Bulgaria), Yavor Yordanov (Soil Resources Agency), Georgy Stoyanov (Society for the Protection of Birds of Prey), Valko Biserkov, PhD (CLGE at BAS), Lubomir Profirov (Independent consultant), Zheko Spiridonov (Nature Fund), as well as to many other experts not mentioned here, who provided data and expert opinions on volunteer bases, which helped this report become more objective, accurate and relevant to the situation in Bulgaria. Special thanks to the Bulgarian Society for the Protection of Birds, the Bulgarian Academy of Science, the Balkani Wildlife Society, the Green Balkans Federation and the World Wildlife Fund Bulgaria for providing large data sets, many of which not publically available, which allowed the Consortium to conduct analysis of the spatial constraints to wind power development from the biodiversity point of view.

F I N A L

This report has been prepared by ENVIRON with all reasonable skill, care and diligence, and taking account of the Services and the Terms agreed between ENVIRON and the Client. This report is confidential to the client, and ENVIRON accepts no responsibility whatsoever to third parties to whom this report, or any part thereof, is made known, unless formally agreed by ENVIRON beforehand. Any such party relies upon the report at their own risk.

ENVIRON disclaims any responsibility to the Client and others in respect of any matters outside the agreed scope of the Services.

Version Control Record

Issue Description of Status Date Reviewer Initials Authors Initials

1 First Draft 27 Jan. 2010 JC JS

2 Final Draft 30 April 2010 PW/JC/MC JS/DD

3 Final Draft with MEET and EBRD comments 12 May 2010 PW JS/DD

4 Final SER Report 18 June 2010 PW/MC JS/DD

SER Environmental Report

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Table of Contents Non Technical Summary

1 Introduction 1 1.1 Background and Context 1 1.2 Strategic Environmental Review 2 1.3 Objectives of the SER 3 1.4 The SER Process 4 1.5 SER Report 4 1.6 Implementation of the SER of the wind power development in Bulgaria 5

2 Development of Wind Power in Bulgaria 6 2.1 Introduction 6 2.2 Wind Potential in Bulgaria 6 2.3 Installed and Planned Wind Power Capacity in Bulgaria 7 2.4 Regulatory Framework and Policy Context 9 2.5 Drivers for the Development of Wind Power in Bulgaria 11

3 SER Approach 13 3.1 Diagram of the SER Process 13 3.2 SER Stage A – Scoping and SER Objectives 14 3.3 SEA Stage B – Generating Alternatives, Assessing and Monitoring Effects 15 3.4 SER Stage C/D – Public Consultation on the SER Environmental Report and Finalisation of the SER Environmental Report 24

4 SER Consultation 25 4.1 Selected representative areas for the consultation process 25 4.2 Scoping Consultation 27 4.3 Consultation on the Draft SER report 29 4.4 Timetable for the draft SER consultation process 30 4.5 Information disclosure during the draft SER report consultation process 30 4.6 Information disclosure at the end of the project 30

5 Policy Context and Baseline Review 31 5.1 Summary of Policy Context, Baseline Review and Key Environmental and Social Issues 31 5.2 SER Objectives and Indicators 50

6 Results of the Assessment 55 6.1 Approach to the SER assessment 55

7 Constraints Analysis 75 7.1 Data gathering 75 7.2 Levels of area sensitivity 76 7.3 Constraint Analysis by SER Topics 78 7.4 Summary of Constraints Analysis 116 7.5 Composite Constraints Analysis 121


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7.6 Limitations of the performed spatial constraints analysis 125 7.7 Recommendations for further spatial analysis 126 7.8 Spatial analysis of current wind power development in Bulgaria 126

8 Recommendations on future wind power development in Bulgaria 132 8.1 Recommended mitigation measures 132 8.2 Recommended monitoring measures 137 8.3 Recommended considerations for the Environmental Impacts Assessments (EIA) process 138

9 Conclusions 147

10 ANNEX 150

APPENDIX A: Performance of the SER Report

APPENDIX B: Evaluation of Significant Effects

APPENDIX C: Example of a metadata form

APPENDIX D: Data sets detailed information

APPENDIX E: Identification of indicative GIS polygons with importance for conservation of bats (Mammalia: Chiroptera) in Bulgaria

APPENDIX F: Main directions for investigating the behavior of birds and bats, as a risk indicator at operational wind farms and future wind projects

APPENDIX G: Minutes of SER consultation meetings

APPENDIX H: Clarification notes on the statements received during SER consultation process


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List of Abbreviations and Acronyms

AES Alternative Energy Sources

AS Alternative Sources

APEE Association of the Producers of Ecological Energy

BAS Bulgarian Academy of Sciences

BEH EAD Bulgaria Energy Holding EAD

BSPB Bulgarian Society for the Protection of Birds

MEET Bulgarian Ministry of Economy, Energy and Tourism

MoEW Bulgarian Ministry of Environment and Water

MRDPW Bulgarian Ministry of Regional Development and Public Works

CH Cultural Heritage

DWPB Development of Wind Power in Bulgaria

EA Environmental Assessment

EIA Environmental Impact Assessment

EPA Environmental Protection Act

EBRD European Bank for Reconstruction & Development

EU European Union

GHG Greenhouse Gases

GDP Gross Domestic Product

HPPs Hydropower Plants

MW Mega Watts

Mtoe Million Tons of Oil Equivalent

NEK EAD Natsionalna Electricheska Kompania EAD

NREAP National Renewable Energy Action Plan

NOx Nitrogen Oxides

NGOs Non-Governmental organizations

NTS Non Technical Summary


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NPP Nuclear Power Plants

ODPM Office of the Deputy Prime Minister

PPPs Plans, policies, programmes

PAH Polycyclic Aromatic Hydrocarbons

PDCP Public Disclosure and Consultation Plan

PSHPPs Pump and Storage Hydro Power Plants

PSPs Pumped Storage Plants

RIEW Regional Inspectorate on the Environment and Water

RAESBA Renewable and Alternative Energy Sources and Biofuels Act

RES Renewable Energy Sources

RS Renewable Sources

SCI’s Sites of Community Importance

SEA Strategic Environmental Assessment

SER Strategic Environmental Review

SEWRC State Energy and Water Regulatory Commission

SG State Gazette

SPA’s Special Protected Areas

TWh Terawatt hour

ToR Terms of References

TPPs Thermal Power Plants

UNESCO United Nations Educational, Scientific, and Cultural Organization

WTG Wind Turbine Generator

WF Wind Farm


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SER Environmental Report Strategic Environmental Review of the Development of Wind Power in Bulgaria Non Technical Summary Project Background The development of environmentally sustainable sources of electricity is increasingly becoming a priority for governments and a business opportunity for national and international developers. Wind power is among the renewable energy sources (RES) that has experienced the strongest growth over the past decade.

Wind power provides clean energy and its incorporation into the Bulgarian energy mix will help the country to meet its acquired obligations towards the EU with respect to the percentage share of energy from RS in the gross final energy consumption in 2020. The manufacture, installation and maintenance of wind turbines will constitute a source of work and income for the country. The use of wind power will also reduce the dependency on foreign energy suppliers.

However, in many countries including Bulgaria, the implementation of wind power has proceeded at greater pace than the development of the accompanying governmental policies.

This environmental report has been prepared by a Consortium led by ENVIRON Iberia S.L (hereinafter “the Consortium”) as part of a project aimed at assisting the Bulgarian Ministry of Economy, Energy and Tourism (hereinafter the “MEET”) with the preparation of a policy for the sustainable development of wind power in the country. The project is funded by the Spanish Government through the EBRD-ICEX Technical Cooperation Funds and the contracting party is the MEET”.

This project will provide the following main deliverables to the MEET:

• A Strategic Environmental Review (hereinafter SER) of wind-power development in Bulgaria which assesses both the positive and negative aspects of wind power, and outlines measures to mitigate the negative aspects to acceptable levels;

• A Best Practise Guide for the implementation of wind power in Bulgaria. This Guide will be presented as a separate document.

The SER is undertaken at a policy/strategy level and includes a process of public consultation from relevant stakeholders has been obtained and has been included in the assessment. The outcome of the SER is intended to advise and inform the development of wind power at a national level through forthcoming MEET documents, regulations, etc. The degree to which recommendations will be incorporated into Bulgarian policy has to be determined by the MEET and other institutional stakeholders.

The recommendations included in this report are based on broad international experience in implementing wind energy programmes and on local, regional and national information on the environmental and social conditions of Bulgaria that has been obtained through the collaboration of Bulgarian governmental entities, academic institutions as well as NGOs and independent experts.

Development of Wind Power in Bulgaria In 2005, Bulgaria had 7,5 MW installed wind power capacity. Based on information available until March 2010, the current Bulgarian total installed and operating capacity is 351,6 MW,


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representing a 46-fold increase in just five years. According to the MEET, in 2009 wind energy represented 6.4% of the electricity produced by Renewable Energy Sources (RES) and 0,6% of the gross inland electricity consumption. The contribution of wind power is expected to increase even further in the coming years. Assuming that most of the projects that are currently being initiated will be implemented, total wind power capacity is expected to reach 2,371.8 MW, which is equivalent to the generation of 4,744 GWh/year or around 13% of the present gross inland electricity consumption.

According to the information provided by the Regional Inspectorate on the Environment and Water (RIEWs), in the period January 2003 – December 2009 at least 2,840 wind turbines were approved by the RIEWs in Bulgaria. Out of these 2,840 approved wind turbines, 2,365 turbines (or 83%) appear to have been approved by the RIEWs without an EIA - during the screening phase of the EIA process it was decided that an EIA was not needed. Most of the turbines approved without an EIA are described as either single turbines or small scale projects (up to 7 turbines). However, many of them are located on adjacent land plots and in some cases the notifications for the construction of a series of turbines on adjacent plots have been submitted at about the same time. Therefore, the practice of project splitting seems to have been used in a number of occasions to split larger wind projects into smaller ones, in order to avoid the conduct of an EIA.

Given this expected increase and in order to make sure that sufficient attention is paid to the environmental sustainability aspects of wind power projects, it is important to establish a clear strategy for wind power development in order to guarantee the correct implementation of wind power projects in Bulgaria in a way that is technically and economically viable, and environmentally and socially sustainable.

The SER Process - What is the SER?

The approach that has been taken for the performance of the SER is based on existing protocols for Strategic Environmental Assessment (hereinafter SEA). The SEA represents a systematic way to examine the likely effects of a strategic action on the environment and to suggest ways to either enhance or to mitigate these effects. The formal SEA process as required by European1 and Bulgarian2 law applies to the assessment of specific plans or programmes. Given that at the start of this project there was no formal wind power development plan or programme in Bulgaria, the environmental and social dimensions of the development of wind power in Bulgaria could not be assessed by a formal SEA which complies with all mandatory requirements. Therefore, the Consortium, with the approval of the MEET, the Ministry of Environment and Water (MoEW) and the European Bank for Reconstruction and Development (EBRD), decided to undertake a SER which draws on best practice and relevant approaches from the application of a SEA.

The structure of the SER on the development of wind power in Bulgaria is presented as a diagram on Figure Non Technical Summary 1 (NTS1).

1 Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment 2 Regulation on the Conditions, Procedures and Methods for Environmental Assessment of Plans and Programs (promulgated SG issue 57/2.02.2004, last amended SG issue 29/16.04.2010)


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Figure NTS1: Diagram of the Development of Wind Power and the SER Processes


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Stage A – SER Scoping and SER Objectives

The scoping stage was aimed at defining the framework for undertaking the SER, together with the collection of an evidence base to inform the assessment itself. This project stage included the preparation of seven Topic Papers which in conjunction provide a summary of Bulgaria’s environmental and social conditions in areas that relate to wind power development. The Topic Papers were prepared under the following headings:

• Energy, Climate and Air Quality (Topic Paper 1);

• Cultural Heritage (Topic Paper 2);

• Fauna, Flora and Biodiversity (Topic Paper 3);

• Soil and Water (Topic Paper 4);

• Landscape (Topic Paper 5);

• Public Health, Noise and Vibration (Topic Paper 6);

• Socio-Economic and Material Assets (Topic Paper 7).

The Topic Papers are provided in full on the project website3. All relevant information that has been obtained during the preparation of the Topic Papers is included in the Final Scoping Report4 which also has been uploaded on the project website. Each Topic Paper contains information about the following issues:

• Policy context (review of other plans, policies, programmes and their objectives);

• Baseline data review;

• Issues identified and implications for the development of wind power generation in Bulgaria; and

• Suggested SER objectives and indicators (parameters to identify, describe and assess the positive and negative aspects of wind power development).

The scoping stage also included a public consultation process to obtain input and feedback from relevant stakeholders. It was agreed to carry out the SER consultation process at the national level and also within specific areas selected as being representative for issues typically related to wind power development in Bulgaria. In order to identify representative areas, the Consortium took into account available information regarding the following selection criteria: Wind Potential; Potentially Affected Population; Environmental Constraints; Installed Wind Power Capacity; and Future Wind Energy Developments. Two different types of areas were selected with the following characteristics:

• Consultation Area A: Krumovgrad-Momchilgrad. This is an inland area with many small wind power developments, where individual wind turbines are progressively added which gives rise to a larger cumulative impact; and

• Consultation Area B: Burgas-Aytos. An area with large-scale wind power generation, located at the Black Sea coast, and with relatively well known bird migratory patterns.

At the national level a series of technical workshops and meetings were organised.

3 Project website can be accessed at www.bgwindenergy.com 4 Final Scoping Report can be consulted at the Project website: www.bgwindenergy.com


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Feedback from the scoping process was, together with final SER objectives and indicators, included in the Final Scoping Report8.

SER Stage B – Generating Alternatives, Assessing and Monitoring Effects

The SER covers the whole territory of Bulgaria and has to address many complex issues and interrelationships which are related to the implementation of wind power. This project stage was centred around two main elements:

• The collection of a vast database on environmental and social conditions of the country which are related to wind power implementation; and

• The interpretation of the effects of wind power implementation and the identification of measures to mitigate negative effects and to enhance the positive ones, based on the elaboration of the SER objectives and indicators.

Relevant environmental and social data was received from a large variety of Bulgarian stakeholders, and additional information was compiled by the Consortium using international data sources. Following discussions with stakeholders and the MEET, it was agreed to use a Geographic Information System (GIS) for the analysis of environmental constraints for the development of wind power and for the presentation of the obtained results. The GIS analysis is based on electronic layers of data, representing certain environmental conditions. Assessing the implications of wind power development on these environmental conditions and combining the layers in specific ways facilitates the identification of areas of potential constraints with regard to wind power development.

It is noted that no reliable information was available on wind potential in the country, and therefore this element could not be incorporated into the data analysis.

The likely impacts of current wind power development in Bulgaria have been considered in relation to each SER objective and the significance of these likely impacts on each SER objective has been assessed. Table NTS1 presents the positive and negative effects that wind power implementation is expected to cause on the environmental and social fabric of Bulgarian society.

Table NTS1 - positive and negative effects of wind power implementation

SER Objectives SymbolLevel of

Significance Positive or

Negative

1.1. Reduce the growing dependence on energy imports within Bulgaria. Major Positive

1.2. Support compliance with the Bulgarian national targets for % of energy from RS in the gross final energy consumption.

Major Positive

1.3. Reduce the overall emissions of greenhouse gases associated with energy generation and support compliance with the Bulgarian greenhouse gas emission targets.

Major Positive

1.4. Reduce the overall emissions of air quality pollutants associated with energy generation and support compliance with the air quality pollutants targets.

Major Positive

2.1. Reduce the risk of potential impact on the boundaries of the Bulgarian and World Cultural

Partial Negative


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Table NTS1 - positive and negative effects of wind power implementation

SER Objectives SymbolLevel of

Significance Positive or

Negative Heritage Properties.

3.1. Reduce the risk of potential impact on threatened and migratory birds and bats. Major

Negative

3.2. Reduce the risk of potential impact on flora and fauna.

Minor Negative

3.3. Reduce the risk of potential impact on Protected territories (under the Bulgarian Protected Territories Act).

Major Negative

3.4. Reduce the risk of potential impact on NATURA 2000 sites. Major

Negative

3.5. Reduce the risk of potential impact on forests. Minor Negative

4.1. Reduce the risk of potential contribution to soil erosion.

Partial Negative

4.2. Reduce the risk of potential mobilization of anthropogenic contaminants during construction.

Partial Negative

4.3. Protect soil resources with significant economic value.

Partial Negative

4.4. Reduce the risk of potential impact on surface water and/or groundwater quality.

Partial Negative

5.1. Reduce the risk of potential negative landscape transformation.

Minor Negative

5.2. Reduce the risk of potential impact on visual value of landscape. Major Negative

6.1. Reduce the risk of potential impact from noise caused by the interaction of the turbine blades with the wind.

Partial Negative

6.2. Reduce the risk of potential impact on public health due to shadow flicker effect.

Partial Negative

7.1. Reduce the effect on property values of developed area and adjacent properties.

? Uncertain Uncertain

7.2. Attain positive contribution towards employment and secondary economy.

Partial Positive

7.3. Reduce the risk of potential impact on other sectors (conventional tourism, hunting, eco-tourism, etc.).

? Uncertain Uncertain

7.4. Reduce the risk of electromagnetic interferences with signals relevant to human activities.

Partial Negative

7.5. Contribute to the development of power transmission and road infrastructure.

Partial Positive


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The data assessment also identified the constraints which wind power development faces in Bulgaria. These constraints are related to effects that wind power development will have on fauna, flora and biodiversity. Table NTS2 presents the five sensitivity levels that were defined in order to classify these constraints, and includes examples for each level.

Table NTS2 – Sensitivity classification

Colour code Level Example

Black Explicit legislative prohibition for wind power development;

World Heritage Properties

Red High sensitivity to wind power development

Annex I habitats in pSCI/SCI NATURA 2000 zones

Orange Medium sensitivity to wind power development

Areas with medium conservation importance for bats

Yellow Low sensitivity to wind power development

Proposed plant microreserves

White No or unknown sensitivity to wind power development

Class I from CORINE Landcover except settlements

A summary of the sensitivity levels for the identified constraints is provided in Table NTS3. In order to allow visual representations of these areas, a set of maps was created with information that was available and accessible as of June 14th, 2010. It should be noted that table below summarized only the data which has been obtained and analyzed. There were data sets which have been requested but were not provided within the duration of this project.

Table NTS3 - Summary of the sensitivity levels for the identified constraints

Area type Spatial areas of constraint Sensitivity

level (P/H/M/L)5

Color designation

Cultural heritage World Heritage Properties P

Flora, fauna and biodiversity, except

bird species and bird related areas

Areas with conservation importance areas for bats H/M/L

Annex I habitats in pSCI/SCI NATURA 2000 zones H

Habitats of Annex II species in pSCI/SCI NATURA 2000 zones

H

Bear and wolf avoidance in pSCI/SCI NATURA 2000 zones

H

Bear bottleneck sites outside pSCI/SCI NATURA 2000 zones

M

Proposed plant microreserves; Important plant areas L

Protected Territories (under Protected Territories Act) P/H

NATURA 2000 – pSCI/SCI M

Forests with high biodiversity value M

Non fragmented large forest landscapes L

5 P = prohibited, H = high, M = medium, L - low


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level (P/H/M/L)5

Color designation

Migration, roosting, staging and

wintering areas

Migration routes H/M/L

Known roosting sites of storks, pelicans and raptors H

Staging areas and flying corridors of Imperial Eagle (Aquila heliaca)

H/M

Staging areas of Black Vulture (Aegypius monachus) H

Staging areas and flying corridors of Saker Falcon (Falco cherrug)

H/M

Feeding areas of Red-breasted Goose (Branta ruficollis)

H/M

Staging areas of Dalmatian Pelican (Pelecanus crispus) H

Known wintering areas of geese H

Waterfowl congregations and

colonies

Wetlands with high waterfowl concentrations H/M/L

Bird colonies H

Breeding areas - breeding areas of

globally threatened species

Imperial Eagle (Aquila heliaca); Saker Falcon (Falco cherrug); Red-footed Falcon (Falco vespertinus)

H

Egyptian Vulture (Neophron percnopterus) N/M/L

Breeding areas - known breeding areas of EU level

threatened species

Griffon Vulture (Gyps fulvus); White-tailed Eagle (Haliaeetus albicilla); Golden Eagle (Aquila chrysaetos)

High

Black Stork (Ciconia nigra); Honney Buzzard (Pernis apivorus); Black Kite (Milvus migrans); Short-toed Eagle (Circaetus gallicus); Marsh Harrier (Circus aeruginosus); Montagu’s Harrier (Circus pygargus); Levant Sparrowhawk (Accipiter brevipes); Long-legged Buzzard (Buteo rufinus); Lesser Spotted Eagle (Aquila pomarina); Booted Eagle (Hieraaetus pennatus); Peregrine Falcon (Falco peregrinus); Capercallie (Tetrao urogallus); Eagle Owl (Bubo bubo)

Medium

Breeding areas – suitable habitats,

where globally threatened species

have been observed

Corncrake (Crex crex); Red-footed Falcon (Falco vesperinus)

Medium

Breeding areas – suitable habitats for EU level threatened

species, where species have been

observed

Honney Buzzard (Pernis apivorus); Black Kite (Milvus migrans); Short-toed Eagle (Circaetus gallicus); Marsh Harrier (Circus aeruginosus); Montagu’s Harrier (Circus pygargus); Levant Sparrowhawk (Accipiter brevipes); Long-legged Buzzard (Buteo rufinus); Lesser Spotted Eagle (Aquila pomarina); Booted Eagle (Hieraaetus pennatus); Peregrine Falcon (Falco peregrinus)

Low


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level (P/H/M/L)5

Color designation

White-tailed Eagle (Haliaeetus albicilla); Golden Eagle (Aquila chrysaetos); Osprey (Pandion haliaetus)

Medium

Areas of reintroduction of

threatened species

Griffon Vulture (Gyps fulvus) – reintroduced within 1 year

Medium

Areas specifically designated for bird

protection

Important Bird Areas High

NATURA 2000 SPA P/H/H

Protected territories designated for bird protection M

Soil and water Sanitary protection zones I, II and III P/H/M/L

Public health, noise and vibration

Buffer zone around settlement boundaries P

The results of the constraints analysis can be summarised as follows.

In limited regions within the territory of Bulgaria the implementation of wind power is currently legally prohibited. These are mainly specially protected natural areas, where also most other forms of economic activities are prohibited. This includes the current prohibition to implement wind power within 500 m from settlements.

The rest of the country shows various types of sensitivity based on local and regional conditions. The eastern and southern portions of the country generally are the most sensitive, and this is mainly due to the presence of threatened bird species.

It is important to note that the levels of sensitivity which have been used for this assessment are based on expert opinions of Bulgarian scientists and renowned environmental NGOs. However, it is recognised that many data gaps exist, and that the opinions regarding the sensitivity of specific species and habitats may not be shared among all experts. It was beyond the scope of the current project to perform extensive cross-checking of the received information. Therefore, the Consortium recommends that work groups are established by the MoEW in collaboration with the MEET to review the data base and the sensitivity classification, in order to finalise the basic sensitivity classification of the country with regards to wind power.

Furthermore, it is recommended that this classification, and the underlying data base, should be periodically updated with the help of both governmental information and data provided by investors and NGOs. The database should therefore also be publicly accessible.

Site selection criteria and mitigation measures

Specific recommendations have been made for the conduct of EIAs of projects falling within each of the sensitivity area, where the proposed level of detail and stringency of the EIA corresponds to the level of sensitivity. Wind power development in areas with high sensitivity is should be approached with upmost care and a detailed EIA is recommended for these areas to confirm the environmental viability of projects and to define the scope of the required mitigation measures. In areas with lesser sensitivity, the EIAs can be less detailed, and the scope of required mitigation measures is likely to be more limited.


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It is considered to be important that the EIAs that are performed for the high sensitive areas are reviewed at national level by the MoEW. Clarifications and support may be asked from the regional inspectorate, within which jurisdiction the project falls, but it is our recommendation that the final official decision should be taken by the MoEW. Such centralized decision making will ensure that these projects are assessed with the highest attention by the public and by the competent authorities with the highest level of expertise.

SER Stage C/D – Public Consultation on the SER Environmental Report and Finalisation of the SER Environmental Report

Consultation meetings were conducted with the identified stakeholders as well as with the general public to discuss the contents of the Draft SER Report. The consultation meetings for the SER process are presented in Table NTS4.

Minutes of all conducted meetings were recorded and are summarized in Annex G of this report.

Conclusions Wind power provides clean energy and its incorporation into the Bulgarian energy mix will help the country to meet its acquired obligations towards the EU with respect to the percentage of RES it needs to achieve in 2020. The use of wind power will also reduce the dependency on foreign energy suppliers.

However, Bulgaria is a country with an important natural heritage, and given its great richness in biodiversity and the occurrence of many species that are at risk of extinction, care should be taken during site selection and the detailed design of wind farms. For certain highly sensitive areas, wind power development in these areas should be approached with upmost care and a detailed EIA is likely to show that the implementation of wind power is not viable as the associated risks cannot be mitigated to acceptable levels, at least not with current wind power technology.

At the strategic level it is recommended that the national wind power development plan takes into account the results of this SER, using the environmental database and the sensitivity classification (following cross-checking and modifying where considered necessary) to steer the implementation of wind power installations towards the most appropriate areas. At site level,

Table NTS4: Timetable for the SER Report Consultation Meetings Activity Location Stakeholders Date

Consultations on the draft SER report (technical)

Sofia Institutional, Energy Business, Public Interest

25 May 2010


Momchilgrad Institutional, Energy Business, Public Interest

27 May 2010

Consultations on the draft SER report (general)

Momchilgrad General Public, Landowners 27 May 2010


Burgas Institutional, Energy Business, Public Interest

28 May 2010


Burgas General Public, Landowners 28 May 2010


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EIAs should be performed with the sufficient level of detail to ensure that no unacceptable damage is caused to the environment.

The cumulative effects of wind power development on the environment have not always been properly taken into account in the past, which has resulted in for example the permitting of a very high number of turbines in the North-Eastern part of the country. In the future, the cumulative impact of wind power development should be better addressed by the investors during the conduct of EIA studies and by the competent authorities in the the strategic planning of the sector.

Monitoring of SER indicators would allow a quantitative assessment of trends and progress over time. Special focus should be given to indicators which can be significantly affected by wind power development. Any existing monitoring arrangements (e.g. field surveys already undertaken or on-going monitoring programs) should be incorporated into this process.


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SER Environmental Report Strategic Environmental Review of the Development of Wind Power in Bulgaria

1 Introduction 1.1 Background and Context The development of environmentally sustainable sources of electricity is increasingly becoming a priority for governments and a business opportunity for national and international developers. Wind power is one of the renewable energy sources (RES) that has experienced a strong growth over the past decade. However, in many countries including Bulgaria, the implementation of wind power has proceeded at greater pace than the development of the accompanying governmental policies.

This environmental report is submitted by a Consortium led by ENVIRON Iberia S.L (hereinafter “the Consortium”) as part of a project aimed at assisting the Bulgarian Ministry of Economy, Energy and Tourism (hereinafter the “MEET”) with the preparation of a policy for the sustainable development of wind power in the country. The project is funded by the Spanish Government through the EBRD-ICEX Technical Cooperation Funds and the contracting party is the MEET”.

The invitation to tender for the project was issued on behalf of the MEET by the European Bank for Reconstruction & Development (hereinafter “EBRD” or the "Bank") on May 6th, 2008, International Financial Institutions, such as the EBRD, are actively supporting the development of renewable sources of energy including, among others, wind power generation.

The process of Strategic Environmental Assessment (SEA) has been identified as a useful tool for the appraisal of the current state of wind power development in Bulgaria and the identification of the appropriate directions for future wind power development. The SEA is a systematic way to examine the likely effects of a strategic action on the environment and to suggest ways to either enhance or to mitigate these effects. The formal SEA process as required by European6 and National7 law applies to the assessment of specific plans or programmes. Given that there is no formal wind power development plan or programme in Bulgaria at present, the development of wind power in Bulgaria cannot be assessed by a formal SEA which complies with all of the mandatory requirements under the SEA Directive or under Bulgarian legislation. Therefore, the Consortium, with the approval of the MEET, the Ministry of Environment and Water (MoEW) and the EBRD, decided to undertake a Strategic Environmental Review (hereinafter SER) which draws on best practice and relevant approaches from the application of SEA but which will not be totally compliant with Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment and the Regulation on the Conditions, Procedures and Methods for Environmental Assessment of Plans and Programs.

6 Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment 7 Regulation on the Conditions, Procedures and Methods for Environmental Assessment of Plans and Programs (SG issue 57/2.07.2004, last amended SG issue 29/16.04.2010).


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1.2 Strategic Environmental Review The Strategic Environmental Review of wind power development has been undertaken in order to better understand the potential for direct and cumulative impacts associated with this type of development and to obtain input from relevant stakeholders through a process of public consultation.

The SER has been undertaken at a policy/strategy level with the outputs focused on providing recommendations and guidance for taking forward wind power generation across the country of Bulgaria. The environmental review process follows the procedures and practices set out within the SEA legislation.

The SER is meant to provide useful support to the Energy Efficiency and Environmental Protection Directorate, and the Renewable Energy Sources Department of the MEET to enhance renewable energy sustainable use in the country. The project provides the foundation for a systematic process for evaluating the environmental consequences of wind power developments. It is intended that this piece of work provides a useful basis for future planning and decision-making in relation to renewable energy sources in Bulgaria.

Two further key outputs of this SER process which will be informed by the outputs of the SER include:

Guide on Streamlining wind power project appraisal and environmental permitting process in Bulgaria:

- A Guidance Note on this subject is currently being developed. It is intended to make recommendations on how the wind power projects appraisal process and the environmental and administrative permitting process can be streamlined. The guidance will describe the relationship with the national-level planning and assessment process and identify the key issues for consideration at a regional and at a national level in order to promote the development of a sustainable wind power system in the country. A full draft of this guidance note is scheduled to be delivered by the end of May 2010.

- Summary of some of the key issues covered by the guidance note is provided within Section 8 of this report.

Best Practice Guide for wind power investors in Bulgaria:

- A Best Practice Guide for wind power investors in Bulgaria is currently being developed. The objective of this guide is to provide a step by step explanation of wind power planning and development in Bulgaria taking into consideration technical, economic, financial, environmental and social issues related to wind power implementation in the country which will provide information for wind power investors on potential risks and constraints to development and assist then in aligning with regional and national plans for development. A full draft of this Best Practice Guide is planned to be delivered by the end of May 2010.


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1.3 Objectives of the SER The study has the following key objectives, as defined in the Terms of Reference initially provided by the EBRD, and modified after the initial data review:

• to provide the environmental dimension that can be incorporate into regional electricity development plans and, thus, contribute to the overall decision making process which will shape the development of the country. This will be tested through a consultation process within selected areas;

• to provide a basis for the subsequent development and appraisal of specific investment projects in the wind power sector in the country. This will assist the national and regional authorities but will also be in line with project appraisal requirements of International Financial Institutions such as the Bank;

• to provide a forum for stakeholders, particularly local residents affected by any wind power development in the selected consultation areas, to participate in the development process;

• to provide potential future investors with information for the most appropriate locations and type of wind power facilities (and any limitations and conditions which should be met and may be part of the permitting process) – however it is noted that this task is severely limited by the currently available information;

• to provide the authorities with criteria for the appraisal of project proposals put forward by developers;

• to develop criteria to be applied to Environmental Permits under which operating projects may be decommissioned due to their impact on bird fatalities; and

• to develop criteria to be applied to scope any impact assessment studies and consultation required prior to developing any new wind farm.


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1.4 The SER Process The SER process was designed to ensure the integration of environmental considerations into the planning and decision making process of future developments of wind power in Bulgaria. The SER of the development of wind power in Bulgaria has therefore been carried out with close involvement of stakeholders (non-governmental organisations (NGOs), Scientific Entities, wind industry and the general public) and the Bulgarian government (MEET and MoEW).

The SER process and its relationship to the Development of Wind Power in Bulgaria (DWPB) are presented diagrammatically in Figure 3 within Section 3 of this report.

Table 1 highlights how the SER stages and delivered or expected outputs are related:

Table 1: Relationship of the SER stages and outputs preparation

SER Stage Indicative Timings

• SEA screening Summer 2009

• Inception Report, Regulatory Overview, Public Consultation and Disclosure Plan, Selection of Representative Areas to Conduct Public Consultation

September, October and November 2009

• SER Scoping Report November 2009

• Consult on SER Scoping Report with stakeholders and local population (30 days)

December 2009

• Draft SER Report April 2010

• Consult on Draft SER Report (30 days) April 2010

• Guidance on streamline wind power project appraisal and environmental permitting process in Bulgaria

May 2010

• Best practice guide for wind power investors in Bulgaria May 2010

• Production of Final SER Report June 2010

1.5 SER Report The purpose of the SER Report is to identify, describe and evaluate the likely significant effects on the environment of the development of wind power in Bulgaria, taking into account the objectives and the geographical scope of both current and future developments.

This SER Report has taken into account several best practice guides, particularly the Manual for Environmental Assessments of Plans and programmes in Bulgaria (POVVIK et al, 2002) and the Practical Guide to the Strategic Environmental Assessment Directive (Office of the Deputy Prime Minister, UK, 2005) In addition, a Quality Assurance checklist is provided at the end of this report (Appendix A) to clarify how this report has addressed the requirements of the SEA Directive and where it has followed recognised best practice.

Before this report was elaborated, its scope was subject to consultations with national and local stakeholders with the aim of canvassing opinions on the relevant issues related to the development of wind power in Bulgaria.

The organization of the SER Report presented in Table 2.


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Table 2: SER Environmental Report Structure

Section Description

1. Introduction and project context

Sets the general context and specific objectives for the SER of the development of wind power in Bulgaria.

2. Development of wind power in Bulgaria

Explains the Bulgarian context of wind power development and the regulatory framework in the country.

3. SER approach and methodology

Covers how the assessment is conducted in order to address the requirements of SEA Directive.

4. SER consultation Provides an overview of the SER consultation process and outputs.

5. Policy context and baseline review

Provides a summary of the available baseline information and sets out the policy context and outlines key identified issues for each environmental, social or economic topic.

6. Results of the assessment Presents results of the assessment with relation to each of the SER objectives and indicators demonstrating the significance of the effects.

7. Spatial Constraints analysis Summarises the potential spatial constraints for each SER environmental topic on the implementation of wind power in Bulgaria.

8. Recommendations including potential mitigation and monitoring

Suggests recommendations and mitigation measures for the future development of wind power in Bulgaria.

9. Conclusions Main conclusion of the project outputs and answers to the projects related objectives.

10. Next Steps Summarises the next steps in the SER process. Provides an overview of the consultation that will be conducted and the some sample questions for the consultees.

1.6 Implementation of the SER of the wind power development in Bulgaria

The outcomes of the SER are intended to advise and inform the development of wind power at a national level through forthcoming MEET documents, regulations, etc. However the degree to which recommendations are taken into account will be determined by the MEET and the other institutional stakeholders, and cannot be influenced by the Consortium.

Consortium recommendations are based on a board international experience in implementing wind energy programmes. Nevertheless, it has been demonstrated that each country needs to apply its own scheme taking into account local environmental, social and economic conditions.


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2 Development of Wind Power in Bulgaria 2.1 Introduction During 2009, 10.526 MW of wind power was installed across Europe and 10.163 MW of that total was within the European Union (EU) countries. This represents a market growth in the EU of 23% compared to 2008. From the 10.163 MW installed in the EU, 9.581 MW was installed onshore, and 582 MW offshore. In 2009, the onshore wind power market grew with 21% compared to 2008, and the offshore wind power market grew 56% compared to the previous year. Figure 1 presents the EU installed capacity from 2005 to 2009:

Figure 1 – Cumulative Wind Power Installations (MW) (Source: APEE, September 2009)

2.2 Wind Potential in Bulgaria According to reviewed information3, Bulgaria has the necessary preconditions for development of the wind energy sector. Existing wind potential data indicates that the Black Sea coastal line and areas with altitudes above 1000 meters are most suitable for wind power development.

The Ministry of Economy, Energy and Tourism (MEET) has prepared a report8 evaluating the wind potential in Bulgaria. In this report the country is divided into three regions according to average wind velocity and average wind power density.

Тhis study refers to data prepared and published from the Bulgarian Institute for Meteorology dated from 1982. The data was from 119 weather stations in Bulgaria, some covering 30 years back of wind velocity and direction measurements in 10 m height. The wind speed was determined at a fictional high without considering obstacles, roughness or topography.

It must be stated that meteorological stations have never had the aim to provide data for the assessment of wind power potential and therefore information of the cited report is not adequate for wind power development considerations.

According to local wind power experts, data on wind potential in Bulgaria is still insufficient. This is a significant obstacle to evaluate the most promising areas and therefore the potential impact of future wind power development projects in the country. General data give primary information

8 Document prepared by Vladislava Georgieva – chief expert in Energy Efficiency and Environmental Protection Directorate, Ministry of Economy and Energy.

2,497 3,476 4,753 6,4539,678

12,88717,315

23,098 24,491

34,37240,5

48,031

56,517

64,719

74,767

0

10

20

30

40

50

60

70

80

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

CUMULATIVE WIND POWER INSTALLATIONS MW


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of the potential of different sites; still investors need to carry out their own measures to evaluate the actual wind farm potential.

2.3 Installed and Planned Wind Power Capacity in Bulgaria At the end of 2008, the installed and operating wind power capacity in Bulgaria was 112,6 MW, which represented 5,2% of all installed RES and was comprised of:

• 77,6 MW connected to the electricity distribution companies;

• 35 MW (“Kaliakra Wind Power Park”) connected to the electricity transmission company – Natsionalna Electricheska Kompania (NEK) EAD (National Electric Company).

The amount of electricity generated by wind energy in 2008 was 121,8 GWh, which was 4,1% of the electricity generated by RES.

At the end of 2009, the installed and operational wind power capacity was 335,3 MW, which was a trifold increase, compared to 2008. This capacity accounted for 13,8% of all installed RES in Bulgaria and the produced electricity from wind was 235,9 GWh, which was 6,4% of the electricity generated by RES 9.

Figure 2 summarises the Bulgarian increase of wind power installed capacity based on information provided by the MEET.

Figure 2 – Installed Wind Power Capacity in Bulgaria from 2005 to 2009

Source: Report on achieving the national indicative goals for consumption of electricity generated by RES in 2009.

The latest official information, provided by the three electricity distribution companies (E.ON Bulgaria Grid AD (EON), EVN Bulgaria Elektrorazpredeleniee AD (EVN) and CEZ Distribution Bulgaria AD (CEZ)) and the electricity transmission company (National Electricity Company (NEK)) to the MEET, in regards to operational wind power capacity and foreseen capacity, based on signed preliminary contracts is presented in Table 3 below.

9 Data based on the MEET Report on achieving the national indicative goals for consumption of electricity generated by RES in 2009.

7,525,5 40,7

112,6

335,3

0

50

100

150

200

250

300

350

400

2005 2006 2007 2008 2009

Installed Wind Power Capacity in Bulgaria (MW)


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Table 3 - Wind power capacity in Bulgaria until March 2010

Company Operational Wind Capacity (MW)

Wind Capacity with Preliminary Contracts (MW)

CEZ 11,0 26,1 EVN 20,0 101,9 EON 129,6 353,7 NEK 191,0 1.538,5 Total 351,6 2.020,2

Source: The data was officially provided by the four companies to MEET.

As presented in Table 3, up to March 2010, the total installed and operating capacity in Bulgaria was 351,6 MW, while more than 2.000 MW additional capacity is planned for the near future.

Based on the data provided by the electricity transmission and distribution companies, wind power development in Bulgaria is characterised by:

• Small size of wind farms - the two largest operational wind farms have respectively 35 and 16 wind turbines. All other farms have less than 5 wind turbines.

• Concentration of many small projects in the same areas - Kavarna region for instance has 57operational projects.

• Few large wind farms already have preliminary contracts with the NEK – a total of 21 wind farm projects are over 20 MW, of which one is for 160 MW, two for 150 MW, two for 100 MW, etc.

Based on data from the Report on achieving the national indicative goals for consumption of electricity generated by RES in 2009, regarding wind power capacity, electricity production from wind power and gross inland electricity consumption, as well as using data from the National Statistical Institute on the gross energy consumption, calculations were made for the contribution of wind energy to the gross inland electricity consumption and the gross energy consumption. These calculations are presented in Table 4.

Table 4 – Contribution of wind power to electricity and energy consumption

Period Installed wind

power capacity (MW)

Annual produced

electricity by wind power

(GWh)

Annual gross inland

electricity consumptio

n (GWh)

% of Gross inland

electricity consumpti

on

Annual gross

energy consumptio

n (GWh)

% of Gross Energy

Consumption

End of 2008 112,6 121,8 39.222,1 0,3 % 231.309 0.05 %

End of 2009 335,3 235,9 37.437,7 0,6 % 220.786 10 0,11 %

Near future 2.371,8 11 4.743,6 12 37.437,7 13 12,7 % 220.786 2,15 %

10 Due to the lack of official statistics for 2009, it has been assumed that the gross energy consumption has changed from 2008 to 2009 in the same manner as the gross electricity consumption. 11 The installed wind power capacity in the near future is assumed to be the sum of the installed capacity, reported in March 2010, and the wind capacity for which preliminary contracts for connection to the grid have been signed. 12 The annual amount of elelctricity produced by wind power in the near future has been estimated with the assumption that wind turbines work on average 2000 hours/year. 13 It has been assumed that the annual gross electricity consumption and annual gross energy consumption will remain relatively stable in the near future.


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As presented in Table 4, the contribution of wind power is expected to significant increase in the coming years, assuming that most of the projects with preliminary contracts will be implemented.

These values can be considered realistic given the wind conditions in Bulgaria and the foreseen evolution of the power demand. Moreover, this capacity increase would be in line with the trends in other European countries. For instance, if all projects which currently have preliminary contracts for connection enter into operation, a total capacity of 2.371,8 MW is expected to be installed which means a generation of 4.743,6 GWh/year or around 12,7% of the present gross inland electricity consumption which is similar to the numbers in other European countries such as Portugal, Ireland or Spain.

Because of this expected significant increase, it is very important to establish a clear strategy for wind power development in order to guarantee the correct implementation of wind power projects in Bulgaria.

2.4 Regulatory Framework and Policy Context A review of relevant international, national and regional level policy documents and regulations related to various aspects of the development of wind energy in Bulgaria has been undertaken. The most relevant pieces of legislation, plans and programmes are set out below.

2.4.1 EU Policy for the Promotion of RES The use of Renewable Energy Sources (RES) guarantees a balanced development of the common energy market and the reduction of dependency on imports and risks associated with reliability of energy supplies, while meeting at the same time the requirements for reducing adverse environmental and climate change impacts and promoting employment.

Directive 2001/77/EC on the promotion of electricity produced from renewable energy sources in the internal electricity market was the first EU Directive with a primary focus on the promotion of electricity produced from RES. It required all Member States to increase the share of RES energy in Europe to 12% of gross energy consumption by 2010. Even though much was done after the adoption of Directive 2001/77/EC to promote the generation of energy from RES, according to the findings of the 2009 EU Renewable Energy Progress Report, Europe is likely to fail to meet its 2010 renewable energy targets.

In the light of these results, the EU passed a new directive - Directive 2009/28/EC on the promotion of the use of energy from renewable sources. This Directive amends and repeals Directive 2001/77/EC and:

• Sets mandatory national targets for the overall share of energy from renewable sources in gross final consumption of energy and for the share of energy from renewable sources in transport;

• Requires each Member State to adopt a National Renewable Energy Action Plan (NREAP) by June 30th, 2010;

• Lays down the rules relating to statistical transfers between Member States, joint projects between Member States and with third countries which will help Member States in the accomplishment of the national targets, and

• Provides the rules for the guarantees of RES origin, training and access to the electricity grid for energy from RS.

The Directive´s goal is to increase the share of renewable energy in the EU from 8.6% in 2005 to 20% in 2020. In 2007, the share of renewable energy had already reached 9.9%. At this point


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with an increase of 0.65% points per year, the EU will reach 18.35% share of renewable energy in 2020.

According to EU’s Renewable Energy Directive, the target for wind power is 12% by 2020, which would require according to EWEA an installed capacity of wind energy in the EU by 2020 between 230GW in a low scenario14, and 265GW in a high scenario15, producing respectively 580TWh to 681TWh of electricity.

According to Annex 1 of this Directive, Bulgaria has to achieve 16% share of energy from RS in the gross final energy consumption by 2020, while the overall EU goal is 20%. However, according to the RES forecast document, developed for the MEET in 2009, if Bulgaria improves its energy efficiency, it can reach 19% of RES from the final gross energy consumption.

EWEA’s predictions indicate that Bulgaria will reach 12.6% in a low scenario and 14.7% in a high scenario, corresponding to 3000MW and 3500MW respectively and an annual average installation of 237MW and 279MW.

2.4.2 Renewable and Alternative Energy Sources and Biofuels Act Directive 2001/77/ЕC on the promotion of electricity produced from renewable energy sources in the internal electricity market and Directive 2003/30/EC on the promotion of the use of biofuels or other renewable fuels for transport were transposed into the Bulgarian legislation by the Renewable and Alternative Energy Sources and Biofuels Act (RAESBA) (promulgated SG 49/2007, last amended SG 98/2008). The Act lays down the rules for:

• National indicative targets for promoting the use of electricity produced from RES – expressed as a percentage of the country's gross annual electricity consumption during the next ten years;

• General principles guiding the promotion of electricity produced from RES:

o Taking into account the characteristics of the various RES and electricity generation technologies;

o Taking into account the principles of the energy market;

o Ensuring that, whenever promotional mechanisms are changed, electricity producers enjoy at least equivalent preferences in terms of their income per unit of electricity produced;

• Mandatory prioritized connection of electricity generated from RES to the electricity transmission grid;

• Mandatory purchase of the full amount of electricity generated from RES - for those generators who are properly registered and have been issued a certificate of origin by the State Energy and Water Regulatory Commission;

• Setting preferential feed-in tariffs for purchasing of electricity from RES – the public supplier and/or public providers are under the obligation to purchase the electricity produced by plants using RES at preferential prices established pursuant to an

14 The “low” scenario is based on EWEA’s traditionally conservative approach to setting future targets for wind energy (in: EWEA 2009, “Pure Power” Wind energy targets for 2020 and 2030; Chapter 4). 15 The “high” scenario acknowledges that because wind power is the most affordable of the renewable electricity technologies it is likely to meet a much higher share of the EU’s Renewable Energy Directive target.


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Ordinance. Preferential prices are updated annually and a pricing new scheme based on green certificates is now being evaluated;

• Establishing a simplified administrative ordinance on the generation of electricity from RES and on the construction of the required facilities.

This Act has been further implemented by numerous ordinances on the matter.

On October 2009, the MEET set up a working group for the elaboration of the New Renewable and Alternative Energy Sources and Biofuels Acts, in order to transpose the newly adopted Directive 2009/28/EU into Bulgarian legislation. According to the Directive, the deadline for its introduction in the national legislation of all EU Member States is December 5th 2010.

2.4.3 National Long Term Programme to Promote the Use of RES (2005-2015)

In 2005, Bulgaria adopted a National Long Term Programme to Promote the Use of RES (2005-2015). This program contains:

• An analysis of the current energy consumption scenario and a forecast of the future development of the energy sector in Bulgaria;

• Formulation of goals for an optimal use of the suitable RES potential in the country;

• Definition of necessary measures and activities to encourage the use of different types of RES;

• Identification of barriers and proposal of a package of mechanisms for the implementation of the national policy in compliance with the general policy for economical and social development.

This programme defines measures and policies to promote the development of RES in the Bulgarian energy balance as a result of the assessment of current RES utilization, the need for intensive RES development by 2015, and the common impact of improvement of the energy efficiency and RES development for the achievement of sustainable energy development.

The programme sets the following goals for electricity generated from RES:

a) to exceed 8% of the gross electricity generation by 2010;

b) to exceed 9% of the gross electricity generation by 2015.

2.4.4 National Renewable Energy Action Plan by 2020 On June 30th, 2009, the European Commission issued a Renewable Energy Action Plan (NREAP) Template, which aims to assist Member States in the preparation of their national NREAPs and to ensure uniformity of the plans within the EU. According to article 4 of Directive 2009/28/EC, this NREAP shall be submitted to the EC by June 30th 2010.

2.5 Drivers for the Development of Wind Power in Bulgaria The implementation of wind power in Bulgaria is integrated with the European strategy for the implementation of RES. For this reason, the country needs to take into account different drivers which can be used individually or in combination to address the current and predicted wind power implementation trends and problems in Bulgaria.

After an initial review of the current situation, the Consortium has identified three main drivers for current policy development across Bulgaria. Focusing on these drivers will provide a framework for building on the progress that has already been made in Bulgaria in recent years.


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The three key drivers are summarised below:

1. To achieve a more effective and efficient development of wind power and associated infrastructure

More efficient and reliable use of available infrastructure (for example achieving higher capacity on some existing wind farms) will be sought, as well as greater efficiency in turbines technology and in the operation of the technical system (i.e. voltage control). In some cases, provision of new infrastructure will also be required. If the effectiveness of the system is to be ensured an improved and more co-ordinated decision making process across different policy areas must be promoted.

2. To supplement wind power development with increased efficiency in energy consumption

Wind energy is a renewable energy source but to guarantee an efficient integration into the electrical system it is important to optimise the operation of the conventional power plants and to implement solutions of load management, in order to avoid curtailments and to reduce the regulatory costs.

The production of this type of energy will allow reducing fossils fuel dependency and will lower greenhouse gas emissions.

3. To optimize the social, economic and environmental impacts of wind power development

The development of wind power has important benefits, like reduction of the environmental impact (less emission of greenhouse gasses and other contaminants), use of renewable and endogenous resources and creation of local employment and economic benefits. All of these factors should also be considered in the identification of priority areas and in the implementation of projects. Integration of mitigation measures should be considered at the early stages of the project implementation.


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3 SER Approach 3.1 Diagram of the SER Process The structure of the SER for the Development of Wind Power in Bulgaria (DWPB) is presented as a diagram within Figure 3:

Figure 3: The DWPB and SER Processes

The process illustrated above differs from that proposed and outlined in the Scoping Report. The main changes were in Stage B which featured:

- the incorporation of a spatial analysis: directly related to the additional data collection during (and after) scoping consultations;


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- the removal of the development of alternatives, as explained in Section 3.3 of this report.

The following legislation and guidance documents have been used to structure and guide the SER:

• Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment;

• Protocol on SEA – Resource Manual to Support Application of the UNECE Protocol on Strategic Environmental Assessment, (UNECE et al, 2006);

• Applying SEA Good Practice Guidance for Development Co-Operation, (OECD, 2006);

• Strategic Environmental Assessment Good Practices Guide - methodological guidance, (APA – IST, 2007) Portugal;

• Manual for Environmental Assessment of Plans and Programmes in Bulgaria, (POVVIK-OOS et al, 2002), Bulgaria.

3.2 SER Stage A – Scoping and SER Objectives The scoping stage in the SER process involved establishing a framework for undertaking the SER together with an evidence base to inform the assessment itself. The stages followed during scoping process are shown in Table 5.

Table 5: SER Scoping

Scoping stage Purpose

Identify other relevant policies, plans, programmes and their environmental objectives

To document how the development of wind power in Bulgaria is affected by external factors and suggest ideas on how any constraints can be addressed

Collect baseline information To provide an evidence base to identify environmental problems and to provide a basis for predicting and monitoring effects

Identify environmental issues To help focus the development of the SER framework on the important issues

Develop the SER framework (SER objectives)

To provide a means by which the current policy framework and practice on the development of wind power generation can be appraised

The scoping stage was structured around seven Topic Papers under the following headings:

• Energy, Climate and Air Quality (Topic Paper 1);

• Cultural Heritage (Topic Paper 2);

• Fauna, Flora and Biodiversity (Topic Paper 3);

• Soil and Water (Topic Paper 4);

• Landscape (Topic Paper 5);

• Public Health, Noise and Vibration (Topic Paper 6);

• Socio-Economic and Material Assets (Topic Paper 7).

Each Topic Paper contains information about the following issues:


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• Policy context (review of other plans, policies, programmes and their objectives);

• Baseline data review;

• Issues identified and implications for the development of wind power generation in Bulgaria; and

• Suggested SER objectives and indicators.

The topic papers are provided in full on the project website16. All relevant information that has been obtained during the preparation of the Topic Papers is included in the Final Scoping Report17.

Feedback from the scoping consultation process was also considered and a revised draft of the objectives and indicators was discussed at the end of the scoping consultation process. These revised SER objectives and indicators for the development of wind energy have been included in the Final Scoping Report8.

Section 5 of this report summarises the available baseline information for each topic, sets out the policy context, identifies the key issues and presents the final SER Objectives and Indicators.

3.3 SEA Stage B – Generating Alternatives, Assessing and Monitoring Effects

The SER covers the whole territory of Bulgaria and has to address many complex issues and interrelationships. For this reason, the consultation process of the SER Scoping Report was designed to allow the stakeholders (regulators, authorities, wind developers, academic, NGOs, etc.) to help fill known data gaps, as well as to identify issues which may not have been addressed to a sufficient level of detail in the draft Scoping report.

Based on published information, as well as on data and opinions provided by the stakeholders, the Consortium has carefully assessed the effects of wind power development and the constraints for wind power development in relation to the relevant environmental and social aspects.

3.3.1 Generating alternatives The SEA Directive requires that:

“Where an environmental assessment is required under Article 3(1), an environmental report shall be prepared in which the likely significant effects on the environment of implementing the plan or programme, and reasonable alternatives taking into account the objectives and the geographical scope of the plan or programme, are identified, described and evaluated. The information to be given for this purpose is referred to in Annex I. (Article 5. 1.)”

Annex 1 (h) requires:

“an outline of the reasons for selecting the alternatives dealt with, and a description of how the assessment was undertaken including any difficulties (such as technical deficiencies or lack of know-how) encountered in compiling the required information”.

As was indicated above, there is currently no formal plan or programme for wind power development in Bulgaria. However, the SER constitutes an overall assessment of the currently

16 Project website can be accessed at www.bgwindenergy.com 17 Final Scoping Report can be consulted at the Project website: www.bgwindenergy.com


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existing situation with regards to wind power development in Bulgaria, the existing legal framework, and the environmental and social issues that are influenced by wind power development.

The SER also makes recommendations for future development of wind power.

At this stage, however it is not possible to identify reasonable alternatives for the implementation of wind power as this SER forms the basis for the development of a strategy or plan for taking wind power development forward. It is intended that the future Bulgarian wind energy development strategy (the National RES Action Plan), which may incorporate recommendations from this SER, will consider alternative methods of implementation, which in turn will need to be tested through a SEA. These alternatives deal with:

the level of demand;

the type of technologies to be used;

locations;

timing and detailed implementation; etc.

3.3.2 Assessing effects The SEA Directive requires an examination of the current state of the environment and the likely evolution of the environment without the implementation of the plan (“future baseline” or “baseline scenario”).

Following discussions with stakeholders and the MEET, it was agreed that the use of Geographic Information System (GIS) to analyse and present spatial information would be beneficial. This will help define and present environmental constraints for the development of wind power in Bulgaria. The spatial analysis is based on electronic layers of data, representing spatially certain environmental conditions. Assessing the implications of wind power development on these environmental conditions and combining the layers in specific ways facilitates the identification of areas of potentially high/low constraints with regard to wind power development.

It is important to note that the GIS analysis pertain only to environmental and social constraints for which information was available and suitable for spatial analysis. Spatial data pertaining to wind potential, grid access and other technical considerations has not been obtained.

To ensure data quality and facilitate the analysis of the collected spatial information, metadata was collected about each data set by the respective data providers. A detailed description of the spatial analysis process is presented in Section 7 and in Appendix D of this report.


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3.3.3 Criteria for defining significant effects The assessment process involves collecting information, defining alternatives, identifying environmental effects, developing mitigation measures and making recommendations in the light of predicted environmental effects. The essential purpose of the SER is to identify the ‘likely significant effects’ on the environment of the current policy framework and its implementation.

The likely impacts of current wind power development in Bulgaria have been considered in relation to each SER objective and the significance of these likely impacts on each SER objective has been assessed. The assessment methodology described below was used for this purpose.

The SEA Directive specifies in its Annex II the criteria that should be taken into account when determining the likely significant effects. The criteria for identifying these significant effects are only defined explicitly in the Directive in relation to determining whether a SEA is needed. Nonetheless, the criteria, which principally relate to the nature of the effects arising from the policy framework which is being assessed, and the value and vulnerability of affected indicators, will be adopted for the assessment of the significant environmental effects.

Terminology is of great importance at this stage of the assessment and there is a wide range of application of the terms used to identify significance. Therefore, to ensure consistency within the assessment, the criteria used in the assessment to support the identification of ‘likely significant effects’ are discussed in further detail in the following sections.

It should be noted that the methodology described below differs in some aspects from the one that was proposed and outlined in the Scoping Report, since a scoring approach has been added in the evaluation of the significance of effects on SER objectives. The aim of this change was to provide a consistent method for evaluating significance of the effects based on clear scoring system.

Identification of Receptor Value and Vulnerability The following definitions are proposed:

o Value: the value of a receptor is based on the scale of geographic reference, rarity, importance for biodiversity, social or economic reasons, and level of legal protection;

o Vulnerability: this is defined by the potential of existence of a pathway for exposure of a receptor to a given environmental effect, together with the sensitivity of the receptor to that effect. (The sensitivity is the tolerance of a receptor to a given environmental effect and its ability to recover from that effect).

The SEA Guidance does not provide specific information on this issue. Furthermore, it is not feasible to develop a ‘one size fits all’ definition that applies consistently to all topics.

Guidance and judgements on receptor value and vulnerability is therefore specific for each topic. A guideline framework for these classifications is provided below. In many cases the assessment of value and vulnerability will be based on qualitative rather than quantitative information and where necessary base on expert judgement.


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Table 6: Guidelines for identifying receptor value and vulnerability

Sample Receptor Definitions

Value Vulnerability

High

E.g. receptor is rare, important for social or economic reasons, legally protected, of international or national designation.

E.g. potential pathways for environmental change exist between options (sources) and indicators. Receptor is in declining condition, dependent on a narrow range of environmental conditions.

Low

E.g. receptor is common, of local or regional designation.

E.g. limited or no pathways exist between options and indicators. Receptor is in stable or favourable condition and dependent on a wide range of environmental conditions.

The Probability, Duration, Frequency and Reversibility of Effects The probability whether an effect will happen is recorded as high, medium, low or very low, a guideline framework for these classifications is provided below:

Table 7: Guidelines for determining probability of effect

Probability of the Effect

Classification High Medium Low Very Low

Guideline >90% 50-90% 10-50% <10%

The duration of the effects is quantified where possible to a length of time. The period of the project lifecycle is described as either construction, operation or decommissioning.

Guidelines for the duration of effects are given below:

Table 8: Guidelines for determining duration of the effect

Duration of the Effect

Classification Long Term Medium Term Short Term Very Short Term

Guideline 8+ years 3-8 years 10 months-3 years 8-10 months

Project phase Operation Operation period Construction or part

of construction period Part of construction

period

An indication of the frequency of the effect will be given, whether it will be continual or intermittent over the period of time identified.

Finally the effect will be described as reversible or irreversible. This judgement will be based on the timescale for a receptor’s return to baseline condition without intervention, in relation to a human lifetime. If the timescale for a receptor’s return to baseline condition is greater than 50 years then it will be considered irreversible and if it is less then it will be considered reversible.


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The Magnitude and Spatial Scale of Effects, Trans-Boundary Effects The magnitude of an effect considers the percentage of the receptor that is affected and is categorised as high, medium, low or very low as set out in the following table:

Table 9: Guidelines for determining magnitude of effect

Magnitude of Effect

Classification High Medium Low Very Low

Guideline 90%+ of receptor affected

50-90% of receptor affected

10-50% of receptor affected

<10% of receptor affected

The spatial scale of the effect can be defined based on whether it is local, regional, national or international. The area or location of the effect is identified where relevant. Тrans-boundary effects are identified, including trans-boundary effects on other EU Member States.

Positive and Negative Effects A positive effect is one that is favourable or otherwise beneficial to the condition of a receptor.

A negative effect is one that is unfavourable or otherwise adverse to the condition of a receptor.

Cumulative Effects The following definitions are taken from Appendix 8 of the UK SEA Guidance18 for secondary, cumulative and synergistic effects:

• Secondary or indirect effects are effects that are not a direct result of the plan, but occur away from the original effect or as a result of a complex pathway. Examples of secondary effects are a development that changes a water table and thus affects the ecology of a nearby wetland; and construction of one project that facilitates or attracts other developments.

• Cumulative effects arise, for instance, where several developments each have insignificant effects but together have a significant effect; or where several individual effects of the plan (e.g. noise, dust and visual) have a combined effect.

• Synergistic effects interact to produce a total effect greater than the sum of the individual effects. Synergistic effects often happen as habitats, resources or human communities get close to capacity. For instance, a wildlife habitat can become progressively fragmented with limited effects on a particular species until the last fragmentation makes the areas too small to support the species at all.

These terms are not mutually exclusive. Often the term, cumulative effects, is taken to include secondary and synergistic effects. The assessment includes any assumed supporting infrastructure. Therefore, the assessment tables identify where there is the potential for cumulative effects from likely additional associated infrastructure. In addition, where practical the potential for cumulative effects from other policies or strategies are identified.

Scoring significance of effects The approach this SER has taken in defining significance is as follows: 18 A Practical Guide to the Strategic Environmental Assessment Directive. (2005) ODPM.


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• Careful definition of the SER framework to ensure that it focuses only on those issues that have been determined to be potentially significant in regards to wind power development in Bulgaria; and

• When determining how likely the current wind power development is to support the achievement of the SER objectives (and therefore be a significant effect), the following factors are considered:

- Characteristics of the effects (magnitude, spatial extent, probability, duration, frequency and reversibility of the effects);

- The sensitivity of the receptors involved (the value and vulnerability of the receptor).

There is a considerable variety of potential issues that could occur during wind power development and these have been documented within the assessment matrices. However, as indicated above it was decided that a simple scoring system would be used to assist with the interpretation of results.

It should be noted that the potential exists that such simplified scoring system may mask individual effects which might be significant even when considered in isolation. Therefore this scoring system was used primarily to provide a summary of the assessment outputs and the obtained scores be considered in conjunction with the more detailed assessment outputs. The characteristic categories and their scores are described in Table 10 below:

Table 10: SER Objectives Scoring Characteristics of Effects

Scoring Characteristics of Effects

Characteristic Category Scoring Definition

Serious 5

Value: receptor is rare, important for social or economic reasons, legally protected, of international or national designation.

Vulnerability: potential pathways for environmental change exist between options and indicators. Receptor is in declining condition, dependent on a wide range of environmental conditions.

Duration of the effect: irreversible or long-term adverse change to key physical and/or ecological processes, irreversible or long-term deterioration of habitat and reduction in species diversity.

Cumulative/ secondary/ synergistic interactions: if cumulative, secondary, synergetic effects are identified.

Magnitude and spatial scale of the effect, trans-boundary effect: if the expected change has significance at the national or international level. At least 90% of receptor is affected. Direct loss of rare and endangered habitat or species and/or threat to their continued persistence and viability (i.e. availability of necessary resources to support characteristics of habitat or population of species).

Additional criteria: change that prejudices the likely success of existing policies and plans or integrity of designated areas of nature conservation.

Moderate 3 Value: receptor is important for social or economic reasons, legally protected, of international or national designation.


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Scoring Characteristics of Effects

Characteristic Category Scoring Definition

Vulnerability: potential pathways for environmental change exist between options and indicators. Receptor can be in a declining condition, dependent on a wide range of environmental conditions.

Duration of the effect: medium-term (between 3 and 8 years) adverse changes to physical and ecological processes.

Cumulative/ secondary/ synergistic interactions: if potential for cumulative effects is identified.

Magnitude and spatial scale of the effect, trans-boundary effect: if the expected change has importance beyond the local level (i.e. the strategic areas plus the buffer zone), but not at national or international level. 50-90% of the receptor affected. Direct loss of some habitat crucial for listed species’ continued persistence and viability in the project area and/or some mortality of species of conservation significance.

Minor 1

Value: receptor is common, of local or regional designation.

Vulnerability: limited or no pathways between options and indicators. Receptor is in stable or favourable condition and dependent on a wide range of environmental conditions.

Duration of the effect: short-term adverse change to physical and ecological processes. Short-term decrease in species diversity in selected biotopes/areas within the project area and/or -increased mortality of species due to direct impact from project activities. Very-short term. Temporary disturbance of species, resulting in their cessation of normal behaviour and/or commencement of avoidance behaviour.

Cumulative/ secondary/ synergistic interactions: no cumulative effects are identified.

Magnitude and spatial scale of the effect, trans-boundary effect: if the expected change has importance only at the local level (i.e. the strategic areas plus the buffer). Less than 10 or up to 10-50% of the receptor is affected. Direct loss of a small amount habitat.

None 0

Effect absorbed by local natural environment (i.e. the strategic areas plus the buffer zone) with no discernible effects:

· No restoration or intervention required.

The probability whether an effect will happen is recorded as certain, likely or unlikely. A guideline framework for these classifications is provided in table 11 below:


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Table 11: SER Objectives Scoring the Probability of the Effects

Category Score Definition

Certain 5 The effect will most likely occur. The level of probability is high (> 90%).

Likely 3 The effect is likely to occur at some time during wind development project life cycle. The level of probability is medium (50 -90%).

Unlikely 1 The effect is unlikely to occur but may occur at some time during wind development project life cycle. The level of probability is low (10-50%) or very low (<10%).

The final significance scores are categorised as shown in Tables 12 and 13.

Table 12: Probability/Characteristics Product Result

5 5 15 25 3 3 9 15 1 1 3 5 1 3 5 Characteristics

Table 13 is an appraisal summary table which shows performance against each SER Objective, and whether this is major or minor, positive or negative or a combination of the two and the correspondent scoring value. Table 13 provides an illustrative key for the SER Objective Appraisal Summary Table, used in Section 6.

Table 13: SER Objective Appraisal Summary Table Key

Performance is based on number or proportion of indicators linked to each SER Objective for which significant effects have been predicted, and informed by consideration of SER Assessment Criteria.

Major negative performance against

SER Objective 15-25

Major positive performance against

SER Objective 15-25

Minor negative performance against

SER Objective 9

Minor positive performance against

SER Objective 9

Partial negative performance against

SER Objective (major or minor)

or 1--5

Partial positive performance against

SER Objective (major or minor)

or 1-5

No Effects 0 Uncertain ? -


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It is recognised that there is a degree of professional judgement in regards to the assessment of performance. This judgement is therefore informed by inputs from the consultation process and the technical analysis provided by the environmental and wind experts and local consultants. The level of performance is also discussed in this report in Sections 6 and 7, with reference to the assessment criteria and indicators established during scoping (Section 5).

The previous sections have provided information on the methodology that has been used as part of the assessment process. It is a requirement of the SEA Directive to consult the statutory consultees when deciding on the scope and level of detail of the information which must be included in the environmental report, and the following provides some additional clarification regarding the method in response to comments made during consultation:

• A SEA is not as detailed as an EIA (Environmental Impact Assessment). This is because a SEA is used to assess relatively broad strategies rather than site specific proposals. The purpose of this SER is to identify where environmental effects may occur as a result of the development of wind power in Bulgaria. Therefore, this SER will not highlight detailed site specific impacts. Rather, the SER is aimed at identifying large-scale potential effects on a particular environmental or social aspect – for example, type of community, particular type of environmental designation or a key species or habitat;

• The SER is not applied to a particular plan, programme or strategy and is intended to examine the existing policy framework and current practice with relation to the development of wind power in Bulgaria. Therefore, the assessment will be undertaken at a policy level and will not examine specific impacts related to the implementation of a particular plan, programme or strategy. Thus, the level of the assessment and outputs generated need to be appropriate to inform the next stage of the policy and framework plan, to facilitate the development of wind power in Bulgaria and to be integrated in the future RES National Action Plan;

• The assessment methodology had to be adapted to the data that was made available from different stakeholders. Given the large data volume GIS analysis was incorporated into the project;

• As part of the assessment, data gaps have been identified and this information may need to be filled in at more detailed assessment scales, with specific studies to be undertaken following the completion of this project;

• For the strategic elements of the assessment, expert judgement has been employed, which often is the best way to predict and assess the effects of wind power development. This has been supported by documented evidence, where available;

• It is important to remember that the levels of uncertainty are likely to be higher when assessing strategic elements of a policy and therefore there has been less opportunity for the provision of quantified predictions;

• Uncertainty has been minimised through clearly documenting assumptions that were made and the evidence that has been used in undertaking the assessment.

3.3.4 Mitigation of Adverse Effects Incorporation of mitigation measures to directly prevent or reduce an effect, as well as of monitoring measures, is an iterative part of the SEA process. However, as the SER is being undertaken at a strategic level and does not involve the assessment of a specific plan, the mitigation and monitoring measures have been outlined as more general recommendations in Section 8 of this report.


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3.4 SER Stage C/D – Public Consultation on the SER Environmental Report and Finalisation of the SER Environmental Report

The main deliverable of the SER process is the Environmental Report (this report). In order to address the requirements of the SEA Directive, this report provides:

• An assessment of likely significant effects of the development of wind power in Bulgaria on the environment, including on aspects such as biodiversity, human health, fauna, flora, soil, water, air, climatic factors, material assets, cultural heritage, landscape and the interrelationship between the above factors. An assessment has taken into account the secondary, cumulative, synergistic, short, medium and long-term, permanent and temporary, positive and negative effects;

• Measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the environment as a result of the development of wind power in Bulgaria. The report suggests issues which may need to be monitored in regards to potential significant effects.

In order to receive the opinions, comments and recommendation of all relevant stakeholders, a consultation process will be conducted on the draft SER report. The SER Consultation process will be further discussed in Section 4 of this report.


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4 SER Consultation 4.1 Selected representative areas for the consultation process Following the decision to conduct SER at a national level, the Consortium, the EBRD and the MEET agreed to carry out the SER consultation process at the national level (in Sofia) and also within specific areas selected as being representative for the issues typically related to wind power development in Bulgaria.

In order to identify representative areas, the Consortium took into account the available information regarding the following selection criteria:

• Wind Potential;

• Potentially Affected Population;

• Environmental Constraints;

• Installed Wind Power Capacity; and

• Future Wind Energy Developments.

Following an initial review of the available information, it has been decided to select two different types of areas with the following characteristics. The decision process was conducted by the Consortium in agreement with EBRD and MEET indications:

• Consultation Area A: An inland area with many small wind power developments, where individual wind turbines are progressively added which gives rise to a larger cumulative impact; and

• Consultation Area B: An area with large-scale wind power generation, located at the Black Sea coast, and with relatively well known bird migratory patterns.

All areas where there was information available on current or planned wind power development were considered as potential representative areas. The selection process has attempted to balance the available technical, socio-economic and environmental criteria, and has taken into account input from the publicly accessible information, local consultants, bird experts and other sources. For each potential area, the five above-mentioned selection criteria have been classified as being of high, medium or low relevance, and in accordance with this classification a score has been assigned to the area. Using this semi-quantitative approach, four areas with some of the highest scores (featuring the highest degree of relevance with regards to the five selection criteria) were proposed as representative areas for the SER consultation process.

Detailed information on the representative areas selection process is provided in a document titled “Selection of Representative Areas to Conduct the Public Consultation Process.19”

The four proposed representative areas, two from each area type (Type A and Type B) are described below.

Consultation Area A: Inland area with many small wind power developments, where individual wind turbines are progressively added which gives rise to a larger cumulative impact

• Alternative Area A1- Topolovgrad and Simeonovgrad Municipalities: The area is located in the region of the Sakar Mountain in Southeastern Bulgaria. There is already sizeable installed wind power capacity in the area and more has been planned. This

19 Selection of Representative Areas to Conduct the Public Consultation Process document can be consulted on the project website: www.bgwindenergy.com


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AREA B1 Shabla-Kavarna Municipalities

AREA A2 Krumovgrad-Momchilgrad Municipalities

AREA A1Topolovgrad-

Svilengrad Municipalities

AREA B2 Burgas-Aytos Municipalities

region is of great significance for the protection of birds because it is the only place in Bulgaria and one of the few in Europe where the endangered and protected Imperial Eagle nests.

• Alternative Area A2- Krumovgrad and Momchilgrad Municipalities: The area around Krumovgrad and Momchilovgrad municipalities, located in the eastern part of the Rodopa Mountains, is reportedly being analysed for the implementation of future wind projects. Although only limited information is available, according to local bird experts the area is environmentally highly sensitive because it is a place for feeding and/or nesting ground for three endangered vulture species: the Black Vulture (Aegypius monachus), the Griffor Vulture (Gyps fulvus) and the Egyptian Vulture (Neophron percnopterus).

Consultation Area B: Large-scale wind power generation, located at the Black Sea coast, and with relatively well known bird migratory patterns

• Alternative area B1- Shabla and Kavarna Municipalities: A large portion of the installed wind power capacity in Bulgaria is located in these two municipalities. The area is located on the second largest bird migration route in Europe, Via Pontica. The combination of large wind farms and rich biodiversity has created tension between the wind power developers and the environmental NGOs in the area. The area around Shabla is highly environmentally sensitive because of the several protected wetlands located around the town and their significant importance for bird protection. Future wind power implementation projects are being planned.

• Alternative area B2 - Burgas and Aytos Municipalities: Wind power capacity has been steadily added to the area over the past few years and future developments are also planned. Similarly to the Shabla-Kavarna area, this area is on the Via Pontica bird route and contains several large water bodies which are habitat to many locally and globally endangered bird species – the Atanasovsko Lake and Burgas Lake, which are also NATURA 2000 sites.

The following map shows the location of these representative areas to conduct public consultation activities:

From these four proposed representative areas, two representative areas (one from each area type) have been selected by the MEET and the MoEW, based on the preliminary baseline review:

- Alternative area A2 - Krumovgrad and Momchilgrad Municipalities

- Alternative area B2 - Burgas and Aytos Municipalities


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Consultation has been undertaken (and will be repeated following the publication of the draft SER report) in the cities of Burgas and Momchilgrad, in addition, the stakeholders and general public from all four municipalities are invited to participate in the public consultation.

After the completion of the draft SER report, and as described in the Public Consultation and Disclosure Plan, meetings will be conducted with the local authorities and the local general public. The Public Consultation and Disclosure Plan20 is provided as a separate document.

4.2 Scoping Consultation The SER scoping consultation process was completed in a period of 30 days from the date of publication of the draft scoping report on the project website (www.bgwindenergy.com). The aim of the scoping consultation process was to allow the ministries, state agencies, regional and local authorities, energy companies, energy associations, NGOs, etc. to provide their feedback and suggestions on the SER scoping report.

The scoping consultation process was outlined in the Public Consultation and Disclosure Plan9, following the Bulgarian Legislative Requirements regarding Public Consultations and Information Disclosure, as detailed in the plan.

This section of the report summarises the main issues arising out of the scoping consultation process.

4.2.1 Activities performed during SER scoping consultation The public consultation exercise involved:

i) consultation meetings with the general public;

ii) meetings with institutional stakeholders;

iii) consultation workshops with major stakeholders;

iv) a dedicated website to facilitate access to project documentation, and e-mail and fax for written submissions.

A list of meetings participants and meetings minutes from the consultation sessions can be reviewed at Appendix I – Minutes of SER scoping consultation activities, of the Final Scoping Report21.

As part of the scoping consultation process, the stakeholders were encouraged to submit their verbal or written statements, opinions, recommendations and suggestions. The received written statements can be found at appendix II – Statements received during SER scoping consultation activities, of the Final Scoping Report11.

The scoping consultation process included the following activities:

• Technical project progress meeting in Sofia between the Consortium, EBRD, MEET and MoEW, November 26th, 2009;

• SER scoping technical consultation workshop in Sofia with representatives of all interested stakeholders from the three stakeholder groups (identified in section 3 of this report), December 14th, 2009;

20 Public Consultation and Disclosure Plan can be consulted on the project website: www.bgwindenergy.com


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• SER scoping technical consultation workshops at the two selected representative areas with representatives of all interested stakeholders from the three stakeholder groups, Burgas, December 16th and Momchilgrad, December 17th;

• SER scoping public consultation meetings at the two selected representative areas with the general public, Burgas, December 16th and Momchilgrad, December 17th;

• Technical meetings with stakeholders following up the official scoping consultation process.

• Technical Project Progress Meeting

An initial meeting with EBRD and the institutional stakeholders was organized in Sofia on November 26th. It served to highlight and resolve any outstanding issues and suggestions regarding the draft SER Scoping Report and the procedure for the upcoming scoping consultations. EBRD representatives from London were present at this meeting, together with the Consortium team leader, the Bulgarian consultant, as well as the representatives from the MEET and the MoEW.

• SER scoping technical consultation workshop in Sofia

The SER scoping technical consultation workshop was organized in Sofia, 14 days after the draft Scoping Report was published on the project website (www.bgwindenergy.com). It was conducted with the participation of representatives of the identified stakeholder groups. The workshop focused on the stakeholders’ feedback on the draft scoping report and on the other envisioned project activities, as well as on the opportunities for these stakeholders to participate in the SER development phase. Additionally, the stakeholders identified other stakeholders, not invited to this meeting, who should be included as part of the consultation process.

• SER scoping consultations at the Representative Areas

In addition to the SER scoping consultation workshop in Sofia, scoping consultation meetings were conducted at the cities of Momchilgrad and Burgas with local authorities and locally represented stakeholders from the energy, business and public interest groups from the municipalities of Krumovgrad, Momchilgrad, Burgas and Aytos. Two meetings were conducted at each of the two cities – one technical consultation workshop and one general consultation meeting.

• Technical meetings following up the official scoping consultation process.

After the official period for public consultation on the scoping report a series of technical meetings were arranged in order to fill in gaps identified during the scoping process. The aim of these meetings was to create a robust process of dataset collection and information gathering.

The collected input from the stakeholders was taken into account for the finalization of the SER Scoping Report.

4.2.2 Relevant issues during SER scoping consultation Feedback received during the scoping consultation process, on the development of wind power in Bulgaria, was both positive and negative – there is a general acceptance that the positive aspects of the development of wind power will be beneficial for Bulgaria. Nevertheless, concern existed regarding the environmental and social impacts, which should be taken into account when planning for future wind power development in the country.

The consultees provided many suggestions on how the development of wind power in Bulgaria can be improved, both in the relation to the environmental/social constraints, and in terms of


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technical issues, such as electrical grid improvement, streamlining of the connection process, and the need for investigation of the wind potential of the country.

Based on the stakeholders’ feedback and taking into account information which various stakeholders committed themselves to provided to the project, the project team concluded that in order to properly and efficiently analyze and integrate different types of information a Geographical Information System (GIS) should be used.

The main advantage of using GIS is that it allows to quickly combine and compare different types of geographical information (maps - for example location of wind turbines, nesting grounds, archaeological sites, residential areas) with alpha-numerical data (population, bird deaths, noise levels, etc.). Many of the datasets required for an area-based analysis, such as information on land use, environmental and social constraints, etc. are either readily available or can relatively easily be converted into GIS format.

The plans for the development of GIS have generated plenty of discussion between stakeholders, as can be viewed in the minutes of the different meetings and in the received statements (Appendix I and Appendix II of the final SER Scoping Report).

4.3 Consultation on the Draft SER report The consultation process for the draft SER report was organized in the same manner as the scoping consultation meetings, as envisaged on the Public Consultation and Disclosure Plan11, and following Bulgarian Legislative Requirements regarding Public Consultations and Information Disclosure. The duration of the SER Consultation process was around 30 days.

The following consultation meetings took place:

• Technical draft SER consultation workshop in Sofia;

• Technical draft SER consultation workshop in Momchilgrad;

• General public draft SER consultation meeting in Momchilgrad;

• Technical draft SER consultation workshop in Burgas;

• General public draft SER consultation meeting in Burgas.

The minutes of the meetings and workshops, as well as stakeholders’ comments and statements will be handled in the same manner as during the scoping consultation process. The minutes of all meetings are summarized in Appending G of this report. The statements submitted by stakeholders during the SER consultation process, along with the responses of the Consortium are presented in Appendix H of this report.

This final SER report was presented to and approved by the MEET and the EBRD.


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4.4 Timetable for the draft SER consultation process

4.5 Information disclosure during the draft SER report consultation process

The information disclosure during the consultation process for the draft SER report will be conducted in the same manner as the consultation for the SER scoping report as described within the Public Consultation and Disclosure Plan11.

Draft SER Report Technical Consultation Workshops:

• Posted letters, faxes and e-mails will be sent to identified stakeholders 7 days prior to the technical consultation workshops;

• Two copies of the draft SER report will be available for a period of 7 days prior to the conduct of the draft SER consultation workshop.

• At least 7 days before the draft SER consultation workshop, the draft SER report will be uploaded on the project website.

Draft SER Report General Public Consultation Meetings:

• Announcement will be published in national, regional and/or local newspapers 7 days before each meeting.

• Two paper copies of the draft SER report will be available for a period of 7 days prior to the conduct of the consultation meeting.

• At least 7 days prior to the consultation meetings, the scoping SER report will be uploaded on the project website.

4.6 Information disclosure at the end of the project At the end of the project, hard and electronic copies of the finalized SER report, as well as other finalized project deliverables (various guidances) will be submitted to the MEET. The project will be concluded by a final presentation by the Consortium to the MEET and EBRD.

The finalized versions of all project deliverables will be available on the project website, www.bgwindenergy.com.

Activity Location Stakeholders Date


Sofia Institutional, Energy Business, Public Interest

25 May 2010


Momchilgrad Institutional, Energy Business, Public Interest

27 May 2010


Momchilgrad General Public, Landowners 27 May 2010


Burgas Institutional, Energy Business, Public Interest

28 May 2010


Burgas General Public, Landowners 28 May 2010


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5 Policy Context and Baseline Review 5.1 Summary of Policy Context, Baseline Review and Key Environmental and Social Issues

This section of the Environmental Report summarises available information for each topic setting out the policy context, the baseline information and the key issues identified.

As described within Section 3.2 Stage A: Scoping and SER objectives, a topic-based approach for gathering information and identifying sustainability issues has been used to establish the baseline for this SER22.

The key purpose of scoping is to identify key issues of concern at an early stage so that they can be considered in appropriate detail in the SEA. Scoping also aids in the identification of information sources and data gaps that may require to be filled by studies or surveys to support the assessment. Information from specific technical and data reports reviewed as part of this SER are included in the relevant sections below.

Sections 6, 7, 9 and Appendix D of this report provide additional information on the baseline review and on the identified data gaps.

5.1.1 Energy, Climate and Air Quality The following table summarises the key issues identified in the regulatory overview and baseline review in regards to energy, climate and air quality. The key environmental issues identified from the Topic Paper 1 and from the additional data review are also presented:

Table 14 – Energy, Climate and Air Quality Policy Context, Baseline Review and Environmental Issues

Policy Context

• Directive 2009/28/EC on the promotion of the use of energy from RS - Bulgarian national target is 16% share of energy from renewable sources in gross final energy consumption in 2020.

• Renewable and Alternative Energy Sources and Biofuels Act (RAESBA) (promulgated SG No 49/2007, last amended SG No 98/14.11.2008) - Sets the rules for (1) the generation and consumption of electrical and heat energy and/or energy for cooling from RS and from alternative energy sources (AES); (2) the production and consumption of biofuels and other renewable fuels in the transport sector; (3) the diversification of the energy supply; (4) the increase in the capacity of the small and medium facilities and generators of energy from RS and alternative sources (AS) and the producers of biofuels and other renewable fuels; (5) the environmental protection; and (6) the creation of conditions for achieving sustainable development at regional and local level.

• National Long Term Programme to Promote the Use of RES (2005-2015) - Aims to reduce the energy demand of the GDP through the reduction of the energy consumption of all sectors of the economy.

• National Renewable Energy Action Plan by 2020 (NREAP) - Prescribes the setting of national indicative targets for the share of energy from RS consumed in transport, electricity and heating and cooling. The Draft version of this plan is currently under revision.

22 All project documents, including the 7 Topic Papers, can be consulted at the project website: www.bgwindenergy.com.


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• Kyoto Protocol to the UN Framework Convention on Climate Change (United Nations, 1992) - Bulgaria ratified the Protocol in 2002 and has a legally binding target of 8% below the 1988 greenhouse gas emission level which has to be achieved by 2020. Currently Bulgaria has achieved a 30% reduction.

• Second National Action Plan on Climate Change (2005-2008) - Provides a set of back-up political instruments and measures that can be implemented if the emission increase is faster than anticipated or when the financial situation in Bulgaria allows for active participation of the government in this area.

• Clean Air Act, (promulgated SG No 45/28.05.1996, last amended SG No 93/24.10.2009) -Aims to protect public health, animals and plants, their communities and habitats/ objects of natural and cultural value from harmful impacts.

• Regulation 7 on ambient air quality assessment and management -Defines the terms and procedures for the assessment and management of air quality, including the development of a State policy for assessment and management of air quality.

Baseline Review

• The GDP of Bulgaria is considerably more energy-intensive than other EU Member States.

• Bulgaria obtains over 70 % of its total primary energy resources from imports, although the statistical indicator for energy dependency is considerably lower – 51.7 % since the methodology recognizes nuclear energy as a local source (data for 2007, derived from NSI statistics).

• Bulgaria generates electricity through a variety of means, including nuclear, thermal and hydro plant. Coal fired heat power plants predominate, followed by nuclear power. Proven reserves of lignite coal are sufficient to ensure electrical generation for 50-55 years. Natural gas reserves are quite modest, and dependency on the import of natural gas and crude oil is practically total. Nuclear fuel is imported.

• Bulgaria has a significant unused potential of RES (approximately 6000 Mtoe) which, given the current rate of energy consumption, amounts to about 15% of the country’s energy needs.

• Energy generated from RS in 2007 was 1029 ktoe and is mostly produced by biomass (72%), hydro power plants (25%), and geothermal energy and others (3%).

• The electrical power produced by wind generators represented 4,1 % of the electricity generated by RES in 2008 and 6,4% in 2009.

• RES in Bulgaria and the market potential for wind farm development in the country is significant.

• The targets for Bulgaria, as proposed by the Commission, are 11% share of energy from RS in gross inland electricity consumption by 2010 and 16% share of energy from RS in the gross final energy consumption by 2020.

• During recent years there has been a tendency towards a warmer and dryer climate.

• Bulgaria has achieved a 30% reduction of emission of greenhouse gases (GHG), making it one of the few EU countries to achieve its targets under the Kyoto Protocol. The country now faces the challenge to control and limit future increases in emissions resulting from economic growth.

• The energy sector, both supply and demand, is the most important sector from the perspective of GHG mitigation.


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• Wind energy plays an important global role in addressing climate change.

• The energy sector, particularly thermal power plants, is the main polluter of ambient air.

• The installation and operation of facilities for the production of electricity from RES, particularly wind farms, have a minimum environmental impact compared to the use of classic technologies in thermal power plants.

Additional Data Review

• Annual GHG emission inventories (2006, 2007, and 2008).

Key Environmental Issues

• Power consumption is one of the greatest challenges for Bulgaria both in terms of increasing competitiveness, and for the issues reduction of greenhouse gas emissions.

• The country is likely to experience a number of changes due to climate change such as warmer wetter winters, more stormy weather and hotter summers. This will have numerous effects on energy consumption trends.

• The energy sector and particularly thermal power plants (TPP) operating with local lignite coals are the main source of emissions of sulphur oxides, carbon dioxide and a considerable source of pollution with nitrogen oxides, dioxins and furans and dust. TPP are the second most significant emitters of mercury in Bulgaria. Activities connected with extraction and conversions of fossil fuels remain the most significant methane pollutants.

• The energy sector is the most important sector from the perspective of GHG mitigation, accounting for two thirds of total GHG emissions.

• Bulgaria has to achieve 11% share energy from RS in gross inland electricity consumption by 2010 and 16% share of energy from RS in the gross final energy consumption by 2020.

5.1.2 Cultural Heritage The following table summarises the key issues identified in the regulatory overview and baseline review in regards to cultural heritage. The key environmental issues identified from the Topic Paper 2 and from the additional data review are also presented:

Table 15 – Cultural Heritage Policy Context, Baseline Review and Environmental Issues

Policy Context

• UNESCO Convention Concerning the Protection of the World Cultural and Natural Heritage (1972) - Each State Party to this Convention is required to identify and delineate the different properties situated on its territory classified as natural and cultural heritage. Bulgaria adopted this convention on February 1974, which entered into force on September 1975 (amended SG 44/2005).

• Cultural Heritage Act (promulgated SG No 19/13.03.2009, last amended SG, issue 93/24.03.2009) - Regulates the conservation and protection of cultural heritage of Bulgaria.

• Spatial Planning Act (promulgated SG No 1/02.01.2001, last amended SG, issue 15/23.02.2010) - Defines the strategy and the mechanisms for territory management, both urban and rural, which plays a key role in the preservation and revitalization of the heritage.

• Tourism Act (promulgated SG No 28/01.04.2002, last amended in SG, issue


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15/23.02.2010) - Covers amongst others activities related to tourism, museums, reserves and areas and objects with cultural values under the Cultural Heritage Act.

• Black Sea Coastal Area Development Act (promulgated SG No 48/15.06.2007, last amended SG No 92/20.10.2009) - Aims to recover and protect the natural landscape and cultural and historical heritage. According to this Act, specialized activities for the protection of individual and group areas and objects with cultural values are allowed in coastal areas. The Act is prescribes activities which can be carried out during implementation of investment projects within the areas of cultural and historical protection.

Baseline Review

• There are 9 UNESCO World Heritage Sites in Bulgaria: 7 World Cultural Heritage Properties and 2 World Natural Properties.

• Additionally, 8 properties are inscribed in the World Cultural Heritage Tentative List and 6 are inscribed in the World Natural Properties Tentative List.

• Spatial distribution on World Heritage Properties has been identified through the baseline review.


• Distance from wind turbines to world heritage properties which minimize the visual impact.


• Lack of adequate legislation in the field of cultural heritage. No regulation for selection/appointment of new World Heritage Properties and for elaboration of management plans for the Tentative List sites. This fact may generate conflicts of interest when selecting areas for wind power implementation.

• There is no comprehensive cultural heritage preservation programme for establishing interactive information awareness.

5.1.3 Fauna, Flora and Biodiversity The following table summarises the key issues identified in the regulatory overview and baseline review in regards to fauna, flora and biodiversity. The key environmental issues identified from the Topic Paper 3 and from the additional data review are also presented:

Table 16 - Biodiversity, Flora and Fauna Policy Context, Baseline Review and Environmental Issues

Policy Context

• EU Directive 79/409/EEC on the Conservation of the Wild Birds (Birds Directive) - Aims to protect, manage and regulate all bird species naturally living in the wild, including their eggs, their nests and their habitats, and to regulate the exploitation of these species. Member States must encourage research and activities conducive to the protection, management and exploitation of the bird species covered by the Directives. In accordance with this Directive, Bulgaria has 114 Special Protected Areas (SPA’s).

The Birds Directive establishes a general system of protection for all wild bird species in the EU is in place. “Member States should take the requisite measures to establish a general


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system of protection for all wild bird species throughout their natural range within the EU. In particular they should prohibit the following: deliberate killing or capture by any method; … deliberate disturbance of these birds particularly during the period of breeding and rearing, in so far as this would have a significant negative effect on the birds; …”(cf Article 5). These provisions apply both inside and outside protected sites. Derogations as set in article 9 are allowed in some circumstances (e.g. to prevent serious damage to crops, livestock, forests, fisheries and water) provided that there is no other satisfactory solution and that the consequences of these derogations are not incompatible with the overall aims of the Directive.

• EU Directive 92/43/EEC on the Conservation of the Natural Habitats and of the Wild Fauna and Flora (Habitats Directive) - Aims to help maintain biodiversity by defining a common framework for the conservation of wild plants and animals and habitats of Community interest. Member States must take all necessary measures to guarantee the conservation of habitats in special areas of conservation, and to avoid their deterioration. In accordance with this Directive, Bulgaria has 228 proposed Sites of Community Importance (SCI).

Article 6 of the Habitats Directive lays down procedural safeguards to be followed in case of new developments.

Under the Birds Directive, sites need to be classified for 190 species of birds listed in Annex I of the Directive (article 4.1). Member States must also classify sites for other regularly occurring migratory bird species not listed in Annex I, bearing in mind the need to protect their breeding, moulting and wintering areas and staging posts along their migration routes, e.g. wetlands of international importance (article 4.2). These sites are called Special Protection Areas (SPAs) and are included directly into the European NATURA 2000 Network23. Special measures have to be taken in SPAs in order to achieve protection of species and their habitats. The network of Special Protection Areas should form a coherent body, which, together with sites designated under the Habitats Directive (92/43/EEC), will form the ecological network NATURA 2000. The protection regime applicable to Special Protection Areas, originally laid down in Article 4.4, has now been replaced by Article 6.2–6.4 of the Habitats Directive. The Article 4.4 applies also for sites proposed but not yet designated as SPAs (ECJ judgment - C-374/98).

Managing and conserving NATURA 2000 sites

Member States must:

- take appropriate conservation measures to maintain and restore the habitats and species for which the site has been designated to a favourable conservation status (Article 6.1).

- avoid damaging activities that could significantly disturb these species or deteriorate the natural habitat types or habitats of the protected species (Article 6.2);

The ultimate objective is to ensure that the species and habitat types are maintained or restored to a favourable conservation status across their natural range.24 To help decide which conservation measures should be undertaken on individual N2000 sites, the Habitats Directive encourages the development of management plans which are specifically designed for the site in question or integrated into other development plans. Whether or not

23 In contrast to the Habitats Directive, there is no intermediary step of selecting sites according to biogeographical region in the case of SPAs. These are included directly into the NATURA 2000 Network 24 The concept of Favourable Conservation Status is not mentioned in the Birds Directive but there are analogous requirements, i.e. all SPAs must still be subject to special habitat conservation measures in order to ensure the survival and reproduction of the Annex I birds in their area of distribution.


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management plans are drawn up, competent authorities in each country must establish the conservation objectives for each NATURA 2000 site based on the status and ecological requirements of the habitats and species for which the site is designated a NATURA 2000 area.

New developments affecting NATURA 2000 sites

Articles 6(3) and 6(4) of the Habitats Directive lay down the procedure to be followed when planning new developments that might affect a NATURA 2000 site25. This stepwise procedure requires that a plan or project having a potentially significant negative effect on a NATURA 2000 site undergoes an ‘Appropriate Assessment’ to study these effects in detail and to see how they relate to the site’s conservation objectives.

Depending on the findings of the Appropriate Assessment, the competent authority either agrees to the plan or project as it stands if it has ascertained that it will not adversely affect the integrity of the site, or depending on the degree of impact it may require one or more of the following:

− certain mitigation measures are introduced to prevent the negative effects;

− certain conditions are respected during construction, operational or closure phases of the project, again to prevent the likelihood of negative effects or to reduce them to an insignificant level where no longer affect the integrity of the site;

− alternative options are explored instead.

In exceptional circumstances, a plan or project may still be allowed to go ahead under certain conditions, in despite of being assessed as having negative effects on the site provided that procedural safeguards laid down in the nature Directive are followed. This may be possible, for instance, if the plan or project is considered to be of overriding public interest and there are no alternatives available. In such cases, compensation measures will need to be introduced to ensure that the overall coherence of NATURA 2000 is protected.

Improving the ecological coherence of the NATURA 2000 Network

In addition to designating core sites under the NATURA 2000 Network, Article 10 of the Habitats Directive also requires Member States to endeavour, through land use planning or development policies, to improve the ecological coherence of the network by maintaining and, where appropriate developing, features of the landscape which are of major importance for wild fauna and flora, such as wildlife corridors or stepping stones, which can be used during migration and dispersal.

• Convention on the Conservation of European Wildlife and Natural Habitats26 (‘Bern Convention’) came into force in 1982. It has been signed by 42 Member States of the Council of Europe, as well as the European Community and four countries in Africa. Bulgaria is a contracting party since 1991. An important objective of the convention is the creation of the Emerald Network27 of Areas of Special Conservation Interest (ASCIs). This operates alongside the EU NATURA 2000 Network. Specifically, each contracting party

25 This applies to SCIs, SACs and SPAs and concerns not just plans or projects inside a NATURA 2000 sites but also those that are outside but could have a significant effect on the conservation of species and habitats within the site. For instance a dam constructed upstream on a river that could alter or stop the regular flooding of an important wetland for birds within an SPA further downstream. 26 More information on http://www.coe.int/t/dg4/cultureheritage/conventions/bern/default_en.asp. 27 More information on http://www.coe.int/t/dg4/cultureheritage/regional/econetworks/emeraldnetwork_en.asp.


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undertakes to:

- take appropriate and necessary legislative and administrative measures to ensure the conservation of the habitats of the wild flora and fauna species especially those specified in Appendices I and II, and the conservation of endangered natural habitats (Article 4.1)

- give special attention to the protection of areas that are of importance for the migratory species specified in Appendix II and III and which are appropriately situated in relation to migration routes, as wintering, staging, feeding, breeding or moulting areas (Article 4.3)

- prohibit the deliberate damage to or destruction of breeding or resting sites of Appendix II species (Article 6.b).

A resolution on effects of wind turbines on migratory species of mammals and birds was adopted in 2002.

Due to the fact that Bulgaria is a party member of this convention an EU Recommendation was issued on wind farms development on the Via Pontica route:

Recommendation No. 130 (2007) of the Standing Committee of the Bern Convention, adopted on29 November 2007, on the wind farms planned near Balchik and Kaliakra, and other wind farm developments on the Via Pontica route (Bulgaria) The Recommendation, adopted on a base of Article 1.2, 3.2 and 4 of the Convention and Recommendations No. 117 (2005)28 and No 109 (2004)29 and referring to document T-PVS/Inf (2003) 1230, requires: (1) … ensure that new plants are not built in the region unless Environmental Impact Assessment (EIA) prove they do not have a substantial negative effect on the biological diversity protected under the Convention - EIA reports should be more precise and scientifically sound than those already presented and should formulate independent peer reviewed conclusions; … (6) conduct an Strategic Environmental Assessment (SEA) of Bulgaria’s wind energy programme, taking into account possible conflicts of wind energy production within the most intensive bird movements areas, in particular along the Black Sea coast; (7) establish a strict moratorium on further turbines and wind farm projects in the coastal areas of Bulgaria until EIA and SEA reports mentioned in paragraphs 1 and 6 are completed; (8) respect the need to focus on the avoidance of the impacts coming from outside having negative effects on areas of recognized conservation importance.

• Convention on the Conservation of Migratory Species of Wild Animals31 (CMS, ‘Bonn Convention’) aims to preserve migratory species throughout their natural range. It entered into force in 1983 and has now been signed by more than 100 parties. This convention is in force in Bulgaria since 1999. Range States are obliged to endeavour, amongst other things, to:

- conserve and, where feasible and appropriate, restore those habitats of the species which are of importance in removing the species from danger of extinction (Article III 4a); and

- with regard to the Agreements which Parties are encouraged to conclude for Appendix II species, each Agreement should, where appropriate and feasible, provide for the maintenance of a network of suitable habitats appropriately disposed in relation to the

28 Adopted on 1st December 2005, on the plan to set up a wind farm near the town of Balchik and other wind farm developments, on the Via Pontica route (Bulgaria) 29 Recommendation on minimizing adverse effects of wind power generation on wildlife 30 BirdLife International’s report: “Wind farms and Birds: an analysis of the effects of wind farms on birds, and guidance on environmental assessment criteria and site selection issues” 31 More information on http://www.cms.int.


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migration routes.

Special attention should be given to the following agreement signed under this Convention for the management of conflicts between migrating animals and wind farms:

- Agreement on the Conservation of African-Eurasian Migratory Waterbirds32 (AEWA) calls for coordinated action throughout the migration routes or flyways. AEWA aims to create the legal basis for a concerted conservation policy among the range states of all migratory waterbird species and populations, which migrate in the African-Eurasian flyway, irrespective of their current conservation status. The Agreement provides a framework for conservation action, monitoring, research and management of several globally important bird-migration systems. It came into force in 1999. The agreement covers 119 countries and 235 species of waterbirds. The European Community ratified AEWA in 2005.

• Convention of Wetlands of International Importance (‘Ramsar Convention’33) is an intergovernmental treaty providing a framework for national action and international cooperation for the conservation and wise use of wetlands. The main undertakings accepted by the contracting parties to the ‘Ramsar Convention’ are to: • designate suitable wetlands within (their) territory for inclusion in a List of Wetlands of International Importance (the Ramsar List) (Article 2.1); • formulate and implement their planning so as to promote the conservation of the wetlands included in the List, and as far as possible, the wise use of wetlands in their territory (Article 3.1); and • promote the conservation of wetlands and waterfowl by establishing nature reserves on wetlands whether they are included in the List or not, (Article 4.1). Each contracting party must designate at least one site for inclusion in the List at the time it joins the Convention (Article 2.4). The responsibilities of the contracting parties include integral conservation of biodiversity in wetlands, preparation of management plans, public awareness, etc. Specific criteria have been drawn up under the Convention to aid the identification of sites of international importance. It was adopted in 1971 and amended in 1982 and 1987. There are to date 158 parties and so far 1723 sites worldwide have been added to the ‘Ramsar’ list of wetlands of international importance. Bulgaria adopted the Ramsar Convention in 1976.

• Convention on Biological Diversity34 (CBD) is a global treaty, adopted in Rio de Janeiro in June 1992. It widened the scope of biodiversity conservation from species and habitats to the sustainable use of biological resources to the benefit for mankind. For the conservation of biodiversity the primary approach is in situ conservation (Article 8). Parties have to identify components of biodiversity important for its conservation and sustainable use (Article 7), inter alia ecosystems and habitats with large numbers of threatened species or required by migratory species (Annex I). To date, 189 parties have ratified the convention. It come into force in Bulgaria on 29 February 1996, and there is already adopted National Biodiversity Conservation Strategy.

• Biodiversity Act (BA) (promulgated SG No 77/09.08.2002, last amended SG No 103/29.12.2009) - Establishes a national ecological network in accordance with NATURA 2000. It defines the responsibilities of the State, municipalities and individual citizens in protecting the diversity of plant and animal species within and outside the protected areas system. It is complemented by the National Action Plan for Biological Diversity Conservation of the five-year period 2005-2010.

All species listed in annex III of the BA require strict protection under article 37 of the BA.

32 More information on http://www.unep-aewa.org 33 More information on http://www.ramsar.org 34 More information on http://www.cbd.int.


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According to Article 38, par. 1, for those species the following activities are prohibited: 1. All methods of deliberate capturing or killing of individuals by using any tools, means and methods; 2. Prosecution and disturbance, especially during the breeding period, during the winter and migration; (…) 4. Deterioration or destruction of the breeding areas and areas for roosting and congregation during migration (…)

• Environmental Protection Act (promulgated SG No. 91/ 25.09.2002, last amended March 2010 (amendment in progress)) - Outlines the general principles of environment protection in Bulgaria and provides the framework for the control of environmental conditions and the supervision over activities which may harm the environment.

• Convention on prevention of pollution of Black Sea. This Convention was adopted in 1992 and it is in force since 1994. It is ratified by 6 countries across the Black Sea. The main objective of the Convention is to prevent pollution of Black Sea by certain pollutants, including inland waters, as well as to preserve the natural habitats of species. The contracting parties have to take actions to prevent, diminish, and if possible to remove pollution by oil and other pollutants generated by discharged of ships or plains or generated on land and that deteriorate the habitats. A protocol on protection of biodiversity is adopted under the Convention, in relation with the issues of overexploitation of resource species, extinction of threatened species in Black Sea and adjacent wetlands, as well as the lack of protection of habitats and the landscape.

Baseline Review

• Bulgaria is characterized by a large diversity of plant and animal communities and has examples of almost all main types of habitats and biotopes known in Europe.

• Approximately 30% of Bulgaria’s territory is covered by forests areas, 60% of which are considered of natural origin.

• Bulgaria’s biota ranks among the most species-rich in Europe.

• More than 20,000 invertebrates have been described for Bulgaria. This total includes more than 1,800 protozoans and more than 2,500 arachnids, molluscs, nematodes, and other non-insect invertebrates.

• About 85% of the known invertebrates are insects. Almost 17,500 insect species and subspecies have been described, and the total number has been estimated at 27,000. Within several insect orders (e. g., the Ephemeroptera, Heteroptera, and Orthotera), more species are known to occur in Bulgaria than in all of Central Europe. Of special note is Bulgaria’s unusually diverse invertebrate cave fauna.

• According to best available information it is estimated that only 51% of insect species existing in Bulgaria are identified and described. There are no quantitative studies on amphibian populations in the country, while it is known that these have been particularly hard hit by environmental changes in a global level. Even with regard to small mammals there are no reliable distribution maps.

• According to the National Plan for the protection of biological Diversity (2005-20010), Bulgaria is among the 5 countries in Europe with the richest biological heritage.

• Extinct, threatened, endangered and rare and protected species have been identified through the baseline review.

• In Bulgaria, there are 288 breeding bird species recorded including the following species, which are globally threatened by extinction: Dalmatian Pelican (Pelecanus crispus), Imperial Eagle (Aquila heliaca), Egyptian vulture (Neophron percnopterus), Corncrake (Crex crex), Lesser Kestrel (Falco naumanni), Saker Falcon (Falco cherrug), Ferroginous


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Duck (Aythya nyroca), Semi-collared Flycatcher Ficedula semitorquata, etc. Significant part of the European breeding populations of the Imperial eagle (Aquila heliaca), the Semi-collared Flycatcher (Ficedula semitorquata), the Olive-tree Warbler (Hippolais olivetorum) and Pied Wheatear (Oenanthe pleshanka).

• Migrations routes, protected areas and NATURA 2000 sites have been identified through the baseline review.

• About 78% of the global population of the White Stork (Ciconia ciconia), 37% of the European population of the Dalmatian Pelican (Pelecanus crispus), 53% of the European population of the Lesser Spotted Eagle (Aquila pomarina), 24% of European population of the Black Stork (Ciconia nigra) and the entire European population of the White Pelican (Pelecanus onocrotalus) migrate along Via Pontica route.

• Among the regularly occurring bird species migrating along Via Pontica are 24 globally threatened species, including Slender-billed Curlew (Numenius tenuirostris), Sociable Lapwing (Vanellus gregarious), Dalmatian Pelican (Pelecanus crispus), Red Kite (Milvus milvus), Egyptian Vulture (Neophron percnopterus), Pallid Harrier (Circus macrourus), Imperial eagle (Aquila heliaca), Greater Spotted Eagle (Aquila clanga), Lesser Kestrel (Falco naumanni), Red-footed Falcon (Falco vesperinus) and Saker Falcon (Falco cherrug), Ferruginous Duck (Aythya nyroca), European Roller (Coracias garrulous), Corncrake (Crex crex), Aquatic warbler (Acrocephalus paludicola), Eurasian Curlew (Numenius arquata) and Great Snipe (Gallinago media).

• More than 200 bird species overwinter in Bulgaria – almost the whole global population of the globally endangered Red-breasted Goose (Branta ruficollis), significant part of the Black Sea biogeographical population of the White-headed Duck (Oxyura leucocephala) and the endangered Lesser White–fronted Goose (Anser erythropus). The most important wetlands for the wintering waterfowl are the Shabla and Durankulak lakes, Varna-Beloslav lake, Burgas wetlands (Pomoriisko, Atanasiovsko, Burgasko and Mandra lakes), the reservoirs in south Bulgaria – Pyasachnik, Ovcharitsa, Rozov kladenets, Zhrebchevo, Malko Sharkovo, Tserkovski, etc., the reservoirs of Ogosta, Gorni Dubnik and Tsonevo in North Bulgaria, as well as the Danube River with its adjacent wetlands.

• Bulgaria is one of the four countries in Europe where the Lesser White-front Goose is recorded to stage during the winter.

• Twenty nine of the species occurring in Bulgaria are threatened by global extinction, where the global population of several of them are concentrated in Bulgaria as follow: Red-Breasted Goose (in winter), Dalmatian Pelican (breeding, migration and wintering) and Semi-collared Flycatcher (breeding).

• 133 species of those listed in Annex I of Directive 79/409 are recorded in Bulgaria.

• Under protection of the Bern Convention there are 383 species (279 under annex II and 104 under annex III).

• Under the protection of the Bonn Convention there are 15 species with strict protection and 199 species for which the member states have to sign agreements on conservation of their habitats. Most of these species are also subject of the Afro-Eurasian Waterbird Agreement (AEWA), including the White Stork (Ciconia ciconia), the Black Stork (Ciconia nigra), the two species of pelicans, all geese species, Ferruginous Duck (Aythya nyroca), etc.

• At the national level, 154 bird species (36% of Bulgarian avifauna) are listed in the Bulgarian Red Data Book (in press) as having unfavourable conservation status in the country. In total, 31 species are qualified as critically endangered by extinction at national level.


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• About 110 species have direct ecological connection with the farmlands, including the globally threatened Lesser Kestrel (Falco naumanni), Great Bustard (Otis tarda) and Corncrake (Crex crex).

• All 114 Important Bird Areas (IBA´s) in Bulgaria meet the EU criteria and are approved as SPAs, although for 6 of them, the area which falls within a SPA is significantly reduced. These 6 IBAs are currently subject to an EU infringement procedure. Most of the IBAs, important for waterfowl, meet at least one of the Ramsar criteria for wetlands of international importance and 10 of them have already been designated.

• In 2007, a total of 114 Special Protection Areas (SPA´s) sites where proposed to the Bulgarian government. Of these proposed sites, up to date 95 have been officially designated.

• Of the officially designated ones, 22 have in their designation orders restrictions either specifically for wind power development or for most commercial and industrial activities. These are the considered SPAs Atanasovsko ezero, Vrachanski Balkan, Emine, Kaliakra, Kamenski bair, Complex Ropotamo, Zaliv Chengene skele, Ostrov Vardim, Ostrov Golya, Ostrov Tsibar, Ostrov Ibisha, Ostrov Lakat, Ostrov Pozharevo, Pomoriysko ezero, Ribarnitsi Mechka, Ribarnitsi Plovdiv, Yazovir Konush, Melnishki piramidi, Derventski vazvisheniya, Durankulashko ezero, Shablenski ezeren complex and Rupite.


• BAS report on the assessment of NATURA 2000 network.

• Spatial locations have been identified for: SPA, SCI NATURA 2000 zones, protected territories, important plant areas, non-fragmented large forest landscapes, areas with conservation importance for bat species, forests with high conservation value, microreserves proposed by BAS, grassland habitats (Habitat Directive – Annex 1) in NATURA 2000, habitats of species (Habitat Directive-Annex 2) in NATURA 2000, dens of wolfs and bears in NATURA 2000, bottleneck sites of large carnivores outside NATURA 2000, known regular foraging and roosting areas for geese in Dobtudzha region, etc.

• Guidance for conducting assessment of the impact of wind generators on habitats and species in protected areas has been reviewed.

• Spatial location of plants, habitats and animals included in the new Red Book, has been reviewed.

• Recommendations for bird behaviour related to wind turbines have been considered.

• Data on various bird species (raptors and vultures) have been reviewed.

• Map of studied part of Via Pontica migration route (2004-2006 and the data from the radar survey 1982-1983) – migration corridors and white stork roosting areas have been identified.

• The report of analyzed data on migration of soaring birds along the Black Sea Coast \Via Pontica (field survey conducted 2004-2006), has been reviewed.

• Distribution maps of breeding birds of prey in Bulgaria (for each species), based on standard UTM grid 10x10 km (as published in the Bulgarian Breeding Birds atlas, 2007), have been identified.

• Available GIS data of distribution (location of nests, feeding areas) of some key species, vulnerable to wind farms, specially studied during last five years all over the country : Egyptian Vulture, Red Footed Falcon, Great Bustard, White tailed Eagle, Imperial Eagle, Golden eagle and Grifon Vulture, have been identified.


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• Spatial location and data for waterfowl congregations in wetlands in Bulgaria have been identified.

• Processed data from satellite tracking of Imperial Eagle and Saker Falcon – areas of importance of the species were identified.

• Data on birds provided by Petar Shurolinkov, PhD, have been reviewed.

• Database of the Bulgarian Bird Quest has been assessed, as well as the book on birds of the Danube River.

• List with designations of the protected territories has been reviewed in order to determine which ones are protected for birds.

• Thesis on the night migration of Bulgaria using the method of moon counting by Pavel Zehtindzhiev, PhD, has been reviewed.


• The large diversity of plant and animal communities and the presence of almost all main types of habitats and biotopes known in Europe represent a big challenge for nature conservation in Bulgaria.

• There is a potential conflict between wind power development and nature conservation sites.

• There is a potential conflict between wind power development Habitats, Rare and National Scarce plants and invertebrate species.


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5.1.4 Soil and Water The following table summarises the key issues identified in the regulatory overview and baseline review in regards to soil and water. The key environmental issues identified from the Topic Paper 4 and from the additional data review are also presented:

Table 17 – Soil and Water Policy Context, Baseline Review and Environmental Issues

Policy Context

• Soil Act (promulgated SG No 89/06.11.2007, last amended SG No 80/09.10.2009) – Aims to prevent damage to soil and disturbance of their functions; permanent preservation of soil functions, recovery of damaged functions of soils.

• Water Act (promulgated SG No 67/27.07.1999, last amended SG No 103/29.12.2009) – framework water policy legislation, which regulates the management and ownership of water bodies and resources in Bulgaria for the purpose of water resource conservation and environmental protection.

• Agricultural land Protection Act (promulgated SG No 35/24.04.1996, last amended SG No 103/29.12.2009) - Governs protection from damage, recovery and improvement of fertility of agricultural land and determines the conditions and procedure for changing their purpose.

• Act on the Ownership and Use of Agricultural land (promulgated SG No 17/01.03.1991, last amended SG No 99/15.12.2009) - Regulates the ownership and use of agricultural land.

• Forests Act (promulgated SG No 125/29.12.1997, last amended SG No 103/29.12.2009) - Aims to preserve Bulgarian forests as national wealth - a major beneficiary environmental factor through reproduction and sustainable development and versatile use in the interests of owners and society.

• Regulation No 13/ 02.04.2007 on characterization of surface water (promulgated SG No 37/08.05.2007) - Determines the procedure for characterization of surface water bodies, each category of water bodies being identified on the basis of hydro-morphological, chemical and physical-chemical quality indicators.

• Regulation No 5/ 23.04.2007 on water monitoring (promulgated SG No 44/05.06.2007) - Set the methods and procedures for water monitoring and the establishment of water monitoring network in each basin management area.

• Regulation No 1/ 10.10.2007 on the Exploration, Use and Protection of Groundwater (promulgated SG No 02/02.01.2010) - Aims to protect groundwater resources, which are one of the main sources of drinking water, limit the contamination of groundwater bodies, and ensure good quality, and sufficient quantity of groundwater resources.

• Ordinance 3 from 16.10.2000 (SG issue 88/2000) for the conditions and order of investigation, designing, approval and operation of the sanitary-protective zones around the water sources and the potable water supply facilities and around the mineral water sources, used for healing, preventive, potable and hygiene needs.

• Order No RD-321/07.05.2007 of the Minister of environment and water for determination of priority and priority hazardous substances in the field of water policy (promulgated SG No 44/05.06.2007) - Sets the priority dangerous substances and pollutants, in the area of water protection.


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Baseline Review

• The Institute of Soil Science "Nikola Poushkarov" is responsible for collating soil information aiming to build a Soil Geographic Information System.

• The distribution of the territory of Bulgaria according to the classes of potential soil risk has been conducted.

• In Bulgaria there are extensive farming areas to the north of the country with the south and central areas dominated by forests and mountain pastures. The southwest areas of the country are dominated by farming and permanent crops.

• Bulgaria’s soil quality is characterised by soil degradation primarily due to the introduction of large scale agriculture in 1940s and 1950s, whereby boundary strips were ploughed up and most of the trees and bushes removed. Diffuse soil contamination is mainly associated with atmospheric deposition, certain agricultural practices and inappropriate treatment and recycling of wastes and wastewater.

• Soil erosion is one of the most pressing issues in Bulgaria, and in most dominant near the central mountain regions as well as in the north of the country.

• Approximately 55 % of the predicted annual soil loss from water erosion is identified in nine administrative districts.

• Local sources of soil pollution are: industrial activities, waste management activities, fertilizer and pesticide storage sites. The industrial activities (historical or current) result in considerable risk for soils and groundwaters.

• Soil acidification in Bulgaria caused by acidic industrial wastes has been established in a limited number of areas adjacent to the pollution sources.

• In Bulgaria no soil contamination with persistent organic pollutants is registered by the EEA (Executive Environmental Agency).

• In Bulgaria, 7,6% of the soils monitoring stations have reported heavy metals concentrations above limit values.

• The use of salt for road cleaning during the winter has resulted in salinisation of adjacent soils.

• About 35,500 ha of arable soils, damaged by salinisation processes, are currently registered in this country, 252 ha being salinized with common soda and chlorides.

• Bulgaria’s hydro-geographical network is particularly dense and complex. The Water Act divided the country into four River Basin Management Districts which are based on their catchments areas. These areas have been geographically identified.

• The level of risk impacts as a result of anthropogenic pressure has been identified for surface water bodies in each of the four water basin management areas.

• Bulgaria is considered to have a medium risk of flooding. The level of importance of the elements at risk exposed to flood hazards has been identified.

• The main sources of pollution of water bodies in Bulgaria include industry, municipal wastewater, farming, livestock rising, and transportation.

• Diffuse pollution, especially from agricultural sources, as well as pollution from untreated municipal wastewater creates the main hazards for the coastal waters in Bulgaria.


• Spatial location of: agricultural land categories 1 to 4, sanitary zones I (from Pleven, Plovdiv, Varna and Blagoevgrad), contaminated soils I and areas with high erosion risk,


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have been identified.

• Proposed plans for management of basin directorates have been taken into account.


• Soil erosion is considered to be wide spread in Bulgaria.

• Groundwater is a major source for water consumption and irrigation of crops and as a result it is strictly regulated.

• Surface waters are important sources of drinking water as well as sustaining a wide range of flora and fauna.

• Changes in land use should be considered to ensure that agricultural areas are retained in conjunction with the installation of wind turbines due to their economic importance.

• Wind power development may contribute to the mobilisation of contaminants during construction.

5.1.5 Landscape The following table summarises the key issues identified in the regulatory overview and baseline review in regards to landscape. The key environmental issues identified from the Topic Paper 5 and from the additional data review are also presented:

Table 18 – Landscape Policy Context, Baseline Review and Environmental Issues

Policy Context

• Spatial Planning Act (promulgated SG No 1/02.01.2001, last amended SG, issue 15/23.02.2010) - Aims to compile spatial plans considering the protection of natural and historical sights and immovable cultural monuments.

• Protected Areas Act (PAA) (promulgated SG No 133/ 01.11.1998, last amended SG No 103/ 29.12.2009) - Its main objectives are:

- To regulate Protected Areas in terms of their purpose, protection and use regime, designation and management (art. 1).

- To set up a system ensure that functioning of a system of protected areas as part of the regional and world network of similar areas, in line with the international treaties for protection of the environment, for which the Republic of Bulgaria is a Party (art.3).

According to the PAA, the following categories of protected areas exist in Bulgaria:

1. Reserves - all human activities are forbidden within the Reserves, except guarding, scientific studies, passing of people along marked paths, collecting of seeds, wild plants and animals for scientific studies.

2. National parks - construction activities, production activities, clear cutting, use of fertilizers and other chemicals, introduction of non-native species, collecting of herbs, berries and other plants at certain places are forbidden within national partks.

3. Managed reserves - all human activities are forbidden in the Managed reserves, except the activities allowed in the reserves, as well as maintaining, directing, regulatory and restoration activities.

4. Protected area - activities that contradict the requirements for the conservation of the elements which are subject of protection are forbidden in the Protected areas.

5. Natural monuments - activities that could deteriorate the natural condition of the


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Natural monuments and can diminish their aesthetic value are forbidden with Natural monuments.

6. Nature parks - the protection regimes of natura parks are less strict compared to National park. For example, it is possible to have settlements within the boundaries of a Nature park. Article 31 of the PAA outlines the activities that are forbidden within the Nature parks.

• Biodiversity Act (BA) (promulgated SG No 77/09.08.2002, last amended SG No 103/29.12.2009) - Aims to preserve representative for Bulgaria and Europe types of natural habitats and habitats of endangered, rear end endemic floral, animal and fungi species within the National environment network.

• Environmental Protection Act (promulgated SG No. 91/ 25.09.2002, last amended March 2010 (amendment in progress)) - Outlines the general principles of environment protection in Bulgaria and provides the framework for the control of environmental conditions and the supervision over activities which may harm the environment.

• Black Sea Costal Area Development Act (promulgated SG No 48/15.06.2007, last amended SG No 92/20.10.2009) – Aims to recover and protect the natural landscape and cultural and historical heritage of the Sea Coast.

Baseline Review

• Approximately 10% of total land area in Bulgaria is protected.

• The 2006 Annual State of Environment Report identifies a total of 881 protected areas, covering a total area of 546,785.3 ha.

• Forests cover the central band of Bulgaria as well as the northwest. The south of the country is characterised by non-irrigated arable land. 51.6% of the country is covered by agricultural land, 42.4% is covered by forest and semi natural areas and 4.9% by anthropogenic objects, such as cities and industrial installations.

• Classes of permanent land cover in Bulgaria have been identified.


• Studies on impact of wind turbines on landscapes have been reviewed.


• Visual impacts of wind turbines in or nearby protected areas.

• The construction of the necessary electrical infrastructure, the substations as well as the transport lines may impact the landscape especially in the case of wind farms installed in secluded areas.

• Protected areas in Bulgaria can be in direct conflict with wind power development.

• The topography of Bulgaria can determine the visibility and suitability of areas for wind power development.

5.1.6 Public Health, Noise and Vibration The following table summarises the key issues identified in the regulatory overview and baseline review in regards to public health, noise and vibration. The key environmental issues identified from the Topic Paper 6 and from the additional data review are also presented:


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Table 19 – Public Health, Noise and Vibration Policy Context, Baseline Review and Environmental Issues

Policy Context

• Health Act (Promulgated SG 70/10.08.2004, last amended SG 101/18.12.2009) -Regulates the social relations concerning the protection of the citizens' health.

• National Health Strategy for the period 2008-2013 (promulgated in SG No 107/16.12.2008) - Aims to integrate health care for the Bulgarian citizens in all policies - foreign policy, national security policy, policy for financial stability, policy of social solidarity and justice, environmental protection policy, policy in the field of education and science, policy for disasters and emergencies etc.

• Health Insurance Act (promulgated in SG No 70/18.06.1998, last amended SG No 19/09.03.2010) - Aims to guarantee the insured persons free access to medical care by means of a package of health-care activities of a specific type, scope and amount, as well as a free choice of a provider of such care, who or which has concluded a contract with a Regional Health Insurance Fund.

• Guidelines for Community Noise (WHO, 2009) - Derive guidelines for community noise aims to consolidate actual scientific knowledge on the health impacts of community noise and to provide guidance to environmental health authorities and professional that have the responsibility to protect people from the harmful effects of noise in non-industrial environments.

• Protection from Environmental Noise Act (promulgated in SG No 74/13.09.2005, last amended SG No 41/02.06.2009) - Sets requirements and procedures for the monitoring, assessment and control of environmental noise, from transport, industrial and local sources.

• Regulation No 6/26.06,2006 on environmental indicators in the environment - Sets the mandated threshold limits for environmental noise during different times (during the day, evening and night) and also sets the methodology for assessing noise levels, taking into account various locations where the noise is measured, and the diverse noise sources.

Baseline Review

• Average health-adjusted life expectancy (HALE) for males was 63 years compared to 67 years for women in 2002.

• Mortality rates reflect health conditions affecting the population which are associated with unhealthy lifestyles, unbalanced nutritional patterns, increasing rates of smoking and alcohol consumption, risky sexual behaviour, psychosocial stress and low levels of physical activity.

• In 2006 Bulgaria had 270 hospitals with 43 645 beds.

• The main noise sources resulting from wind power implementation (blade tips, the trailing edge of the outer part of the blade, the gearbox and generator) are elevated, and so are not screened by topography or obstacles. Larger parts of the wind energy developments in Bulgaria are located in plains, plateaus, or hilly land at an altitude less than 600 m.

• Limited data regarding measured environmental noise levels is available.


• Spatial location of the boundaries of settlements has been identified.

• Studies on the optimal distances to settlements to minimize noise and flicker effect impacts


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have been reviewed.


• Noise emissions which may disturb local communities, particularly in rural areas where background noise levels can be very low.

• Noise caused by interaction of the turbine blades with the wind may affect citizens’ well-being and local communities’ public health.

• Shadow flicker effect.

5.1.7 Socio-Economic and Material Assets The following table summarises the main regulatory overview and baseline review on Socio Economic and Material Assets. The key environmental issues identified from the Topic Paper 7 and from the additional data review are also presented:

Table 20 – Socio-Economic and Material Assets Policy Context, Baseline Review and Environmental Issues

Policy Context

• Energy Act (promulgated SG No. 107/09.12.2003, last amended SG No. 103/29.12.2009) - Sets the rules for the generation, import, export, transmission, transit transmission and distribution of electrical and heat energy and natural gas, the transportation of petrol and petroleum products via pipelines, and the trade of electrical and heat power and natural gas, and defines competencies of the State authorities for the creation, regulation and control of the energy policy.

• Regulation 8 from 09.06.2004 on the conditions and rules for the operation of the electricity transmission system and electricity distribution network - Regulates the economic relationship between energy producers, transmission companies and energy end users, placing specific requirements on the operator of the national electricity system operator (ESO) and operators of the distribution networks and their personnel.

• Regulation 14 on the technical rules and norms for design, construction and operation of facilities for the production, transformation, transmission and distribution of electric power (last amended SG No. 73/05.09.2006) - Defines requirements and procedures for the design, construction and operation of facilities for the production, transformation, transmission and distribution of electric power. Not applicable targets.

• Road Act (promulgated SG No. 26/29.03.2000, last amended SG No. 93/24.11.2009) - Defines the issues related to the ownership, maintenance, repair and financing of the road infrastructure in Bulgaria.

• Regulation 1 for the Design of Roads (promulgated in SG No. 47/ 09.06.2000, last amended SG No. 102/ 20.12.2005) - Sets the requirements for clearing of land prior to road construction, as well as the technical specification for the paving and construction works. Not applicable targets.

• Regulation 39 on construction in forests and lands belonging to the national forest fund (promulgated SG No. 38/ 09.05.2006) - Sets the requirements and procedures for the construction of roads in the national forest fund lands. The forest fund lands comprise a great proportion of uncultivated, non-urbanized, and not otherwise protected territories in Bulgaria.

• Tourism Act (promulgated SG No 28/01.04.2002, last amended in SG, issue


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15/23.02.2010- Sets conditions for the development of tourism as a priority branch. It controls tourist activities, by determining rights and obligations associated to the tourism and defining unified criteria for the practices of tourism, and provides protection for tourists.

• National Strategy for the Sustainable Development of Tourism for the period 2009-2013 - Defines the trends and expectations for tourism development in Bulgaria, and sets a national policy in line with the desire to develop a differentiated and sustainable tourist product.

Baseline Review

• Population of Bulgaria is subject to negative growth rates and a steady process of ageing.

• At the end of 2008, population in Bulgaria was of 7.606.551 persons, of which 71.1% were living in urban areas, whereas the remaining 28.9% occupy rural areas.

• Bulgaria's agriculture, industry, and services sectors account for 4.6%, 28.7%, and 66.7% of its GDP, respectively.

• The country's dominant industries are mining and energy. Bulgaria's most abundant natural resources like copper (Central-Balkan region) lead and zinc (Southern Rodopa mountain region), and coal (Balkan Mountains and the Maritsa river basin) are its main exports.

• Primary industries include the processing of food, beverages, and tobacco, machinery and equipment, base metals, chemical products, coke, refined petroleum, and nuclear fuel. Bulgaria also produces electrical components and computers.

• Bulgaria has around 3.239,000 hectares arable agricultural land, which constitutes 60,8% of the used agricultural area and 30% of the total area of Bulgaria.

• Topographical data regarding the distribution of agricultural and forest areas in Bulgaria is available as well as an agricultural land characterization.

• Bulgaria's services sector is mainly comprised of financial services and tourism. The effects of wind power development on tourism and recreation in Bulgaria have not been assessed.

• Power transmission lines in Bulgaria are owned by Natsionalna Elektricheska Kompania (NEK) EAD. Investments have been conducted in the recent years for the construction, rehabilitation and modernization of power lines and substations in Bulgaria. Some of these upgrades are on –going.

• Bulgaria's transportation infrastructure includes railroads, with 3,979 kilometres (2,472 miles) of track in use, and about 36,724 kilometres (22,819 miles) of paved roads.

• Bulgaria has many highway projects under construction, notably portions of the Trans-European motor-way connecting Budapest (Hungary) with Athens (Greece) via Sofia, and with Istanbul (Turkey), via eastern Bulgaria. European funding, international investors and the State budget are the main sources for financing road network improvements.

• The development of wind farms in remote areas increases accessibility through the development of tracks and roads, thus promoting economic development.


• Studies on impact of wind turbines on property values, employment, regional GDP, other sectors of the economy, electromagnetic interferences and the development of infrastructure, have been reviewed.


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• Potential effect on property values of developed area and adjacent properties. • Effects on local economy and employment. • Potential effects on tourism and recreation. • Electromagnetic interference with signals relevant to human activities. • Effects on wind power infrastructure. • Effects on the electricity transmission infrastructure. • Effects on road infrastructure.

5.2 SER Objectives and Indicators The review of wind power development is assessed against the SER objectives and indicators within the SER framework in order to identify potential impacts. Although the use of SEA Objectives is not a requirement of the SEA Directive, their use is a recognised good practice method of assessing the effects on a strategic level. Consequently, the SER has adopted this approach. SER objectives are expressed in the form of targets, the achievement of which is measurable using indicators. Due to the strategic nature of the SER, the selected objectives are supported by receptors/indicators, which are used to determine performance of an alternative or policy against the objective.

The SER objectives were included in the Scoping Report and were derived using the information gathered within the Topic Papers, including: the review of environmental policies, plans and programmes, the baseline review and the identification of environmental issues. The SER objectives are thus based on a review of all major issues, and each SER objective is supported by at least one indicator which is intended to provide more explicit explanation of how the development of wind power will be appraised against the SER objectives.

The selected indicators were not always measurable, since the project is being conducted at a strategic level. However, indicators can also be used to point directions and to provide information on how the development of wind power will impact the environment. In essence, indicators can be used to define relative performance rather than absolute performance. Several of the selected indicators can also be used as benchmark values, to show how the development of wind power is currently helping to achieve a certain objective (e.g. Bulgaria RES obligations).

Finally, the identification of these indicators can form the basis of a monitoring programme which could be developed to monitor the implementation of wind power in Bulgaria.

Table 21 presents the SER assessment framework which contains specific objectives and indicators.

Table 21: SER Assessment Framework

SER Topic Obj. Ref.

SER Objective. Will the development of wind power

generation in Bulgaria … SER receptor/indicator

Energy, Climate and Air Quality

1.1 Reduce the growing dependence on energy imports within Bulgaria.

1.1.1. Percentage of wind energy production from gross inland energy consumption and benchmark with EU countries.

1.2 Support compliance with the 1.2.1. Contribution to the compliance


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SER Topic Obj. Ref.



Bulgarian national targets for % of energy from RS in the gross final energy consumption.

with 2010 Bulgarian RES targets (11% share of energy from RS in the gross inland electricity consumption) and 2020 (16% share of energy from RS in the gross final energy consumption).

1.3

Reduce the overall emissions of greenhouse gases associated with energy generation and support compliance with the Bulgarian greenhouse gas emission targets.

1.3.1. Contribution to the compliance with the 2012 Bulgarian GHG emission targets (8% reduction from 1988 levels) and 2020 (20% increase from the 2005 levels).

1.4

Reduce the overall emissions of air quality pollutants associated with energy generation and support compliance with the air quality pollutants targets.

1.4.1. Contribution to the compliance with the 2010 and 2015 air emission reduction targets for SO2, NOx, PM and Hg (set by the National Environmental Strategy 2009-2018).

Cultural Heritage 2.1

Reduce the risk of potential impact on the boundaries of the Bulgarian and World Cultural Heritage Properties.

2.1.1. Avoid direct and minimise visual impacts on Bulgarian World and National Cultural Heritage properties.

Flora, Fauna and

Biodiversity 3.1

Reduce the risk of potential impact on threatened and migratory birds and bats.

3.1.1. Avoid impacts on migration bottleneck sites of globally and EU protected bird species (more than 5000 storks and pelicans or more than 3000 raptors).

3.1.2. Avoid impacts on roosting sites of globally and EU protected bird species.

3.1.3. Avoid impacts on staging areas and flying corridors of globally and EU protected raptors and vultures.

3.1.4. Avoid impacts on staging and feeding areas of globally and EU protected wintering geese, swans and ducks.

3.1.5. Avoid impacts on wetlands with waterfowl concentrations and waterfowl colonies (regardless of season).

3.1.6. Avoid impacts on breeding and feeding areas of globally and EU protected raptors and vultures.

3.1.7. Avoid impacts on areas of


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SER Topic Obj. Ref.



reintroduction of globally and EU protected bird species.

3.1.8. Avoid impacts on Important Bird Areas.

3.1.9. Avoid impacts on areas around the boundaries of protected territories, specifically designated for bird protection.

3.1.10. Avoid impacts on breeding and feeding areas, and migratory routes for bats.

3.1.11. Consider the variations in the behaviour of different bat and bird species towards wind turbines.

3.2 Reduce the risk of potential impact on flora and fauna.

3.2.1. Minimise the impacts on bottleneck sites for migration of large carnivores outside of NATURA 2000 sites.

3.2.2. Minimise the impacts on threatened plant species.

3.3

Reduce the risk of potential impact on Protected territories (under the Bulgarian Protected Territories Act).

3.3.1. Avoid impacts on protected territories.

3.4 Reduce the risk of potential impact on NATURA 2000 sites.

3.4.1 Avoid impacts on NATURA 2000 SPA sites.

3.4.2. Avoid impacts on NATURA 2000 SCI sites.

3.4.3. Avoid significant deterioration on all habitats in Annex 1 of the Habitat Directive in NATURA 2000 sites.

3.4.4. Avoid significant deterioration of all habitats of the species included in Annex II of the Habitat Directive inside NATURA 2000.

3.4.5. Avoid disturbance of species under Annex II of the Habitat Directive inside NATURA 2000 - large carnivores.

3.5 Reduce the risk of potential impact on forests.

3.5.1. Minimise the impacts on high conservation value forests (HCVF).

3.5.2. Minimise the impacts on forests


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SER Topic Obj. Ref.



with special designation.

3.5.3. Minimise the impacts on forested areas.

Soil and Water

4.1 Reduce the risk of potential contribution to soil erosion.

4.1.1. Minimise the contribution to soil erosion.

4.2 Reduce the risk of potential mobilization of anthropogenic contaminants during construction.

4.2.1. Minimise the mobilization of anthropogenic contaminants during construction.

4.3 Protect soil resources with significant economic value.

4.3.1. Minimise the area of soil resources with significant economic value which land use has been changed as a result of wind power development (ha).

4.4 Reduce the risk of potential impact on surface water and/or groundwater quality.

4.4.1 Minimise the impacts on water quality of surface water bodies.

4.4.2 Minimise the impacts on water quality of groundwater water bodies.

Landscape35

5.1 Reduce the risk of potential negative landscape transformation.

5.1.1 Minimise the impact on land use and land use change.

5.1.2 Minimise the impacts on landscape sensitivity, vulnerability and resistance of landscape units.

5.2 Reduce the risk of potential impact on visual value of landscape.

5.2.1. Distance of wind power developments to protected zones, protected territories, tourist areas and recreation areas.

5.2.2 Minimise the loss of aesthetic values.

Public Health,

Noise and Vibration

6.1

Reduce the risk of potential impact from noise caused by the interaction of the turbine blades with the wind.

6.1.1. Minimum distance of wind power developments from settlements.

6.2 Reduce the risk of potential impact on public health due to shadow flicker effect.

6.2.1. Minimum distance and orientation of wind power developments in relation to settlements.

35 The landscape objectives and indicators have been provided by Ms. Svetla Bratanova from the Central Laboratory for General Ecology at the Bulgarian Academy of Sciences (BAS)


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SER Topic Obj. Ref.



Socio-Economic

and Material Assets

7.1 Reduce the effect on property values of developed area and adjacent properties.

7.1.1. Real estate values in areas affected by wind power development prior to and after the implementation of wind projects.

7.2 Attain positive contribution towards employment and secondary economy.

7.2.1. Impact of wind power development on employment.

7.2.2. Impact of wind power development on regional GDP.

7.3

Reduce the risk of potential impact on other sectors (conventional tourism, hunting, eco-tourism, etc.).

7.3.1. Coordination of wind power investment projects with existing economic regional development plans.

7.4 Reduce the risk of electromagnetic interferences with signals relevant to human activities.

7.4.1. Electromagnetic interference levels prior to and after implementation of wind projects.

7.5 Contribute to the development of power transmission and road infrastructure.

7.5.1. Length of power transmission and road infrastructure subject to construction, rehabilitation or modernization associated with wind-energy projects.


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6 Results of the Assessment 6.1 Approach to the SER assessment The methodology for the assessment of wind power development against the SER objectives and indicators is presented in section 5.2. The assessment is presented as an evidence based discussion citing peer reviewed information and other literature, and draws on the perspectives of the identified stakeholders (regulators, local authorities, investors in wind power, NGOs, academics, etc.). This information has principally been obtained through the consultation process.

As part of the assessment, the implications of the current development of wind power in Bulgaria for relevant existing environmental and social issues and constraints have been identified and evaluated. The overall approach focuses mostly on assessing constraints, sensitivities and risks, and where possible, assessing the potential impacts. Due to the scope of the project (including the entire country of Bulgaria), a detailed analysis of the characteristics of specific impacts was not undertaken. Where it has not been possible to quantify an impact, a qualitative assessment has been performed. This approach is consistent with the ‘good international practice’ in SEA and complies with the requirements of the SEA Directive.

The results of the assessment, performed in accordance with the criteria discussed in Section 3.3.2, are presented for each environmental topic in matrix format in Appendix B. Summaries of these results are addressed, by topic, in the following sections.

6.1.1 Energy, Climate and Air quality Overall, the promotion of wind power projects in Bulgaria is likely to lead to significant positive effects on the identified energy, climate and air quality aspects. The level of significance of the effects varies for each SER objective. Because of the common EU requirements and targets for energy independence, energy from renewable sources, greenhouse gas emissions and air quality, the effects on these SER objectives have explicit implication, not only at the national level but also at European scale.

The following table summarizes the assessment for Energy, Climate and Air Quality SER Objectives:

Table 22: SER Objective Appraisal Summary - Energy, Climate and Air Quality

SER Objective Objective performance

Scoring Objective Significance

Characteristics Probability Total

1.1 Reduce the growing dependence on energy imports within Bulgaria.

3 5 15

1.2 Support compliance with the Bulgarian national targets for % of energy from RS in the gross final energy consumption.

5 5 25

1.3 Reduce the overall emissions of greenhouse gases associated with energy generation and support

3 5 15


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SER Objective 1.1 Reduce the growing dependence on energy imports within Bulgaria

Bulgaria obtains over 70 % of its total primary energy resources from imports, although the statistical indicator for energy dependency is considerably lower – 51,7%, due to the methodology used by Eurostat, which recognizes nuclear energy as a local source. A decreased dependence on energy imports would increase the country´s control on the supply of a vital resource for the Bulgarian economy such as energy resources. In 2009, the contribution of wind power represented approximately 6,4% to the electricity generated from RES, 0,6% of the gross inland electricity consumption and about 0.1% of the gross energy consumption. Based on the information about the installed and planned capacities of wind power (for more information refer to Section 2.3), it is expected that in the near future wind power may contribute as much as 13 % to the gross inland electricity consumption and about 2% of the gross energy consumption. Therefore, while the development of wind power will clearly play a role towards improving the energy independence of Bulgaria, its contribution, is in comparison to other energy sources, is assessed as modest. Nevertheless, the probability of this effect to occur is high and therefore as a result the assigned significance level is major positive.

SER Objective 1.2 Support compliance with the Bulgarian national targets for % of energy from RS in the gross final energy consumption

As discussed above, while in 2009, the contribution of wind power represented only 0,6 % of the gross inland electricity consumption and about 0,1% of the gross energy consumption, it is expected that in the near future these numbers may rise to 13% and 2% respectively. These numbers, combined with the high certainly of the positive effect, lead to the conclusion that the contribution of wind power to the achievement of SER Objective 1.2 is major positive.

SER Objective 1.3 Reduce the overall emissions of greenhouse gases associated with energy generation and support compliance with the Bulgarian greenhouse gas emission targets

During their operation, wind turbines do not generate any greenhouse gas emissions. Even though the contribution of wind energy to the overall energy consumption in Bulgaria is still small, wind energy contributes to the reduction of the greenhouse gas emissions from the electricity generation sector. However, greenhouse gas emissions are generated not only by the electricity producing facilities but also by the transportation sector, the agriculture sector, by particular industrial processes, etc. In 2007, the whole energy generating sector produced 43% of the total GHG emission in Bulgaria (32 795KtCO2e from 75 793KtCO2e)36, which includes GHG emissions for electricity generation and for thermal energy generation. Thus, while wind energy contributes to the achievement of national targets set by the Kyoto protocol and the EU directive 2009/28/EC, its effect is still moderate. Nevertheless the probability of this effect to occur is high and therefore as a result the assigned significance level is major positive.

36 National GHG Inventory Report 2009, EEA

compliance with the Bulgarian greenhouse gas emission targets.

1.4 Reduce the overall emissions of air quality pollutants associated with energy generation and support compliance with the air quality pollutants targets.

3 5 15


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SER Objective 1.4 Reduce the overall emissions of air quality pollutants associated with energy generation and support compliance with the air quality pollutants targets

The generation of electricity by wind energy does not create emissions to air and therefore contributes to the reduction of atmospheric contaminants related to electricity generation. According to a report by the EEA on air quality in Bulgaria, in 2007 combustion installations in industrial facilities (this category includes electricity generating installations) were responsible for 1 % of the overall SO2 emissions, 5% of the NO2 emissions, 3% of the PM10 emissions and 50% of the Hg emissions. If wind energy reaches levels of 13% of the gross inland electricity consumption in Bulgaria (which would be the case if all wind projects for which preliminary contracts have already been signed, are implemented), this will result in minor reductions of SO2, NO2 and PM10 but moderate reductions of Hg. Nevertheless, the probability of this effect to occur is high and therefore, the contribution of wind power to the achievement of SER objective 1.4 has been assessed as major positive.

Assessment of cumulative/ secondary/ synergistic interactions

The effects of wind power development on all indentified energy, climate and air quality SER objectives are likely to have a cumulative positive effect when considered with the effects of the development of the other RES (hydro power, solar power, etc,).

6.1.2 Cultural Heritage All cultural heritage properties inscribed on the World Heritage List have delineated boundaries, buffer zones and protective prescriptions. Information about the seven (7) World Cultural heritage properties in Bulgaria was obtained from the UNESCO website. These sites have been mapped and included in the spatial analysis (Section 7). The national cultural, historical and religious heritage properties, however, could not be mapped because data was not available.

While many of the World Culture Heritage properties in Bulgaria do not have proper management plans, all of them fall within some type of protection – local ordinance, national law, site instructions, etc. which to a large extent ensures their preservation. However, this is not the case with many of the national and regional cultural heritage properties for some of which it is difficult to find even information on the exact location.

The following table summarizes the assessment for Cultural Heritage SER Objectives:

Table 23: SER Objective Appraisal Summary - Cultural Heritage




2.1 Reduce the risk of potential impact on the boundaries of the Bulgarian and World Cultural Heritage Properties

1 3 3

SER Objective 2.1 Reduce the risk of potential impact on the boundaries of the Bulgarian and World Cultural Heritage Properties

Wind power development is only expected to cause significant impacts on cultural heritage properties (with global, national or regional importance) if wind turbines are built on or in the immediate vicinity of these properties. This can easily be avoided if during the Environmental


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Impact Assessment (EIA)37 process the presence of cultural properties is carefully identified. When such properties are found in the vicinity of the area of the planned project, adequate assessment of the potential impacts has to be carried out.

The magnitude of the effects from wind power development on cultural heritage cannot be assessed at the national scale since impacts are likely to be location-specific and currently there is not enough information on the locations of these properties, their status and the occurrence of any past impacts that may have affected them. Particular zones of cultural heritage significance at a national or regional level have not been identified, apart from the World Heritage properties. Therefore, if the EIA process for wind power development is carried out sufficiently with relation to potential impacts on cultural heritage, it should adequately mitigate any potential impacts.


The potential for cumulative effects is unknown at this stage as it depends on the number and sensitivity of the locations developed.

6.1.3 Fauna, Flora and Biodiversity The evaluation of significant effects has shown that one of the main concerns for wind power developments in Bulgaria are related to the protection of fauna, flora and biodiversity. The development of wind power has been evaluated as having major negative effects on these SER Objectives.

The following table summarizes the assessment for Flora, Fauna and Biodiversity SER Objectives;

Table 24: SER Objective Appraisal Summary - Flora, Fauna and Biodiversity




3.1 Reduce the risk of potential impact on threatened and migratory birds and bats.

5 3 15


3 3 9

3.3 Reduce the risk of potential impact on Protected territories (under the Bulgarian Protected Territories Act).

5 3 15


5 3 15


3 3 9

37 An EIA is always considered to be necessary, even though the scope, duration and complexity of the EIA will vary according to the characteristics of the region that is being considered for wind power development. These issues are further discussed in Section 8 of this report.


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SER Objective 3.1 Reduce the risk of potential impact on threatened and migratory birds and bats

Bats

Bulgaria has a uniquely high diversity of bats. Of the 35 species present within continental Europe, 33 species are known to inhabit Bulgaria. Among the reasons for this high diversity are the country’s transitional geographic location, its mosaic of habitats which start at sea level and reach an altitude of over 2 900 m, the continued existence of wild nature in many parts of the country, extensive farming activities in the mountains and semi-mountainous regions, the presence of over 5,900 caves and the high diversity and abundance of insects. The greatest bat diversity can be found in the belt between 100 and 400 m altitude, where relatively small areas are inhabited by 17-20 species.

Impact types on bats

Wind power plants may cause negative impacts on bat populations, as well as on their prey and habitats, such as:

Direct risks Indirect risks

• Direct strike with rotor blades

• Damage, disturbance or destruction of roosts

• Disorientation of bats in flight through emission of ultrasound noise

• Changes on characteristics of the habitat - Damage, disturbance or destruction of foraging habitats and commuting corridors

• Clash with the power-transmission network • Fragmentation of habitat

• Turbulence spin while in flight • Barrier effect

• Noise “pollution” • Cumulative death effect

Bulgaria is the second richest country in Europe in terms of diversity of bird fauna. So far, 420 bird species are recorded in the country, which represents 75% of the European ornithofauna diversity.

There are 288 breeding bird species recorded in Bulgaria, including globally threatened by extinction as identified in Section 5 of this report.

A large part of the bird species occurring in the country are migratory species. One of the two biggest migration routes in Europe, Via Pontica, passes through the eastern part of Bulgaria. This migratory route is up to 100 km wide and millions of waterfowl, birds of prey, quails, rails and passerines migrate every year along it. There are records that more than 620,000 soaring birds (raptors, storks, pelicans and cranes) pass through the country along Via Pontica twice per year, where they also find places to roost and forage during migration. The Struma migration route, also known as Via Aristotelis, is situated in Western Bulgaria along the Struma and Mesta river valleys and is of regional importance for the Balkan Peninsula. The Danube River plays a role as a major migration corridor for waterfowl from the inland part of the Europe to the Black Sea. There are also smaller migration corridors, but none of them has been studied. In general, the migration of soaring birds in Bulgaria is not sufficiently studied except along the Black Sea Coast.


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Twenty nine of the species occurring in Bulgaria are threatened by global extinction, where the global population of several of them are concentrated in Bulgaria. 133 species of those are listed in Annex I of Directive 79/409 are recorded in Bulgaria.

Under protection of the Bern Convention there are 383 species (279 under annex II and 104 under annex III) and under the protection of the Bonn Convention there are 15 species with strict protection and 199 species for which the member states have to sign agreements on conservation of their habitats. Most of these species are also subject of the Afro-Eurasian Waterbird Agreement (AEWA). Detailed information on species was identified in the baseline review as presented in Section 5 of this report.

Of all birds occurring in the country during different seasons, 332 species are under protection of the Biodiversity Act (Annex 3) and for 133 species special measures have to be taken for the conservation of their habitats.

As birds dependent almost entirely on forests there about 47 species are determined, including all species of woodpeckers, Capricallie (Tetrao urogallus), Lesser Spotted Eagle (Aquila pomarina), etc.

Other unique habitats for birds in Bulgaria include: the Burgas wetlands, the coastal flooded forests at the mouths of the rivers of Kamchia, Batova, Ropotamo and Veleka along the Black Sea coast, as well as the riverine flooded forests at the Danube islands.

During the last decade it was confirmed that wind farm development have impacts on certain biodiversity species groups including birds and bats. Poorly sited or designed wind farms may cause a significant threat to certain vulnerable species and habitats. The type and scale of impact very much depends on the affected species, their ecology and conservation status, as well as the location, size and design of the wind farm. Significant negative impacts of wind farms to birds’ are confirmed during all stages of their life cycle – breeding, migration and wintering. Even though the severity of impacts varies significantly from one species to another, all bird species have the potential to be affected by wind farms. The most affected are some breeding raptors, waterfowl and several other species; migratory soaring birds (raptors, storks, pelicans and cranes), as well as waterfowl congregations regardless of the season. Species that are globally threatened by extinction, those that are threatened and have small populations or low reproductive rate are especially vulnerable to wind farm because even when single individuals are affected, this may adversely affect the entire population.

The main types of identified impacts are as follows:

- Collision mortality and risk: Birds may collide with various parts of the wind turbine (rotors, towers, nacelles) or with associated structures such as guy cables, electricity power lines and meteorological masts38. Risks of lethal injury or mortality are mostly thought to be related to collisions with rotors, although results from recent modelling studies also indicate that the hub might be the most dangerous part. There is also evidence of birds being forced to the ground as a result of being drawn into the vortex created by moving rotors39.

The impact of additional mortality due to wind farms on population development varies greatly between species. However, even with relatively small increases in mortality, decreasing trends in population development are having been reported for many species. The largest population declines are shown by species which start breeding when one year old and those that first breed at the age of five40. Recognizing that many wind farms result in only low levels of

38 Kikuchi (2008). Drewitt & Langston (2008). 39 Winkelman 1992b 40 Hotker at al. (2005)


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mortality, even these levels of additional mortality may be significant for long-lived species with low productivity and slow maturation rates, especially when rarer species are affected. In such cases there could be significant effects at the population level (locally, regionally or, in the case of rare and restricted species, nationally), particularly in situations where cumulative mortality takes place as a result of the progressive installation of multiple wind turbines, or due to other human activities.

The studies so far may underestimate the potential impact of wind farms, because the studies are based on the number of actual bird fatalities, however, this does not take into account removal by predators or by wind farm wardens. Additionally it is noted that in some cases injured birds have been found dead as far as 2 km away from the turbines.

International data is indicative of the degree of impact of wind turbines on bird fatalities. It is estimated, for example, that up to 12541 birds collide annually per turbine in Belgium42. Some of the highest levels of mortality for raptors have been reported at Altamont Pass in California43 and at Tarifa and Navarre in Spain44. At Navarre, corrected annual estimates ranging from 3.6 to 64.3 mortalities/turbine were obtained for birds and bats45. A minimum of 75 Golden Eagles are killed annually at Altamont and over 400 Griffon Vultures are estimated (following the application of correction factors) to have collided with turbines at Navarre.

The level of mortality depends very much on site location. Poorly sited wind farms can cause substantial mortalities whereas those that are located away from areas important for birds cause relatively low rates of bird mortality. High collision mortality is recorded in the following cases: in areas where there are large concentrations of birds regardless to the season, but particularly on migration season, where many birds regularly fly between roosting and foraging areas; in areas where birds hunt regularly or take off from their roosting or breeding sites; and in areas where night migrants are attracted by the lights into the wind farm area.

Wind speed and direction, air temperature and humidity, flight type, distance and height, time of day and topography all influence the risk of collision, as do species, age, behaviour and stage of the bird’s annual cycle. However, it is broadly accepted that the risk for collision with wind turbines increases in poor visibility and severe weather conditions46; even though it is confirmed that even in good weather with good visibility some birds such as raptors often collide with turbines. Large birds with poor manoeuvrability47 (such as raptors, swans and geese) are generally at greater risk of collision with structures48 and species that habitually fly at dawn and dusk or at night are perhaps less likely to detect and avoid turbines49. Soaring flights with wind force 4.6-8.5 m/s and crossing flights, when starting below the blade height, are the type of flight

41 Kikuchi (2008). Drewitt & Langston (2008). 42 Winkelman 1992b 43 Hotker at al. (2005) 44 Killed birds annually by 1 turbine in Spain: 4 (Алайз, Spain), 8 (Гуеринда, Spain), 26 (Изко, Spain), 64 (Ел Пердон, Spain), Howell & DiDonato 1991, Orloff & Flannery 1992, Drewitt and Langston (2006) 45 Hunt et al. (1999), Hunt (2001) 46 Collision risk is greatest in poor flying conditions, such as strong winds that affect the birds’ ability to control flight manoeuvres, or in rain, fog, and on dark nights when visibility is reduced. In these conditions, the flight height of migrating birds tends to be greatly reduced. Lighting of turbines has the potential to attract birds, especially in bad weather, thereby potentially increasing the risk of collision. 47 In Tarifa only in 2% of total recorded flights (3832, 15% of which lead to risk situation), the vultures clearly changed their flights when approaching turbines 48 Brown et al. (1992) 49 Larsen & Clausen 2002


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that have a higher Collision Risk Rate50. The available data indicates that the higher mortality might be associated with the larger turbines51.

- Disturbance and distancing: The displacement of birds from areas within and surrounding wind farms due to visual intrusion and disturbance can amount effectively to habitat loss. Displacement may occur during both the construction and operational phases of wind farms, and may be caused by the presence of the turbines themselves through visual, noise and vibration impacts, or as a result of vehicle and personnel movements related to site maintenance. The scale and degree of disturbance determines the significance of the impact, as does the availability and quality of other suitable habitats nearby that can accommodate the displaced birds. Behavioural responses vary not only between different species, but between individuals of the same species, depending on such factors as seasonal and diurnal behaviour patterns of the birds, stage of life cycle (wintering, moulting, and breeding), flock size and degree of habituation. The displacement effect occurs mostly in areas where birds spend significant time during their annual cycle – breeding and staging areas, but not so typical for migrants which use the area annually but during a very short time. Displacement is confirmed for many staging waterfowl, especially geese and ducks, which avoid areas taken by wind farms in a distance up to 800m52. Displacement is confirmed also for breeding raptors, where Golden Eagle avoids the entire area of a wind farm placed within its hunting territory53. A recent systematic review of the effects of wind turbines on bird abundance has shown that with increasing time of operation greater declines in bird abundance occur (Stewart et al. 2004). This evidence that impacts are likely to persist or worsen with time suggests that habituation is unlikely, at least in some cases. When birds habituate to wind farms and the avoidance of turbines decreases, the risk of collision increases because birds fly more often between the turbines.

- Barrier effect. The effect of birds altering their migration flyways or local flight paths to avoid a wind farm is also a form of displacement. This effect is of concern because of the possibility of increased energy expenditure when birds have to fly further, as a result of avoiding a large array of turbines, and the potential disruption of linkages between distant feeding, roosting, moulting and breeding areas otherwise unaffected by the wind farm. The effect depends on species, type of bird movement, flight height, distance to turbines, the layout and operational status of turbines, time of day and wind force and direction, and can be highly variable, ranging from a slight ‘check’ in flight direction, height or speed to significant diversions which may reduce the numbers of birds using areas beyond the wind farm. The cumulative effects of large wind farm installations may be considerable if bird movements are consequently displaced. There are circumstances where the barrier effect might lead indirectly to population level impacts; for example where a wind farm effectively blocks a regularly used flight line between nesting and foraging areas, or where several wind farms interact cumulatively to create an extensive barrier which could lead to diversions of many tens of kilometres, thereby incurring increased energy costs.

- Habitat loss or degradation. The scale of direct habitat loss resulting from constructing a wind farm and associated infrastructures depends on the size, location and design of the project. The effects may be more widespread where developments interfere with hydrological patterns or geomorphological processes. The significance of loss depends on

50 Marti, Barrios (1995) 51 Johnson, G. (2002) 52 Winkelman, 1989, 1992a; Kruckenberg, Jaene, 1999; Percival 2003; Drewitt and Langston, 2006; Pearce-Higgins et al. in prep 53 Walker et al. 2005


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the rarity and vulnerability of the habitats affected (e.g. marshes, wet meadows or sand dunes) and/or of their importance as a feeding, breeding or roosting/moulting place for species, especially for species of European conservation concern. Also, the potential role of some habitats as components in corridors or stepping stones important for dispersal and migration, as well as for more local movements between e.g. feeding and nesting sites, has to be taken into account.

Impacts on birds during migration and staging

Birds that migrate annually for long distances as natural part of their life cycle are the group of birds that are most vulnerable to wind farm development and operation. If wind farms are located on their migratory routes, there is a considerable risk of collision, barrier effect and habitat loss. The highest mortality rates are reported at sites with high concentration of birds, especially migratory birds – raptors and other soaring birds (storks, pelicans, cranes), as for example in the Altmont Pass in USA, as well as in Tarifa and Navarra in Spain.

The collision risk is higher when: birds fly in dense flocks close to the rotors, where they change their behaviour, loose orientation, loose more energy which decreases their survival rate; roosting birds take off from roosts or alight there; birds fly at low height before finding thermals; birds gain height or reach land after they have flown above a water basin; and nocturnal migrants are attracted by the lighted wind turbines into the wind farm area. The mortality rate increases when birds are disturbed, including external reasons (e.g. power line) or due to strong winds, rains and fogs, which force birds to descend to a lower altitude or land. The collision risk for soaring birds does not decrease even in good weather conditions. The highest collision risk for soaring birds appears at the edges of mountain plateaus, close to wetlands or along a sea coastline, at mountain passes and mountain ridges, where the soaring birds prefer to fly.

The wind farms are barrier for migratory and non-breeding birds. Birds try to avoid wind turbines designed in groups, where they try to go round them instead to pass through them45. If birds pass the turbines at a distance of lessl than 100m, the risk of collision is 75% even if birds try to avoid the turbine. An increase in the number of wind turbines creates larger-scale barrier at the migratory routes/movement corridors that in certain cases cannot be avoided by the birds. Thus, birds are forced to fly between the turbines where the collision risk is much higher.

Similar effects are observed at staging areas when wind farms are located on the movement corridors between roosting and feeding areas. Waterfowl are especially sensitive to wind farms at their staging areas. For example avoidance behaviour by European white-fronted geese (Anser albifrons) was observed in response to the Rheiderland wind farm in Germany54. In a study, conducted before and after the construction of a wind farm, on the wind farm site and a reference area, substantially lower densities of feeding geese were found within 600m of the wind turbines. Studies at Urk, The Netherlands55, found decreases in population density within the wind farm area in winter. The affected area extended to 300m away from the wind farm.

Impacts on waterfowl, including waterfowl congregations and colonies

Numerous studies confirm that waterfowl are very vulnerable to wind farms situated in close distance to wetlands. These impacts are related to loss of habitats, displacement, strong barrier effect and mortality caused by collision with turbines.

Outside of the breeding season, the waterfowl (hooper swan, geese, ducks, etc.) avoid using foraging and roosting areas, including habitats which are otherwise suitable, in a distance of up

54 Kruckenberg & Jaene 1999 55 Winkelman (1989)


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to 800 m from wind turbines56. Increasing the number of turbines causes significant “effective” habitat loss because of the cumulative impact. It is confirmed that geese do not use areas between turbines, designed in groups (clusters) regardless if they are in lines or dispersed randomly57. The scale of the impact could be increased if there are not enough suitable habitats for the species in the neighbouring areas. Breeding water birds avoid using habitats in a distance up to 300 m from wind turbines58.

The collision risk increases where there are: regular movements associated with migration (every autumn or spring); occurrence of thermals for gaining height; regular wintering grounds; regular staging areas where birds congregate in huge numbers; daily foraging movements of birds between roosting and foraging sites; or regular foraging/hunting areas.

Impacts on breeding birds

The wind farms could cause mortality, disturbance, displacement, barrier effect and habitat loss to breeding birds. Construction of wind farms in close proximity to the nesting or feeding areas of birds could cause significant disturbance and chasing away of birds. As a result, an habitat loss could be observed. The disturbance during the operation of wind farms is related to direct visual impact, noise, vibrations, and electromagnetic waves from the wind farms59/45. Increasing the number of turbines causes significant “effective” habitat loss because of the cumulative impact. The scale of the impact may increase if there are not enough suitable habitats for species in neighbouring areas. The noise and the movement of turbines can cause a decrease in the breeding success, increase of mortality rates and change in the population structure. The noise repulses birds and they avoid using surrounding habitats60. Disturbance (visual and noise) may displace birds into less suitable habitats and this may reduce their ability to survive and reproduce (i.e. an indirect form of habitat loss through perceived predation risk)61. If not physically displaced, birds’ foraging success may be impaired and other important life history behaviours disrupted (i.e. a form of habitat degradation)62. Alternatively, birds that are not displaced have a risk of collision with rotating rotor blades63. There is little evidence suggesting that fewer but bigger in size and power wind turbines cause less risk to birds.

Some species are exposed to higher risk, because they are less sensitive to the noise and visual impact of the wind turbines and fly directly through the rotor blades. Raptors in general have a low rate of avoidance of wind turbines. The mortality risk is higher for young birds of prey (eagles, vultures). The large raptors have a relatively low manoeuvring capacity. The long lived raptors with low reproduction rate (vultures, eagles) are the most affected by wind turbines because even single cases of mortality could cause adverse impact of the size and structure of their population, especially if they are already threatened by extinction. The most vulnerable species to wind farms is the Griffon Vulture (Gyps fulvus). Only in Spain, it is estimated that about 400 birds die due to collision with wind turbines annually (Drewitt, Langston, 2006). The Egyptian Vulture (Neophron percnopterus) and the Black Vulture (Aegypius monachus) are affected in a similar way.

56 Winkelman, 1989, 1992a; Kruckenberg, Jaene, 1999; Percival 2003; Drewitt and Langston, 2006; Pearce-Higgins et al. in prep 57 Larsen, Madsen, 2000 58 Percival 2003 59 Petersen & Malm (2006), Meissner & Sordyl (2006) 60 BirdLife International 2003, Kingsley & Whittam 2001, Percival 2003, Rugge et al 2003, Thomas 1999, Tingley 2003 61 Frid & Dill 2002 62 F. Bergen pers. comm. 63 Erickson et al. 2001


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Among the eagles, existing information indicates that the most affected by wind farms are the Golden Eagle (Aquila chrysaetos), the Imperial Eagle (Aquila heliaca) and the White-tailed Eagle (Haliaeetus albicilla). At Altmont Pass, USA, tens of Golden Eagles die annually due to collision with wind turbines. At Smola Island, Norway White-tailed eagles (Haliaeetus albicilla) die regularly because collisions with wind turbines and the reproduction rate of some pairs is zero because of the disturbance caused by the wind farm. Other breeding raptor species are also confirmed to be vulnerable to wind farms and to collide with the turbines quite often – Black Kite (Milvus migrans), Lesser Kestrel (Falco naumanni), Peregrine Falcon (Falco peregrinus), Booted Eagle (Hieraaetus pennatus), Short-toed Eagle (Circaetus gallicus), buzzards, harriers, etc.

Other breeding birds are also identified as highly sensitive to wind farms as the Corncrake (Crex crex), Capercallie (Tetrao urogallus), Eagle Owl (Bubo bubo), Black Stork (Coconia nigra), waders and many song birds.

Studies on waders and passerines showed relatively low impact on breeding birds caused by wind turbines. For example, disturbance effect is not found for the Eurasian oystercatcher (Haematopus ostralegus), Northern lapwing (Vanellus vanellus), Black-tailed godwit (Limosa limosa) or Common redshank (Tringa totanus)64. These are all long-lived and highly site-faithful species and thus their attachment to a location may outweigh any potential response to change. On the other hand, shorter-lived species with a more rapid turnover of individuals or species that are less site-faithful may display different responses to change, and consequently settlement patterns. Studies at Buffalo Ridge, Minnesota, USA65 found increased densities of breeding grassland passerines with increased distance from wind turbines in the wind farm area, and higher densities in the reference areas than within 80m of the wind turbines. They did not find an effect of operational versus non-operational turbines, indicating that the presence of turbines had some deterrent effect, although it is unknown whether the effect was long-lasting.

The available evidence suggests that poorly sited wind farms have already caused bird casualties in Bulgaria.

Appendix F of this report provides additional information on the main directions for investigating the behaviour of birds and bats, as a risk indicator at operational wind farms and future wind projects. This document was prepared by Dr. V. Delov and includes suggestions as to the approach that can be applied to these types of investigations.

In order to mitigate potential effects from new wind power development, wind farms need to be located preferentially away from major migration routes and important feeding, breeding and roosting areas of those bird species known or suspected to be at risk. The spatial distribution of potential effects are strongly related to the distribution and relative sensitivities of individual bird species.

SER Objective 3.2 Reduce the risk of potential impact on fauna and flora

Bulgaria’s biota ranks among the most species-rich in Europe, especially relative to the country’s size. According to the 2006 Annual State of Environment report, 175 plants are protected in Bulgaria. There are around 3,600 species of higher plants in Bulgaria, of which 763 are included in the Red Data Book of Bulgaria (1984). According to the degree of endangerment, plants are classified into three categories: extinct (31 species), endangered (158 species), and rare (574 species). The Book also includes 124 endemic for Bulgaria plant species, 105 endemic for the Balkans plant species and numerous relict species.

64 Winkelman (1992d) 65 Leddy et al. 1999


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Bulgaria is characterized by a large diversity of plant and animal communities, which include examples of most main types of habitats and biotopes known in Europe. In addition to commercial species (including timber trees, Black Sea and fresh water fish species, more than 200 edible mushroom species and scores of local medicinal plants), Bulgaria is the motherland of many traditional and rare cultivators and breeds, and many wild relatives of domesticated species.

The diversity of animal species in Bulgaria ranks among the highest in Europe. The unusually high diversity of animals also attains international significance.

Impacts from wind farm development are Likely to impact more on fauna than on flora.

In the case of flora, significant impacts can occur in the event that deforestation and changing of agricultural land patterns occurs as part of the wind development. Additionally, it is noted that even though the foundation of each wind turbine is in between 64 and 225 m2 (depending on the turbine type); during the construction of the turbine a larger area is affected by the construction equipment. If protected plants or habitats are present at the development site, they may be damaged and in some particular cases destroyed.

With regards to fauna, the destruction of habitats such as high mountain pastures may particularly destructive for locally endemic invertebrates during the construction of the wind farms and associated infrastructure. Developing new road infrastructure to connect remote wind projects may lead to localized habitat fragmentation, which may have significant negative impact on small mammals, amphibians and reptiles, and in particularly snakes. Furthermore, while wind farms are very unlikely to cause direct mortality to large mammals (there is no risk of collision, as there is for bats and birds), they still can cause considerable negative effects. Because of the noise associated with wind turbines and because of the mere presence of urbanised structures, large mammals can start avoiding otherwise suitable for them habitats. Therefore, even though wind turbines have relatively small footprints, they can in fact fragment the habitats of large carnivores, such as bears and wolf, impacting their surviving rate, mating and reproduction patterns and thus, impacting negatively the populations of these mammals.

More specifically, information exists suggesting that the Grey wolf (Canis lupus) avoids making a den within 200 m from wind turbines, their auxiliary facilities and service roads, while this distance for Brown bear (Ursus arctus) is 500 m. The Eurasian lynx (Lynx lynx) does not make dens within 3000 m from the wind turbines and 1500 m from the power lines and the service roads. For smaller species, such as the Marbled Polecat (Vormela peregusna) and the Steppe Polecat (Mustela eversmanii) the avoided habitats are within 200 m from the wind turbines.

Fragmentation or destruction of habitats of particularly vulnerable species can affect behaviour. Hence, it is crucial that the identified effects are adequately addressed and evaluated prior to any future wind power development.

To summarize, the territory of Bulgaria has a rich flora and fauna diversity, including many globally and EU level protected species and habitats. The impacts of wind energy on flora are likely to be less significant than in the case of fauna. For that reason, the level of significance of the potential effects of wind power development on this SER Objective is assessed as minor negative.

SER Objective 3.3 Reduce the risk of potential impact on protected territories (under the Bulgarian Protected Territories Act)

The Protected Territories cover approximately 545,725 hectares which constitutes 5% of the total country area. Bulgaria’s Protected Areas system includes 3 national parks: Rila National Park, Pirin National Park and Central Balkan National Park (with a total area of 221,252.2


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hectares); 55 reserves; 35 managed reserves; 11 nature parks (over 180,000 hectares); 501 protected sites; and 350 natural monuments. Two of the nature parks (Pirin National Park and Sreburna biosphere reserve) have been included in UNESCO's World Heritage List.

The potential impacts from wind farm development on the protected territories ranges from disturbance of the natural state of the territories and diminishing the aesthetic value of natural monuments to interference with ecosystem functioning in protected habitats. Possibly, the biggest concern stems from the cumulative wind power development encroaching in close proximity to the boundaries of protected territories, whose statute and/or management plan does not prohibit the individual developments. Therefore, the potential effects from wind power development on protected territories have been assessed as a major negative effect.

SER Objective 3.4 Reduce the risk of potential impact on NATURA 2000 sites

The current number of Sites of Community Importance (SCI's) in Bulgaria is 268, with a total area of almost 3.343 million hectares (29.5% of national territory), while the Special Protected Areas (SPA’s) are 114 and occupy an area of over 2.321 million hectares (20.4% of the country). SCIs and SPAs largely overlap and the Black Sea coast also includes aquatic territories (14 sites designated). Up to date, the Ministry of Environment and Water of Bulgaria has issued 95 orders to officially designate SPAs. Such orders contain an accurate description of the boundaries of the zones and their corresponding regimes of limitations. The designation orders of 6 more SPAs are awaiting publication in the State Gazette and 13 SPAs new designation orders are either currently undergoing public consultation process or are expecting the Minister of Environment and Water to sign them.

Wind power development within protected NATURA 2000 sites or in the fringes of these sites may create disturbance, possibly through direct habitat loss or fragmentation by access roads and infrastructure. In cases where wind power projects are sited within, or in the vicinity of, designated or potentially designated protected areas, the risk that the achievement of their protection goal might be compromised exists. It should be emphasized that in order to protect animal species for which the SCIs or SPAs have been designated, these species have to be protected inside the boundaries of the NATURA 2000 sites, as well as outside of the boundaries.

Recent developments in Bulgaria show that wind generator construction is still taking place within or near the boundaries of NATURA 2000 areas. Based on two infringement procedures started by the EC against Bulgaria, as well as two recommendations of the Bern Convention, it appears that for a long time the Bulgarian appropriate assessment mechanism has not worked properly. The appropriate assessment mechanism is further weakened by absence of management plans for most of the NATURA 2000 areas, which would mandate particular prohibited impacts, location requirements and mitigation measures for each NATURA zone. Therefore, the assessment process that has been used seems to have been incapable of safeguarding adequately the NATURA 2000 network against the impacts of individual projects, and most importantly, it has not taken into account in full cumulative effects of wind power development. Due to this ongoing issue, the potential effects of wind power development of the NATURA 2000 network is assessed as being major and negative.

SER Objective 3.5 Reduce the risk of potential impact on forests

Approximately 30% of Bulgaria’s territory is covered by forests, 60% of which are considered to be of natural origin. The identified High Conservation Value Forests (HCVF) in Bulgaria, as detailed in Section 7 of this report, contain a significant level of biological diversity, rare, threatened and endangered ecosystems, and endemic species. The impact on these forests from wind power development may range from initial human disturbance of non-fragmented


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forest landscapes to direct destruction of endangered vegetation types, to impact on the ecosystem services that forests provide, such as water and erosion protection and recreational functions. While wind developments are not expected to occur in extremely remote forested and/or mountainous landscapes where the highest conservation value forests (categories HCV1 and HCV2) are primarily located, wind developments in adjacent areas could have a knock-on effect of increased visitors and economic activities, for example by the provision of new access roads or local employment. Therefore, potential effects of wind power development within the forests in Bulgaria, is assessed as being minor negative.


There is a significant potential for cumulative impact of wind turbines on fauna, flora and biodiversity particularly with relation to birds. This cumulative effect could arise from an increase in the number of wind turbines, as well as from the addition of other infrastructure, such as electrical substations and new power lines. It should be noted that the impacts of wind power turbines on birds are additional to the already existing anthropogenic impacts, such as hunting, traffic, existing electrical infrastructure, use of chemicals in agriculture, etc.

These cumulative effects increase the likelihood for disturbance, habitat displacement and collision risks, which is particularly relevant for soaring migratory birds and for wintering waterfowl species. For waterfowl congregations, impacts of wind power projects are have the potential to be cumulative with negative effects of other human activities such as hunting and agriculture.

In addition, there is the potential for cumulative effects of wind power development with relation to protected territories as development may encroach on the boundaries of protected territories, whose statute and/or management plan does not prohibit the individual developments.

In general, the construction of a single turbine or a small wind farm may attract the construction of other developments by providing road infrastructure and increased opportunities for grid connection. For this reason, secondary and cumulative effects on flora, fauna and biodiversity SER Objectives are considered to be likely.

For most of the flora, fauna and biodiversity SER objectives, the identified effects are expected to have a trans-boundary nature either because the species are moving across country borders (such as migrating birds) or because the receptors have an EU level or global importance.

6.1.4 Soil and Water The following table summarizes the assessment for Soil and Water SER Objectives:

Table 25: SER Objective Appraisal Summary - Soil and Water





1 1 1


1 1 1


3 1 3


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1 1 1

SER Objective 4.1 Reduce the risk of potential contribution to soil erosion

Based on a study carried out by the Pushkarov Institute of Soil Science, the potential erosion risk for 62 % of the country’s territory exceed 10 t/ ha/ y and for 30% of the country’s territory it is higher than 40 t/ ha/ y. Keeping these numbers in mind, it can be expected that the construction of wind power installations may cause an increase of the risk erosion within the areas of the construction of the wind turbines and the associated infrastructure. These effects are expected to be long term even though the risk of erosion is increased only during the construction stage of the projects. The spatial rage of these effects is local. For the above, the assigned level of significance is partial minor negative.

SER Objective 4.2 Reduce the risk of potential mobilization of anthropogenic contaminants during construction

There are no reliable statistics on the total area of contaminated sites. In Bulgaria an inventory of such sites is underway and information on this inventory is expected to become available in the future on the EEA website. However, it is known that such areas exist throughout the country as a result of bad environmental practices implemented in the past. When wind projects are implemented on such sites, it is expected that some remobilization of the pollutants in the soil is likely to take place. However, the described impacts are either minor or unlikely to happen and it is believed that overall, wind power projects have partial minor effects on this SER Objective.

SER Objective 4.3 Protect soil resources with significant economic value

When wind turbines are installed in agricultural lands, the area around turbines usually can continue to be used for the production of crops, regardless whether the status of land plots has been changed from agricultural use to energy generation use. Only the area occupied by the foundations of the turbines (for example 15 x 15 m for 2 MW turbines) and its immediate vicinity can no longer be used for agricultural purposes. In order to be able to assess the magnitude of the impact of wind power development on soil resources with significant economic value, the ratio “area occupied by wind turbines”/”area of soil resources with significant economic value” has to be calculated. Based on information, publically available on the website of the Ministry of Agriculture and Food, in 2008, the portion of the country which is occupied by agricultural land is around 51% while the portion of the cultivated agricultural land is around 28% of the country’s territory (3 060 543 ha). It is unclear what portion of this land is within categories 1 to 4, which are considered to be with highest economic value.

However, even though the exact magnitude of the effect is difficult to quantify due to data gaps, it is expected that it is very low to low. Therefore, even though wind power developments often take place in agricultural lands, it is not believed that they significantly reduce the country’s soil resources which have significant economic value. As a result, the effects of wind power on this SER Objective have been assessed as partial minor negative.

SER Objective 4.4 Reduce the risk of potential impact on surface water and/or groundwater quality

If wind power projects are located in close proximity to lakes or steams, or/and if during the construction phase of the project the run-off from the construction site is not properly managed, the potential may exist for some negative impacts on the receiving water bodies. One such


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impact is the sedimentation of soil particles contained in the run-off, causing reduced photosynthesis and reduced oxygen content of the water. Also, during the operation phase of a wind power project, the potential exists for oil leaks from equipment used to service the wind turbines, which can cause some water pollution. However, the described impacts are either minor or unlikely and it is believed that overall, wind power projects have no effects on water quality.


At this stage the potential of cumulative effects is considered to be unlikely.

6.1.5 Landscape Bulgaria is characterized with a high level of agricultural use. Forests cover the central band of Bulgaria as well as the northwest. The south of the country is characterized by non-irrigated arable land. Around 51% of the country is covered by agricultural land, 42% is covered by forest and semi natural areas and 5 % by anthropogenic objects, such as cities and industrial installations.

The following table summarizes the assessment for Landscape SER Objectives:

Table 26: SER Objective Appraisal Summary - Landscape




5.1 Reduce the risk of potential negative landscape transformation.

3 3 9

5.2 Reduce the risk of potential impact on visual value of landscape. 3 5 15

SER Objective 5.1 Reduce the risk of potential negative landscape transformation and SER Objective 5.2 Reduce the risk of potential impact on visual value of landscape

There were three principal considerations for the assessment of likely impacts of wind turbines on the landscape: the limit of visual perception, the individual characteristics of the landscape which affect its capacity to absorb a development and how people perceive its interaction with the landscape.

The ‘compatibility’ or degree to which a wind power development alters or harmonises with the character of a landscape in which it is observed, is largely determined by the above mentioned sensitivity criteria.

Key considerations include how the layout and scale of the development interacts with the landscape, and the level of development already experienced from other investment projects. These characteristics are highly variable at the regional and even at the local scale and are difficult to account for in a comprehensive manner in a strategic study like this one. Therefore, Landscape Visual Impact Assessments cannot be assessed at the national level but should be carefully taken into account when wind power projects are planned. Naturally, wind turbines are visible from a distance and it is important that the special characteristics of each installation site are taken into consideration and an attempt is made to blend the project into the landscape. Landscape value is assessed on the basis of the importance attached to a certain area because of its natural or cultural qualities.


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Further, the sensibility of effects is site specific and it depends also on the perception of local communities, e.g. in rural areas visual effects can be more significant. Opinions on wind developments landscape issues can change during each stage of construction.

Moreover, although all effects continue through the whole operation of a wind power project, these effects are usually considered local. An exception is when the visual impact is on protected areas with EU or global importance.

Therefore, in terms of the effects of wind power on the landscape transformations, it is expected that the effects are negative but minor while the effects on the visual value of the landscape are considered negative and major.


The implementation of wind power projects can result in an increase of the existing visual impacts on the landscape, therefore, it is very important to assess the presence of cumulative effects at early stages of the projects. Furthermore, the construction of wind turbines is related to the construction of power lines, electricity substations and other auxiliary infrastructure and thus cumulative visual effects of all these developments should be assessed during the planning stage of each project.

6.1.6 Public health, Noise and Vibration The following table summarizes the assessment for the Public Health, Noise and Vibration SER Objectives:

Table 27: SER Objective Appraisal Summary - Public health, Noise and Vibration




6.1 Reduce the risk of potential impact from noise caused by the interaction of the turbine blades with the wind.

1 1 1

6.2 Reduce the risk of potential impact on public health due to shadow flicker effect.

1 1 1

SER Objectives 6.1 and 6.2 Reduce the risk of potential impact on public health due noise and shadow flicker effect

The level of uncertainty with respect to the amount of noise and vibrations generated by wind turbines and also the effect that this might have on receptors is high. Noise, vibrations and the flickering effect could affect nearby population during the construction and operation phases. At night, the World Health Organization recommends that the level of continuous noise outside a dwelling should be 45 dB or less, and inside, 30 dB or less. These thresholds should be even lower if there is a significant low-frequency component to the sound, as is the case of wind turbines. Higher levels of noise disturb sleep and produce a host of effects on health, well-being, and productivity.


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The shadow flickering effect is generated when the sun shines through rotating turbine blades, which creates pulses of light and shadow in the area at the opposite side of the turbine. This stroboscopic effect is known to affect the health of certain persons66.

It is difficult to assess the potential for these effects at the strategic level because the scale, duration and method of construction for individual projects may vary and are in general unknown. Also, noise maps and noise action plans are still under development in Bulgaria which is further hindering the assessment of the significance of the impact of wind power development on public health. On the other hand, it should be noted that operational noise can be dramatically reduced by selecting appropriate site location, regular maintenance of turbines and continual vibrations monitoring.

Therefore, despite data limitations, it is assessed that the effects of wind power developments on public health (through noise, vibration and the flickering effect) are likely to be partial minor and negative. Further data would be needed in order to assess exposure of population to noise and other disturbances related to wind power developments. This should be undertaken in detail during planning stages of each wind power project.


A detailed evidence base regarding cumulative effects of wind power developments in public health could not be found at this stage of the assessment. Nevertheless, several studies67 warn of adverse secondary effects that wind power developments can have on population in the immediate project vicinity. For example, noise from multiple turbines similarly distant from a residence can be noticeably louder than from a single turbine simply due to addition of multiple noise sources. Under steady wind conditions, noise from a wind turbine farm may be greater than noise from the nearest turbine due to synchrony between noise from more than one turbine (van den Berg, 2005). Furthermore, shadow flicker is a potential issue in the mornings and evenings, when turbine noise may be shrouded by other local activities. Nevertheless, shadow flicker effects can be addressed in wind power developments during the preliminary design stage and cumulative impacts can be avoided. Moreover, this impact is negligible if turbines are sited more than 500 m from populated sites.

66 Danish Wind Energy Industry Association: http://www.talentfactory.dk/en/tour/env/shadow/index.htm 67 Public Health Impacts of Wind Turbines: http://windconcernsontario.files.wordpress.com/2009/06/windturbines.pdf


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6.1.7 Socio-Economic and Material Assets The impact of wind power development on Socio-Economic and Material Assets depends on a number of factors which makes the evaluation of these effects difficult. The availability of wind power projects related to Socio-Economic and Material Assets data would enable a more detailed assessment of these topics. Even so, it can often be difficult to establish the links between apparently or possibly related phenomena, for example wind power projects and property value.

The following table summarizes the assessment for the Socio-Economic and Material Assets SER Objectives:

Table 28: SER Objective Appraisal Summary - Socio-Economic and Material Assets




7.1 Reduce the effect on property values of developed area and adjacent properties.

? - - -

7.2 Attain positive contribution towards employment and secondary economy.

1 1 1

7.3 Reduce the risk of potential impact on other sectors (conventional tourism, hunting, eco-tourism, etc.).

? - - -

7.4 Reduce the risk of electromagnetic interferences with signals relevant to human activities.

1 1 1

7.5 Contribute to the development of power transmission and road infrastructure.

1 3 3

Property devaluation can be an issue of concern, particularly for property owners immediately adjacent to properties selected for the location of wind turbines. It is generally recognized that the negative impact on agricultural land values is smaller than that in residential property values.

However, this potential impact is difficult to determine and varies in time; no detailed studies have been conducted in Bulgaria concerning impacts of wind farm development on property prices. The potential land use impact in hilly, forested areas is more complex than that in agricultural areas, and tends to be cause for controversy.

A formal assessment of impacts of wind power development on other sectors in Bulgaria has not been conducted. For example, green or sustainable tourism development is recognised to be increasingly important in attracting visitors. If proper surveys are conducted, this would enable a more accurate assessment.

Bulgaria’s natural landscapes attract almost 6 million visitors annually, which contribute significantly to the economic growth of the country and make Bulgaria one of the most visited destinations in the Black Sea Coast. The Black Sea Cost is an area that has shown the necessary preconditions for development of wind energy but it is also one of the most significant tourist attractions. Moreover, in some areas wind farms are being regarded as a feature of the landscape, especially in areas which previously had no appeal to visitors.


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Regarding to the electromagnetic interference of wind turbines, no evidence base was found in Bulgaria. Nevertheless, impacts have been detected in other countries where evidence was found that turbines can interfere with radio or TV signals if a turbine is in the "line of sight" between a receiver and the signal source. This issue can usually be easily dealt, improving the receiver's antenna or installing relays to transmit the signal around the wind farm. However, if a wind project is proposed near an airport or military airfield, this issue will likely require further technical investigation. The interference is generally limited to objects (airplanes) that are physically shadowed by the turbines (that is, very low-flying aircraft), so the further the turbines are from an airfield and the lower their altitude, the less interference should occur. For all the above, the effect was considered as partial negative

Wind power development may give rise to partial positive effects with regards to the development of power transmission and road infrastructure. It is known that the development of wind farms in remote areas increases accessibility through the development of tracks and roads, thus promoting economic development.

Moreover, the Bulgarian law requires electricity transmission and distribution companies to ensure priority connection to their transmission and distribution grids to all plants producing electricity from renewable energy sources (RES). Additionally, electricity transmission and distribution companies should allocate resources for grid development aiming to promote the production of electricity from RES in their investment and maintenance programmes. As a result, areas where wind farms are expected to be implemented are priority areas for grid connections and electricity transmission and distribution, which is likely to bring about partial positive effects for the population of these areas.


The evidence base of cumulative effects of wind power development in Socio-Economic and Material Assets is related to other development projects both at regional and national level. Additionally, effects can be cumulative with other sectors, such as tourism, both in positive and negative directions.

The assessment of cumulative effects will be addressed during SER Draft Report consultation process and any relevant outcomes will be included in the final report.

Future related projects can continue with the assessment and monitoring of the effects of wind power development on Socio-Economic and Material Assets in Bulgaria, and base their scope of work on the outcome of the SER.


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7 Constraints Analysis Following the scoping consultation stage it became clear that a considerable amount of spatial data could be obtained to inform the assessment of the SER objectives and indicators. For this reason, spatial data was formally requested from all relevant institutions, organizations and individual experts, which were identified during the scoping consultation process. Data providers range from state entities, including ministries, agencies and regional inspectorates, academic institutions, non-governmental organizations and independent experts. Data providers and the information they supplied is provided in Appendix D.

A Geographical Information System (GIS) was used to manage and analyse the data which was collected. The GIS allows visual representations of spatial data to be created which includes the creation of various thematic maps. This is described further in this section of the SER Report.

7.1 Data gathering To have a complete understanding of the extent, completeness and limitations of the collected data, metadata (information about the data sets) has also been collected.

For the purpose of this project, a metadata form has been completed by the data provider for each data set. In the cases where the data provider has not supplied this form the project team has completed these forms in accordance to data provider indication. An example of a completed Metadata form is in Appendix D of this report.

It is important to notice that the compilation of a large database with environmental and social spatial data and the creation of a metadata system have been undertaken to provide MEET with a solid scientific platform for the development of a defendable and justifiable wind power development strategy. It can also be used as a tool, which MoEW, RIEWs, municipalities and investors can use to identify, at an early stage, areas with high environmental and social constraints where wind power development should be treated with upmost care, avoided or prohibited while directing investors to more appropriate areas with a lower environmental and social sensitivity to wind power development.

The compilation of the database with spatial data was a challenging task. While representatives of the academia and the environmental non-governmental organizations readily contributed to the project the relevant data sets which they have developed, about half of the governmental institutions, which were approached with data requests, were very slow to respond. The main problems were:

• lack of well defined responsibilities and/or communication within the institutions;

• lack of adequate GIS knowledge of people in charge of managing the spatial information of the respective institution;

• heavy and time consuming procedures for data sharing between governmental institutions;

• excessively high costs of spatial data even when the recipient is another governmental body (MEET);

• lack of (or unwillingness to provide) spatial data on key matters such as the location of constructed wind turbines.

The information included in this report is current as of June 14th, 2010. This was the end of the public consultation process for the draft SER report until when all stakeholders were encouraged to sumbit their statements, comments, information, etc.


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7.2 Levels of area sensitivity Based on available information regarding environmental and social constraints, the territory of Bulgaria has been classified into five area types, in accordance to the following sensitivity definitions:

• Areas with explicit legislative prohibition for wind power development;

• Areas with high sensitivity to wind power development;

• Areas with medium sensitivity to wind power development;

• Areas with low sensitivity to wind power development;

• Areas with no or unknown sensitivity to wind power development.

In order to allow visual representations of these areas a set of maps were created with information that was available and accessible as of March 2010. The size, shape and classification of areas are is subject to future modifications as further data becomes available.

It should also be noted that the environmental sensitivity is closely linked to the existing wind power technology and available mitigation methods. Developments in these fields will need to be taken into consideration when reconsidering environmental and social constraints in the future.

A description of the classification system for the five types of areas is presented below. The assigned colours are those used in the generated maps.

Black areas = Areas with explicit legislative prohibition for wind power development

• Justification The boundaries of these areas are determined in designation acts or similar documents, usually at the land plot level. The particular reason for prohibition of wind power development (or industrial activities in general) varies from one area type to another but in general, it is linked to the purpose of the area designation (protection of priority habitats, feeding and breeding areas for globally threatened bird species, drinking water source, etc.).

• Implications: According to current enacted Bulgarian legislation, almost all economic activities including wind power development are explicitly prohibited in these areas.

Red areas = Areas with high sensitivity to wind power development

• Justification: Wind power development in these areas is expected to cause significant negative impacts on the identified environmental and/or social aspects. The assigned level of sensitivity is supported by current enacted Bulgarian and EU legislation, as well as by published and non-published scientific information, including data from field studies.

• Implications: Given the likelihood that the installation of new wind turbines in these areas is likely to cause significant negative impacts on the environment, wind power development in these areas should be approached with upmost care. In the event that wind power development is considered within an area with high sensitivity, a detailed assessment of the environmental impacts should be required. To ensure that the EIAs of projects proposed in areas with high sensitivity have the quality, which is adequate to properly assess the existing risks, the Consortium recommends the following:

• the EIA should be mandatory, except for small size domestic turbines;

• the competent authority for these EIAs to be MoEW, instead of the RIEWs;


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• the consultations on the EIAs should include academic institutions, NGOs and other relevant stakeholders; a list with the stakeholders should be compiled by MoEW and provided to investors;

• the stakeholders should be informed about the consultation meetings through invitations over mail, fax and e-mail, as well as through an add on the MoEW´s website;

• all identified stakeholders should be consulted through the conduct of meeting no later than the scoping stage of the projects;

• the EIA should systematically assess cumulative effects;

• the EIA should include a comprehensive inventory on flora and habitats, a minimum one year monitoring of fauna for areas not designated for their avifauna, and a minimum of two years monitoring of fauna for areas designated for their avifauna.

Details on the proposed additional requirements for the EIA process are in Section 8.3 of this report.

Orange areas = Areas with medium sensitivity to wind power development

• Justification: Wind power development in these areas is expected to cause considerable impact on the identified environmental and/or social aspects. The assigned level of sensitivity is supported by current enacted Bulgarian and EU legislation, as well as by published and non-published scientific information, including data from field studies. As additional information becomes available, the sensitivity of these areas may change.

• Implications: In order to assess the viability of wind power projects in these areas, as well as their most suitable layout, detailed analysis/studies should be carried out. To ensure that the EIAs of projects proposed in these areas have the quality, which is adequate to properly assess the existing risks, the Consortium recommends the following:

• the EIA should be mandatory for wind power projects above 100kW;

• the consultations on the EIAs should include academic institutions, NGOs and other relevant stakeholders; a list with the stakeholders should be compiled by the RIEW and provided to investors;

• the stakeholders should be informed about the consultation meetings through invitations over mail, fax and e-mail, as well as an add at the respective RIEW’s website;



• the EIA should include a comprehensive inventory on flora and habitats and one to two years monitoring of fauna.


Yellow = Areas with low sensitivity to wind power development

• Justification: Wind power development in these areas is expected to potentially cause some impact on the identified environmental and/or social aspects. The assigned level of sensitivity is supported by current enacted Bulgarian and EU legislation, as well as by published and non-published scientific information, including some data from field studies. In some cases the data is limited and/or further studies are required to assess the actual sensitivity of the area.


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• Implications: In order to assess the viability of wind power projects in these areas, as well as their most suitable layout, EIAs should be carried. To ensure that the EIAs are performed with the due detail, the Consortium recommends the following:

• the EIA should be mandatory for wind power projects above 100kW;

• the consultations on the EIAs should include academic institutions, NGOs and other relevant stakeholders; a list with the stakeholders should be compiled by the RIEW and provided to investors;

• the stakeholders should be informed about the consultation meetings through invitations over mail, fax and e-mail, as well as through an add on the website of the respective RIEW;



• the EIA should include an inventory on flora and habitats and one year monitoring of fauna.


White = Areas with no or unknown sensitivity to wind power development

Justification: Wind power development is not expected to cause significant impacts on the identified environmental and/or social aspects because spatial environmental and social constrains in relation to wind power development have not been identified in these areas thus far. It should be emphasized that the designation of an area to have no sensitivity does not imply the absolute absence of environmental and social constraints. As additional information becomes available, the sensitivity of these areas may vary.

• Implications: Wind power development should be directed to these areas but all wind power installations above 100kW should undergo a standard EIA.

It is important to note that although great effort has been invested by the Consortium and the involved stakeholders to compile the best scientific data that is currently available regarding the social and environmental issues that may be affected by wind power development, the currently available dataset will undoubtedly have to be expanded and updated in the future.

Additionally, the interpretation of the data in terms of sensitivity will have to be reviewed periodically, and to perform this task the MoEW may consider to establish workgroups, in collaboration with the MEET, with regional and national experts. The database and its interpretation, as described in this report, are intended to be the starting point for a dynamic policy development program that should safeguard in the best way the interests of Bulgarian society and the country’s natural heritage. In its current state it does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.

7.3 Constraint Analysis by SER Topics This subsection is organised according to the environmental and social topic categories, outlined in Section 3.2 SER Stage A – Scoping and SER Objectives of this report. Each of these sub-subsections contains a summary table displaying the respective SER objectives and SER


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indicators, and the identified areas of constraint for each SER indicator. For each identified constraint area, the assigned level of sensitivity, the legal basis, the availability of spatial data and data sources are indicated.

In most cases, the designated level of sensitivity has been determined in cooperation with the data providers during multiple consultation meetings. The level of sensitivity is based on the environmental and social significance of the identified area and the requirements and recommendations established in the existing legal framework.

Some of the SER objectives and SER topics are not suitable for spatial analysis and where appropriate, this has been indicated. Below each summary table, where needed, additional summarized information is provided about the reasoning behind designating the respective level of constraint, the legal basis, the data sources, data quality and data gaps.

For a detailed analysis of these issues Appendix D should be consulted.

7.3.1 Energy, Climate and Air Quality The quality level of the available data was insufficient for the performance of a spatial analysis for the SER indicators identified for the energy, climate and air quality topics. This was mainly due to the fact that currently available information on the exact locations of the operational and planned wind turbines is incomplete which hinders the application of spatial analysis.

Furthermore, it is the opinion of the Consortium that the spatial analysis will only bring limited value to the evaluation of SER objectives 1.1 Reduce the growing dependence on energy imports within Bulgaria, 1.2 Support compliance with the Bulgarian national targets for % of energy from RS in the gross final energy consumption and 1.3. Reduce the overall emissions of greenhouse gases associated with energy generation and support compliance with the Bulgarian greenhouse gas emission targets.


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7.3.2 Cultural Heritage The description of the identified areas of constraint in relation to the cultural heritage aspects are summarized in Table 29:

Table 29 Cultural Heritage – Summary table

SER Objective

SER Indicator Identified areas of constraint Level of

constraint Basis for inclusion

Spatial data availability and data sources

2.1 Reduce the risk of potential impact on the boundaries of the Bulgarian and World Cultural Heritage Properties.

2.1.1. Avoid direct and minimize visual impacts on Bulgarian World and National Cultural Heritage Properties.

Cultural World Heritage Properties, including the set buffer zone

Black

Convention Concerning the Protection of the World Cultural and Natural Heritage, 1972, art. 4 and art. 5; Cultural Heritage Act (SG issue 19/2009), art. 50, art. 65

UNESCO World Heritage website

Immovable cultural monuments with national significance, including a reasonable site-specific buffer zone

Orange Cultural Heritage Act, art. 50, art. 65; Regulation 17 setting limits and arrangements for the use and protection of monuments of culture outside the settlements (SG issue 35/1979); Declaration Letter of the National Institute for Cultural Monuments #545 from 27.02.2001

Not Available

Immovable cultural monuments with local significance, including a reasonable site-specific buffer zone

Yellow Not Available


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Table 30 summarizes the justification for designating the respective level of constraint in the provided data set:

Table 30 Justification for designating the respective level of constraint for Cultural Heritage

Cultural World Heritage Properties, including buffer

zone

Assigned as areas with explicit legislative prohibition to wind power development

As identified in early stages of the project (Topic Paper 2 – Cultural Heritage), the World Heritage Properties are being designate through a rigorous process which is outlined in detail in the Operational guidelines for the implementation of the World Heritage Convention. The boundaries of the World Heritage Properties are drawn “to ensure the full expression of the outstanding universal value and the integrity and/or authenticity of the property”. Further, “for the purposes of effective protection of the nominated property, a buffer zone is an area surrounding the nominated property which has complementary legal and/or customary restrictions placed on its use and development to give an added layer of protection to the property”. “Although buffer zones are not normally part of the nominated property, any modifications to the buffer zone subsequent to inscription of a property on the World Heritage List should be approved by the World Heritage Committee.” 68

Based on the above requirements World Heritage Properties and the buffer zones around them, as shown in the designation documentation of each property, can be considered as places where wind power development is prohibited.

The Geodesy, Cartography and Cadastre Agency, the Institute of History at the BAS, the Religious Department at the Council of Ministers and the National Institute for Monuments of Culture have been contacted about spatial information on the locations of the cultural monuments with national and local significance in Bulgaria. Such spatial information is not available for the national scale at either of the institutions. However, when wind power development is planned at a particular site, the presence of cultural monuments with national and local significance should be assessed as part of the EIA process.

More information about the identified areas of constraint in relation to the cultural heritage aspect is outlined in Appendix D1.

Figure 4 displays the map of the Cultural World Heritage Properties within Bulgaria with the associated sensitivity criteria.

68 All citations are from the Operational guidance for the implementation of the Word heritage Convention, 2008, p. 26-27

World Cultural Heritage - Spatial Constraints Analysis

FIGURE 4Bulgaria

Title:

Rev.: PW/MC

Location:

Prepared for: Bulgarian Ministry of Economy, Energy and Tourism

Project No: ES11BUL001

Date: June 2010Drawn: TL/DD/JS

Legend:

Color Key

Data Set Data Source

World Heritage Properties UNESCO

Note:

This map was created as part of the report: "Strategic Environmental Review of the Development of Wind Power

in Bulgaria". The map should be used only when taking into account the content of the report. It is important to note

that the map is meant as a policy development tool, it is not the product of nation-wide Environmental Impact

Assessment. The presented sensitivity classification is based on the best available scientific information, current

environmental legislation and on expert opinions from data providers. The classification is provisional and should

be confirmed by the competent authorities

Areas with no or unknown sensitivity for WPD

Areas with high sensitivity for WPD

Areas with low sensitivity for WPD

Color Key:

Areas with explicit legislative prohibition for Wind Power Development (WPD)

Areas with medium sensitivity for WPD

Areas with explicit legislative prohibition for WPD - expected


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7.3.3 Flora, fauna and biodiversity, (with the exception of bird species and birds related areas) The identified areas of constraint in relation to flora, fauna and biodiversity aspects are presented in this section, except the constraints identified for bird species and bird related areas which are analyzed in a separate section.

The decision to conduct a separated analysis on bird species and bird related areas was taken based on the importance of birds in this assessment, as well as the amount of data collected in this regard. It is the opinion of the Consortium that this separate analysis allows for a better understanding of the levels of sensitivity defined for this topic.

Description of the identified areas of constraint in relation to flora, fauna and biodiversity aspects, excluding bird species and bird related areas, are summarized in Table 31.

Table 31 Flora, fauna and biodiversity (with the exception of bird species and birds related areas) – Summary table

SER Objective

SER Indicator Identified areas of

constraint Level of




Indicators 3.1.1-3.1.9 are included in a separate table for birds.

3.1.10 Breeding areas, feeding areas and migratory routes for bats.

Areas with high conservation

importance for bats Red Biodiversity Act, Annex 3 to art. 37

National Museum of Natural History (Boyan Petrov)

Areas with medium conservation

importance for bats Orange Biodiversity Act, Annex 3 to art. 37

Areas with low conservation

importance for bats Yellow Biodiversity Act, Annex 3 to art. 37

3.1.11. Consider the variations in the behaviour of different bat and bird species towards wind turbines.

Not suitable for spatial analysis


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SER Objective


constraint Level of




3.2.1. Minimise the impacts on bottleneck sites for migration of large carnivores outside of NATURA 2000 sites.

Avoidance of bottleneck sites of Annex II species

outside pSCI/SCI NATURA 2000

Orange

Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, art. 1, art. 3 art. 6, Annex II Biodiversity Act, art. 6, art. 31, art. 32, art. 37

Balkani Wildlife Society

3.2.2. Minimise the impacts on threatened plant species.

Proposed Plant Microreserves Yellow

Protected Territories Act will be amended (art. 5) in order to comply with the Biodiversity Act, Annex 3 to art. 37 Biodiversity Act, art. 35, par. 4 and art. 52.

Institute of Botany at BAS

Important Plant Areas Yellow

The Convention on Biological Diversity, 1993; Global Strategy for Plant Conservation, 2002

Institute of Botany at BAS

3.3 Reduce the risk of potential impact on Protected territories (under the Bulgarian Protected Territories Act).

3.3.1. Avoid impacts on protected territories.

Protected Territories Black Red

Protected Territories Act MoEW



Special Protected Areas (SPA) from NATURA 2000 networks are reviewed with the rest of the data sets related to birds.


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SER Objective


constraint Level of



3.4.2 Avoid impacts on NATURA 2000 SCI sites.

Sites of Community Interest (SCI) from

NATURA 2000 network Orange

Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora; Biodiversity Act, art. 6

MoEW

3.4.3. Avoid significant deterioration on all habitats in Annex I of the Habitat Directive in NATURA 2000 zones.

Annex I habitats in pSCI/SCI NATURA

2000 zones Red

Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, art 1, art. 3, art. 6, Annex I Bulgarian Biodiversity Act, art. 6, art. 31, art. 32


3.4.4. Avoid significant deterioration of all habitats of the species included in Annex II of the Habitat Directive inside NATURA 2000.

Habitats of Annex II species in pSCI/SCI

NATURA 2000 zones Red

Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, art. 1, art. 3 art. 6, Annex II Biodiversity Act, art. 6, art. 31, art. 32


3.4.5. Avoid disturbance of species under Annex II of the Habitat Directive inside NATURA 2000 - large carnivores.

Disturbance avoidance of Annex II species in

pSCI/SCINATURA 2000 zones

Red

Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, art. 1, art. 3 art. 6, Annex II Biodiversity Act, art. 6, art. 31, art. 32



3.5.1. Minimise the impacts on high conservation value forests (HCVF)

Biodiversity important forests

(Category I,III, IV from HCVF)

Orange

Category HCVF1: HCVF1.1: Protected Areas Act HCVF1.2 and HCVF1.3: IUCN Red List; Bulgarian Red Data Book - Volume I and II; Atlas of endemic, endangered and rare species in Bulgaria Category HCVF3: Protected Territories Act, art. 6 (1) (Priority natural forest habitats with national and European importance)

Mapping of the high conservation value forests in Bulgaria, BSPB

publication, 2009


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SER Objective


constraint Level of



Category HCVF4: Ordinance 3 for the conditions and order of investigation, designing, approval and operation of the sanitary protection zones around the water sources and the potable water supply facilities… (SG issue 88/2000), art. 53

Non-fragmented large forest landscapes (Category HCVF2)

Yellow

No particular piece of legislation; National HCVF Toolkit for the identification, management and monitoring of HCVF in Bulgaria

World Wildlife Fund Bulgaria

3.5.2. Minimise the impacts on forests with special designation.

Forests with special designations Orange Forest Act, Art.4 (2)

Executive Forest Agency

(when such data becames available)

3.5.3. Minimise the impacts on forested areas.

Forests Areas Yellow Forest Act, Art.1 (2)

Executive Forest Agency



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Table 32 summarizes the justification for designating the respective level of constraint in the provided data sets:

Table 32 Justification for designating the respective level of constraint for Flora, fauna and biodiversity (with the exception of bird species and birds related areas)

Areas with conservation importance to bats

Assigned as areas with low, medium or high sensitivity to wind power development. The identification process for areas with conservation importance to bats in Bulgaria was based upon both published literature data and the unpublished database of the Bat Research and Conservation Center at the National Museum of Natural History in Sofia. Fifteen major literature sources in combination with critical expert judgment were used to outline the size and form of 99 polygons. Five polygons were determined to be with low sensitivity to wind power development, 59 with medium sensitivity and 35 with high sensitivity. The size, shape and level of sensitivity for each polygon were based on the following parameters: local species diversity, population abundance, migration/dispersal potential, number of underground roosts and quality of the surrounding forests.

The protection of the identified zones will ensure the protection of important bat roosts and habitats and will minimize the impact of wind power development on the protected bat populations. Detailed explanation on the identification approach is provided in Appendix E of this report.

Avoidance of bottleneck sites of Annex II species

outside pSCI/SCI NATURA 2000

Assigned as areas with medium sensitivity to wind power development. This data set represents the bear bottleneck areas located between NATURA 2000 network sites. These areas are very important for the unimpeded movement of bears from one protected zone to another. The construction and operation of wind power turbines in these bottleneck sites can pose significant disturbance to the bears and prevent them from using the sites, thus posing an overall negative impact on the bear populations.

Proposed plant microreserves

Assigned as areas with low sensitivity to wind power development. In the near future, microreserves will be established in Bulgaria in order to protect 47 rare plant species which currently do not have adequate protection. The currently available information about the locations of the populations of these 47 rare plant species is limited to 10x10 km UTM squares where these species have been observed. The plant populations are located anywhere in the squares but further studies are needed in order to determine the precise location of the population. It is expected that in the next 3 years the precise locations of the plant populations will be mapped and that the MoEW will designate these areas as microreserves under the Protected Territories Act.

If wind power development is planned within such UTM square before the official designation of these microreserves, it is recommended that the Institute of Botany at BAS is contacted and a request is submitted for the most recent information on the location of the rare plant population in order to assess properly the impact of the wind power development on this proposed


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microreserve.

Important plant areas

Assigned as areas with low sensitivity to wind power development. IPAs are not legal site designations but are a tool for identifying and highlighting the best sites for plants and fungi which can be used to focus conservation actions and funding.

The currently available data set about the locations of the IPAs in Bulgaria contains only the central coordinates of the areas, without specifying their actual sizes. This data set should be used only as a general guidance on the presence and location of IPAs at a particular territory. If a wind power project or another major development is considered in a close proximity to a point from this data set, further information should to be requested from the Institute of Botany at BAS on the actual boundaries of the respective IPA, its species diversity, species conservation status, etc. and this information should be taken into consideration in the EIA process.

Protected territories

Strict nature reserves, managed nature reserves and national parks are assigned as areas with explicit legislative prohibition for wind power development, while natural parks, natural monuments and protected sites as areas with high sensitivity to wind power development. • Strict Nature Reserves – according to art. 17 (1), all activities shall be prohibited in strict nature reserves, except some activities which are directly related to the protection of the reserves;

• National Parks – according to art. 21, any construction, with the exception of hikers' shelters and chalets, water catchments for drinking purposes, treatment facilities, park management and visitor service buildings and facilities, underground communications, repair of existing buildings and roads, and sports and other facilities, shall be prohibited in the national parks.

• Natural Monuments – according to art. 24, any activities that may disturb the natural state of natural monuments or impair the aesthetic value thereof shall be prohibited in natural monuments.

• Managed Nature Reserves – according to art. 27 (1), any activities shall be prohibited in managed nature reserves, except some activities which are directly related to the protection of these territories;

• Nature Parks – according to art. 31, all activities and construction, which are not permitted in the park designation orders , park management plans and the spatial and technical plans and projects, as well as all activities which are specifically prohibited in the parks designation orders and the management plans, shall be prohibited in nature parks.

• Protected Sites – according to art. 34, any activities contrary to the requirements for conservation of the specific features subject to protection shall be prohibited in protected sites.

Sites of Community Assigned as areas with medium sensitivity to wind power development.


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Interest (SCI) from NATURA 2000 network

The pSCI/SCI areas are designated to provide protection for certain natural habitats included in Annex I of the Habitat Directive and habitats of species included in Annex II of the Habitat Directive. At present, there is no sufficient spatial data about the exact locations of the habitats for which the pSCI/SCI sites have been designated within these sites. Therefore, currently, without a field survey, it is hard to be sure that at a certain location within pSCI or SCI, a protected habitat or a habitat of a protected species is present and therefore they are not considered as high sensitivity areas. It is important to mention that since this project is not addressing offshore wind power development, the sections of the SCI areas, which extend into the Black Sea, were not included in this spatial constraints analysis because they are considered to be out of the current scope of work.

Annex I habitats in pSCI/SCI NATURA 2000

zones

Assigned as areas with high sensitivity to wind power development. According to art. 6 (2) of the Habitat Directive, Bulgaria has to avoid damaging activities that could significantly deteriorate the natural habitat types. The construction of wind power turbines, their auxiliary installations, as well as the access roads, is expected to significantly deteriorate the natural habitats in NATURA 2000 zones if constructed on them. The spatial analysis has utilized a GIS layer with the grasslands in NATURA 2000 pSCI/SCI zones.


Assigned as areas with high sensitivity to wind power development. According to art. 6 (2) of the Habitat Directive, Bulgaria has to avoid damaging activities that could significantly disturb the species or deteriorate their habitats. The construction of wind power turbines, their auxiliary installations, as well as the access roads, is expected to potentially significantly deteriorate the habitats of species from Annex II of the Habitat Directive in NATURA 2000 zones.

The spatial constraints analysis has utilized GIS layer with the habitats of the following species in NATURA 2000 pSCI/SCI zones: Marble polecat (Vormela peregusna), Romanian hamster (Mesocricetus newtonii), Tortoise (Testudo sp.) and European souslik (Spermophilus citellus). All these species are included in Annex II of the Habitat Directive, as well as in Annex 2 (or 2a) of the Bulgarian Biodiversity Act.

Disturbance avoidance of Annex II species in

pSCI/SCI NATURA 2000 zones

Assigned as areas with high sensitivity to wind power development. The justification is based on art. 6 (2) of the Habitat Directive, as mentioned above. The spatial constraints analysis has utilized GIS layer with the habitats of Grey wolf (Canis lupus) and Brown bear (Ursus arctos) in NATURA 2000 pSCI/SCI zones.

The Grey wolf and the Brown bear are species listed as requiring priority protection of their habitats because they are threatened of extinction – they are included in Annex II and IV of the Habitat Directive and Annex II of the Bulgarian Biodiversity Act.

Biodiversity important forests (Categories

Assigned as areas with medium sensitivity to wind power development. According to HCVRN there are six types of high conservation value (HCV) areas:


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HCVF1, HCVF3 and HCVF4)

• HCV1: Areas containing globally, regionally or nationally significant concentrations of biodiversity values (e.g. endemism, endangered species, refuge). This HCV is subdivided into: HCV1.1 – protected areas, HCV1.2 – threatened and endangered species, HCV1.3 – endemic species and HCV1.4 – critical temporal use.

• HCV2: Globally, regionally or nationally significant large landscape-level areas where viable populations of most if not all naturally occurring species exist in natural patterns of distribution and abundance.

• HCV3: Areas that are in or contain rare, threatened or endangered ecosystems.

• HCV4: Areas that provide basic ecosystem services in critical situations (e.g. watershed protection, erosion control).

• HCV5: Areas fundamental to meeting basic needs of local communities (e.g. subsistence, health).

• HCV6: Areas critical to local communities’ traditional cultural identity (areas of cultural, ecological, economic or religious significance identified in cooperation with such local communities).

The data set of biodiversity important forests, provided by the Bulgarian Society for the Protection of Birds is based on categories HCVF1 (1.1, 1.2 and 1.3), HCVF3 and HCVF4. The legislative support for these areas is provided below:

• HCVF1.1: The Bulgarian Protected Areas Act sets the framework for the protection of the areas designated as protected territories.

• HCVF1.2 and HCVF1.3: The plant, animal and fungi species which are threatened, endangered or endemic are listed in the IUCN Red List, the Bulgarian Red Data Book - Volume I and II, and the Atlas of endemic, endangered and rare species in Bulgaria.

• HCVF3: Rare, threatened or endangered forest ecosystems are usually protected under the Protected Areas Act (as protected territories) or under the Biodiversity Act (as NATURA 2000 sites).

• HCVF4: According to art. 53, art. 25 and art. 32 of Ordinance 3 for the conditions and order of investigation, designing, approval and operation of the sanitary protection zones around the water sources and the potable water supply facilities… (SG issue 88/2000) the forests in sanitary water protection zone I have to be recovered and maintained, while the forests in sanitary protection zones II and III are managed in accordance with the special forestry projects.

Construction activities in forests which have been identified by High Conservation Value Resource Network (HCVRN) as important for biodiversity should be approached with special care.

Non-fragmented large forest landscapes (Category HCVF2)

Assigned as areas with low sensitivity to wind power development. The forests which contain viable populations of most or all local species should have large areas, to be relatively undisturbed by human activities and should have low fragmentation (% of non-forested areas). The forests which are designated as being HCVF2 have to fulfill the criteria with certain quantitative parameters – naturalness, fragmentation and minimal size of the viable occurrence of the


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populations of the naturally occurring species.

Where possible, further anthropogenic fragmentation of these forest landscapes should be avoided.

Forests with special designations

Assigned as areas with medium sensitivity to wind power development. Even though there are no explicit legislative restrictions for the conduct of construction activities in forest, designated for water protection, erosion control, ameliorative or recreational used, in practice, significant impacts on these forest types may lead to erosion problems, water supply problems, etc. Thus, the potentially negative effects of construction activities should be carefully assessed. As this layer was not provided during the elaboration of this Final Report, these areas were not included in the final spatial constraints analysis.

Forested areas

Assigned as areas with low sensitivity to wind power development. The general forested areas are considered in this category – regardless of their naturalness, level of fragmentation, size and special functions. Considering that forested areas are generally considered as contributing to the preservation of biodiversity and they are also a major carbon sink, where possible, the construction of wind power installations should avoid significant disturbance to permanently forested areas. As this layer was not provided during the elaboration of this Final Report, these areas were not included in the final spatial constraints analysis.

Red Data Book data sets

A new, revised edition of the Bulgarian Red Data Book is completed and is expected to be released in 2010. The Red Data Book of Bulgaria has been prepared by four institutes of the Bulgarian Academy of Science (BAS) – the Central Laboratory of General Ecology, which prepared the volume on threatened habitats; the Institute of Botany – responsible for the volume on the threatened flora and micota, and the National Museum of Natural History and the Institute of Zoology, which prepared the volume on the threatened fauna. Besides preparing a paper edition of the Red Data Book, the BAS has also prepared and electronic version of the Red Data Book, as well as a GIS map for each volume. These maps represent a UTM grid, 10 x 10 km and the number of protected taxa in each square is represented by the intensity of the color of the square – deeper the color, higher the biodiversity value of the square. It should be noted that an entire 10 x 10 km square is identified as important on even if a specie/habitat is present only in a very small part of the square.

Around 60% of the flora and micota 10 x 10 km UTM grid GIS map are occupied by at least one Red Data Book taxon. In the fauna GIS map, more than 90% of the squares are occupied by at least one Red Data Book taxon, while at the GIS maps of Red Data Book habitats, almost 100% of the squares are


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occupied by threatened habitats. When the three GIS maps are combined, there are squares which have more than 100 Red Data Book target items, while many of the squares have more than 40 Red Data Book target items69.

Considering that: 1) when the three Red Data Book GIS maps are combined they cover the territory of the whole country, 2) these maps have very low precision, and 3) the data from the Bulgarian Red Data Book is used as part of the scientific argumentation for the designation of protected territories, NATURA 2000 zones, Important Bird Areas, Important Plant Areas, Microreserves, etc. (all of which have/will have much high precision than 10 x 10 km squares), it was decided not to use the Red Data Book layers in the spatial analysis for biodiversity.

More information about the identified areas of constraint in relation to the Flora, fauna and biodiversity (with the exception of bird species and birds related areas) is presented in Appendix D2.

It is important to mention that since this project is not addressing offshore wind power development maritime/costal areas were not included in this spatial constraints analysis because they are considered to be out of the current scope of work.

Figure 5 displays the map of the environmental constraints related to flora, fauna and biodiversity, except bird species and birds related areas.

69 This information is based on a document, which will accompany the new electronic version of the Red Book. The document was provided by the Central Laboratory for Genergal Ecology at BAS.

Fauna, Flora & Biodiversity except bird species and birds related areas - Spatial Constraints Analysis

FIGURE 5Bulgaria

Title:

Location:



Date: June 2010Drawn: TL/DD/JS Rev.: PW/MC

Legend:

Color Key


Areas with high conservat ion

importance for bats National Museum of

Natural History (B. Petrov)

Areas with medium conservation importance for bats NMNH (B. Petrov)

Areas with low conservation importance for bats

NMNH (B. Petrov)



Habitats of Annex I I species in pSCI/SCI NATURA 2000 zones




Bear and wolf bottleneck sites

outside pSCI/SCI NATURA 2000 Balkani Wildlife Society

Proposed plant microreserves Inst itute of Botany at BAS

Important plant areas Inst itute of Botany at BAS

Protected Territories: Strict nature reserves, Managed reserves, National parks Ministry of Environment

and Water (MoEW)

Protected Territories: Natural parks, Protected sites, Natural monuments

Natura 2000 – pSCI/SCI MoEW

Forests with high biodiversity value Bulgarian Soc iety for the

Protect ion of Birds (BSPB)

Non fragmented large forest

landscapes WWF Bulgaria




Color Key:




Note:








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7.3.4 Flora, fauna and biodiversity – Bird species and birds related areas As previously mentioned, given that birds can be particularly affected by the development of wind power, it was decided to perform the spatial analysis for bird species and birds related areas . This section refers to the main findings of the spatial analysis. The methodology for the conduct of this spatial analysis was discussed at multiple meetings with some of the best Bulgarian ornithologists.

7.3.4.1. Legal basis for inclusion The Birds and Habitats Directives are the cornerstones of the EU’s biodiversity policy. They enable the EU Member States to work together, within a common appropriate legislative framework, to protect Europe’s most valuable species and habitats across their entire natural range within the EU, irrespective of political or administrative boundaries.

Detailed information, on both Directives, and additional policy review is referred in Section 5 of this report. Nevertheless, there are two aspects of the EU Directives of particular relevance to effects of the wind farm developments on birds and birds related areas, regarding the location of the wind farm:

• In and around NATURA 2000 sites: any wind farm development that is likely to affect one or more NATURA 2000 sites has to undergo a step-by-step Appropriate Assessment procedure and, where necessary, apply the relevant safeguards for the species and habitat types of Community interest as described above

• Anywhere within the EU: the two Directives also require that Member States protect species of Community interest throughout their natural range within the EU (cf. Article 5 of Birds Directive and Article 12 of Habitats Directive). Thus any wind farm development must also take account its potential impact on species of Community interest (covered by the two Directives) outside NATURA 2000 sites as well.

Bulgaria is a contracting party to various relevant international environmental Conventions and Agreements as mention on Section 5 of this report. These Conventions have helped to shape the legal framework for biodiversity policy and legislation within the EU.

7.3.4.2. Justification for assigning the respective sensitivity levels Available published and unpublished ornithological information was used for the preparation of the spatial data sets and the determination of the appropriate level of sensitivity for each area type. No specific field studies were carried out to gather new information.

Additionally, it is important to mention that since this project is not addressing offshore wind power development, maritime/costal areas, like parts of SPAs, costal buffer areas around nests or migration corridors, which extend into the Black Sea, were not included in this spatial constraints analysis because they are considered to be out of the current scope of work.

The main data sources and data gaps are identified in Appendix D3, where a brief discussion on the data quality can also be found.

Migration, roosting and staging

The areas, important for migratory birds are divided into three categories: migratory routes, roosting sites for migratory birds and staging areas with key importance for migratory birds.

Migratory routes

The intensive migratory routes are defined as areas where the majority of migratory birds pass the country. The main migratory route in Bulgaria is Via Pontica migration route. According to BirdLife International criteria, areas along migratory routes where at least 5000 storks, pelicans and cranes or at least 3000


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raptors pass during autumn or spring migration are defined as migratory bottlenecks. The aggregation of bottleneck sites creates intensive migratory routes. These areas are very sensitive in terms of bird migration and special care should be taken if wind power development is considered there. The intensive migration corridor on Via Pontica along the Black Sea Coast is 40 to 100 km wide, which has been determined through radar surveys conducted in the period 1982-1983, review of published studies and visual migration observations in the field, conducted at 39 observation points in the period 2003-2009. Across each of the observation points along the Via Pontica migration route more than 10 000 (in many cases even more than 30 000) storks, pelicans and cranes and more than 3000 raptors have been recorded to pass during the field studies.

According to the present level of knowledge of the known migratory routes, they are divided into three main categories:

1. Relatively well studied migratory routes with high intensity of migration. The studied part of the Via Pontica migration route (as described above) falls into this category as been assigned as high sensitivity to wind power development.

2. Insufficiently studied migration corridors, where data exists that migratory birds pass along and where it is believed that detailed studies will result in the identification of bottleneck sites. Detailed studies on both spring and autumn migration for a period of at least 2 years are recommended to be conducted in these areas in order to determine whether these areas are suitable for wind farm development. The western part of Via Pontica migration route falls into this category, and has been assigned as medium sensitivity to wind power development.

3. Relatively poorly studied migratory routes with medium migration intensity. It has been confirmed that along these migratory corridors certain groups of birds, such as passerines, waterfowl and soaring birds, migrate regularly but in numbers lower than the BirdLife International thresholds for bottleneck sites. However, it is expected that at some of these areas the development of wind power will cause high risk for the migrating birds. Detailed migration studies are recommended for a period of 3 years in order to further assess these areas. Assigned low sensitivity to wind power development.

Roosting sites for migratory birds

Roosting sites for migratory birds are those places where migrants spend a relatively short period of time – stay during the night or alight during the day in severe weather conditions. At these sites migratory birds are concentrated in large numbers. The areas where storks, raptors or pelicans regularly alight to roost during the autumn or spring migration are identified as key roosting sites. Wind farms should not be constructed within 5 km of such sites because in this radius around the roosting sites birds usually fly lower and spend time to look for thermals or for a suitable place to roost. Roosting sites are assigned as high sensitivity to wind power development.

Staging areas with key importance for migratory/wintering birds

Apart from waterfowl congregations in wetlands, very little is known about staging areas for the majority of migratory and wintering birds that are vulnerable to wind farms. Special attention is given to species threatened by extinction at the global level. The known regular staging areas for globally threatened species or other species that congregate in high numbers should be treated with upmost care when wind farm development is planned. Those areas have to be large enough to include the entire staging area and to allow birds to approach it (see below). Movement corridors between the different staging areas also have to be safe, thus detailed studies are required to identify the areas where the construction of wind farms does not cause undue risks to staging areas.

At present, data on regular staging areas are available only for six globally threatened species - Red-breasted Goose (Branta ruficollis), Saker Falcon (Falco cherrug), Imperial Eagle (Aquila heliaca), Dalmatian


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Pelican (Pelecanus crispus), Lesser White-fronted Goose (Anser erythropus) and Black Vulture (Aegypius monachus).

• Imperial Eagle: The known staging areas are identified through satellite tracking and radio telemetry as sites where young birds prefer to stage and forage after the breeding season, as well as preferable movement corridors between them. Staging areas are assigned with high sensitivity to wind power development and flying corridors, as areas with medium sensitivity.

• Saker Falcon: The known staging areas are defined on the bases of field studies (mainly satellite tracking and visual migration studies), which confirm that the same bird (or birds) stay to forage and roosts for more than one day out of the breeding season. Most of the staging areas identified so far have been used by birds between a week and a month. Some of the movement corridors have also been identified. Only few of the staging areas of Saker Falcon have been identified thus, so further studies are needed. The identified staging areas should be treated with special care when wind farms are planned. Staging areas are assigned with high sensitivity to wind power development and flying corridors, as areas with medium sensitivity.

• Dalmatin Pelican: The known staging areas, where bird’s roosts and forage regularly in winter are relatively well studied and have been identified. The main roosts (wetlands) along the Black Sea Coast, as well as along the Danube River are not included because they fully overlap with high sensitivity wetlands and adjacent lands. The included staging areas are assigned with high sensitivity to wind power development.

• Black vulture: The known staging areas are identified through a radio telemetry study (biangulation and triangulation), conducted in the period 2005-2008 of individuals from a Greek population. The area is located in the Eastern Rodopi Mountain and is assigned as high sensitivity to wind power development.

• Red-breasted Goose and Lesser White-fronted Goose: The staging areas for both species include sites around roosting areas, where most frequently Red-breasted Goose and the Lesser White-fronted Goose are found to forage or are known to be used for foraging. Two types of foraging areas are defined:

- Sites within a distance of 10 km from known regular roosting sites (both in wetlands and the sea) of the Red-breasted Goose and the Lesser White-fronted Goose. Based on long-term studies, it is confirmed that the Red-breasted Goose prefers to forage in areas up to 10 km around roosting sites if there are no additional sources of disturbance (e.g. hunting). These areas are assigned as high sensitivity to wind power development. Usually, the hunting pressure around main roosts of the species is very high which forces the birds to fly further inland;

- The region of occurrence of Red-breasted Goose in Dobrudzha according to the published Species Consevation Action Plan, where detailed studies have to be carried out in order to identify the fields where the Red-breasted Goose forages regularly. This area is assigned as medium sensitivity to wind power development. All regular geese foraging areas should be treated with upmost care during wind farm planning and development, especially in Dobrudzha and along the Danube, where it is confirmed that the globally threatened Lesser White-fronted Goose always mixes with the numerous White-fronted Goose. Parts of the regular foraging areas in Dobrudzha, along the Black Sea cost and along Danube River have been identified. Further studies are needed to identify other foraging areas.

Waterfowl congregations and waterfowl colonies

Based on publications related to impact studies of wind farms on birds and discussion amongst 30 Bulgarian experts in ornithology, buffer zones have been proposed around certain wetlands in Bulgaria, which are known to hold globally threatened water bird species and/or hold significant waterfowl congregation or waterfowl colonies. Thus, they have to be treated with upmost care during the planning and construction of wind farms. The buffer zones are identified as 2 km-wide belts around the wetland’s banks. These buffer zones are based on published studies, field observations and local expertise about the level of dependence of birds to wetlands. Buffer zones have also been proposed around some rivers because they serve as


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important movement corridors for waterfowl, and along with their adjacent flooded areas are important feeding and roosting areas.

The wetlands are grouped in three categories based on the following criteria:

• Wetlands, including the adjacent 2 km land strip around banks that meet at least one of the following criteria:

o Site of international importance according to the Ramsar Convention or site that meets at least one of the Ramsar criteria for international importance for waterbirds – assigned as high sensitivity level. Important Bird Area and/or Special Protected Area, designated for protection of waterfowl or site that meets at least one of the IBA criteria for waterfowl protection – assigned as high sensitivity level. Site that holds at least one globally threatened waterfowl species during the breeding season, migration/staging or winter – assigned as high sensitivity level.

o Site regularly holding at least 1% of the national wintering population of waterfowl specie – assigned as medium sensitivity level.

• Wetlands, including the adjacent 2 km land strip around the banks, where waterfowl congregations have been observed, but for which there are not enough studies during migration and winter to the assess the real value of the wetlands for waterfowl. The 2 km buffer around these wetlands has to be studied carefully before planning wind farm development, assigned as medium sensitivity level.

• Wetlands, including the adjacent 2 km land strip around the banks, which in certain years hold at least 1% of the national wintering population of a waterfowl species. Detailed studies have to be carried out in order to identify movement corridors of the waterfowl and the use of the adjacent land by waterfowl, before a decision for wind farm development is taken. The most appropriate location for wind farms has to be identified in order to avoid the barrier effect and the collision risk for the birds. In certain cases, after detailed studies, the predefined buffer zone of 2 km could be decreased in certain places. These areas are assigned as low sensitivity to wind power development.

Breeding birds

Based on publications related to impact studies of wind farms on birds and discussion amongst 30 Bulgarian experts in ornithology, it was agreed that certain bird species are highly vulnerable to wind farms and for those that are globally threatened and/or threatened at EU level wind farm development should be avoided at a certain distance from their nest, nesting colonies or roosts and foraging areas during the breeding season (especially for Griffon Vulture and Black Vulture). The species list and the buffer zones are identified based on the following criteria:

• Vulnerability to wind farm development – those that are confirmed as high/medium vulnerable are taken into account.

• Conservation status – only globally threatened and threatened species at EU level are taken into account. For the threatened species which have faced severe decline during the last 20 years, the known nests are divided in three categories and the consulted experts have made the following recommendations: a) nests occupied during the last 10 years (2000 – 2010) – these areas should be avoided; b) nests occupied between 1990 – 2000 but are not currently occupied – detailed studies have to be carried out to determine that possibility that these nests will be reoccupied; c) nests that have been occupied before 1990 –these nests should also be documented although at a less detailed level. This approach has been applied only to Egyptian Vulture (Neophron percnopterus).

• Ecological specifics of the species – species with low reproduction rate and long life cycles are considered more vulnerable to wind power development and thus there may be a need to propose larger buffer zones. The buffer zones are defined on the bases of the usual feeding areas, as well as the buffer zones already defined as a result of impact studies. For species that use several nests for long periods of


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time and change them periodically as part of their natural behaviour (e.g. Egyptian Vulture, White-tailed Eagle, Golden Eagle), buffer zones are proposed around each nest.

• Sensitivity of the species to certain human activities, in particular hunting and illegal capture. For species that are subject of illegal capture t is not reasonable from the conservation point of view to publicize information about location of the nests, even when a predefined buffer is applied. Thus, on the bases of the predefined buffers, the known breeding areas that have to be avoided are combined in a way that secures the confidentiality of the exact locations of the nests. Such approach is used for the Saker Falcon (Falco cherrug), Golden Eagle (Aquila chrysaetos) and Imperial Eagle (Aquila heliaca).

As can be observed in Appendix D3 FF, in certain cases the buffer zones, recommended by the consulted specialists is large, such as in the case of the Griffon Vulture (50 km around breeding colonies and roosts, and 20 km around core areas of reintroduction of the species). As the territory around the colonies and roosts which is used by these species is irregular in terms of food availability, flight conditions, etc., further studies are required to better define the required extension and shape of the buffer zones around these sensitive areas.

For species for which there is no information about the exact nest locations, habitat based approach is used to identify the sensitive areas. Suitable habitats for these species are identified based on of the Bulgarian Breeding Atlas (2007) and the CORINE Landcover 2006, bearing in mind also the preferable altitude of flight of species. In these areas, further studies have to be carried out in order to identify exact locations of nests and to apply a buffer zone around them before determining the location of the wind farm.

For species which are very vulnerable to wind farms but are widely spread throughout the country, such as the kestrel, common buzzard and hawks, the buffer zone approach has not been implemented. In these cases, as well as in all other cases of breeding birds that do not meet any of above-mentioned criteria, the suitability of wind farm development in a close distance to their breeding grounds should be defined based on EIA/AA assessment.

Further detail on the justification of the proposed buffer zones can be consulted in Appendix D3 FF.

The assigned levels of sensitivity for the various types of breeding areas are as follows:

• Known breeding localities for globally threatened species – high sensitivity.

• Known breeding localities for highly vulnerable species threatened at EU level (listed in Annex I of the Bird Directive) – high sensitivity.

• Known breeding localities of vulnerable species threatened at EU level (listed in Annex I of the Bird Directive) – medium sensitivity.

• Known breeding localities of globally or EU threatened species that met severe decline in last 20 years, occupied in the period 1990-2000 - medium sensitivity.

• Known breeding localities of globally or EU threatened species, that met severe decline in last 20 years, occupied before 1990 - low sensitivity.

• Suitable breeding habitats of globally or EU level threatened species, highly vulnerable to wind turbines, where species have been confirmed to breed – medium sensitivity.

Areas of reintroduction of globally threatened or highly vulnerable to wind turbines EU level threatened species

Sites of reintroduction of globally threatened or EU level threatened species are also considered as part of this study. Reintroduction of threatened species into the environment is usually a large scale conservation activity that combines efforts of many organizations to improve the national conservation status of a species. When released, young birds usually fly over large territories around the site of release in order to


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“investigate” the region for suitable feeding, roosting, staging and nesting grounds. To ensure the success of these reintroduction efforts, areas around sites where the species will be released into the environment should be treated with the appropriate level of protection. Based on expert consensus, a 30 km buffer zone around known sites of reintroduction is recommended. Areas where birds will be reintroduced within 1 year are assigned as medium sensitivity level, while areas, where reintroduction is planned within the next 5 years are assigned as low sensitivity level. At the moment, there are reintroduction efforts only for Griffon Vulture (Gyps fulvus). This species has just been or expected to be soon reintroduced in five sites – four along the Stara Planina region and one in the Kresna Gorge.

Areas specifically designated for bird protection

Important Bird Areas

The Important Bird Areas (IBA) are identified according to a set of standards - scientifically based numerical criteria of BirdLife International for the identification of sites of particular importance for birds during breeding, migration and winter on an international scale. The criteria for identification of IBAs include sites of global importance that meet criteria common all over the world, sites of European importance that meet criteria common to the whole Europe and sites of EU importance, that meet the criteria common to the European Union and that are the scientific ground for the identification of Special Protection Areas under the Bird Directive. More detailed information on the IBA´s was identified on Section 5 of this report.

In general, the IBAs in Bulgaria contain a set of species that are particularly vulnerable to wind farms and in order to ensure the long-term survival and favourable conservation status of these species, wind power development in these areas should be treated with upmost care. At least 90 of the IBAs are of global importance for globally threatened species or congregations of birds that include globally threatened species, which makes these sites both important for the survival of these species and sensitive to human impacts. Therefore, the IBAs are assigned with high sensitivity level.

Special Protection Area (SPAs)

The SPA network in Bulgaria is created in compliance with the Bird Directive and the Bulgarian Biodiversity Act. It is based to a large extent on the IBA network. It is important to stress that the network coherence should also be secured by ensuring safe migratory movements (ecological corridors) between SPAs, as well as by securing key areas outside SPAs for species that are protected in the SPAs. For this purpose, the above criteria for migration, bird congregations and breeding are applied.

In 2007, a total of 114 SPA sites where proposed to the Bulgarian government. Of these proposed sites, up to date 95 have been officially designated. Of the officially designated ones, 23 have in their designation orders restrictions either specifically for wind power development or for most commercial and industrial activities. Therefore, based on the currently enacted legislation, these 23 SPAs are assigned as explicitly prohibited for wind power development.

Furthermore, there are 14 additional SPAs (Bakarlaka, Trigrad-Mursalitsa, Vasiliovska planina, Mesta, Mandra-poda, Sakar, Balchik, Belite skali, Batova, Galata, Varnensko-Beloslavsko ezero, Zapaden Balkan (above velation of 800m), Kamchiyska planina, Kompleks Kamchiya) for which the proposed designation orders contain prohibition for wind power development and have been made available for public consultation. The designation orders of the first four SPAs (Bakarlaka, Trigrad-Mursalitsa, Vasiliovska planina, Mesta) have been approved, signed by the Minister of Environment and Water and are awaiting publication in the State Gazette. The public consultation process of the next four SPAs (Mandra-poda, Sakar, Balchik, Belite skali) ended on April 5th 2010 and they are awaiting the final approval of the Minister, followed by the publication in the State Gazette. Regarding to the last 6 SPAs (Batova, Galata, Varnensko-Beloslavsko ezero, Zapaden Balkan (above velation of 800m), Kamchiyska planina, Kompleks Kamchiya) public consultation process is currently undergoing. Nevertheless, officially publication is expected soon after the consultation process finishes. Because of the above mentioned, these 14 areas are assigned with a special


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intermediate level, only applicable for this particular case, as high sensitivity level with black overlaying stripes.

It is important to mention that since this project is not addressing offshore wind power development, the parts of the SPA areas, which extend into the Black Sea were not included in this spatial constraints analysis because they are considered to be out of the current scope of work.

Even though there are no explicit restrictions for wind power development for the other 64 designated SPAs and 19 approved, but not yet designated SPAs, due to the high sensitivity of these sites and their richness with bird species, they are assigned as high sensitivity level. Nevertheless, following the precautionary principle, the not yet officially designated SPAs should be treated with special care by wind power development at least until their designation orders are published.

It is important to add that the areas of IBAs that are proposed but not designated as SPAs fall under the requirements of the Article 4.4 of the Bird Directive, according EU case law, in particular the ECJ decision in case C-374/98. These areas should be protected until it is confirmed that they designated as SPAs. These areas are the 19 approved but not yet designated SPAs, as well as the areas of IBAs Kaliakra, Lomovete, Central Balkan, Rila, Pirin and Western Rhodopes that are proposed but not approved as SPAs and thus are subject to an EU infringement procedure.

Protected territories designated for bird protection

Protected territories, designated under the Protected Areas Act, are either explicitly prohibited for wind power development or in any case wind power development should be carefully considered. The protected territories are reviewed with the rest of flora, fauna and biodiversity aspects in Section 6.3.3. Some of the protected territories have been designated specifically for the protection of birds. In most cases though these territories are small areas and cover mainly the breeding areas of the targeted species, without strictly protecting sufficient foraging and feeding areas. In order to avoid detrimental effects on the populations of the species protected within these protected territories, buffer zones of 1.5 km around the territories boundaries have been proposed. There areas are assigned as areas with medium sensitivity to wind power development. The protected territories specifically designated for the protection of bird species have been identified through a review of the profiles of the 955 protected areas, listed on the Executive Environmental Agency website.

7.3.4.3. Identified areas with high sensitivity By application of the criteria described earlier several regions in the country are identified as having high sensitivity to wind farm development, because of migration, waterfowl congregations and/or breeding raptors:

The Eastern Bulgaria up to 100 km west from the Black coast line, because of Via Pontica migration Route, wetlands with globally important congregations, concentration of wintering geese, important staging areas for raptors, breeding localities of vulnerable raptors. Special attention should be given to the fact that the Black Sea coast holds the biggest number of globally threatened species, including globally important congregations of the Red-breasted Goose, White-headed Duck, Red-footed Falcon.

Strandzha-Sakar-Eastern Rhodopes are the most important areas for the globally threatened Imperial Eagle, the Egyptian Vulture, the Black Vulture and the highly vulnerable Griffon Vulture, as well as for numerous raptor species.

The area between the towns of Sliven, Karnobat and Topolovgrad because of the breeding Imperial Eagle and many other raptors, migration corridors for soaring birds, waterfowl congregations.

Balkan Mountain because of concentration of breeding areas of many raptor species, as well as the globally threatened Corncrake, Saker Falcon and Egyptian Falcon.


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Danube river and adjacent land because of main breeding area of White-tailed Eagle, Dalmatian Pelican, Pygmy Cormorant, Ferruginous Duck and many colonies of herons, egrets, cormorants and terns; waterfowl congregations and movement corridor for waterfowl; wintering congregations and feeding areas of geese; migration corridor; last breeding areas of Egyptian Vulture in the Danube Plain.

The rivers of Maritsa, Tundzha, Struma, Mesta, Iskar, Ogosta, Vit and Yantra because of waterfowl congregations and migratory corridors.

Important Bird Areas and Special Protected areas (these include also all Ramsar sites) that are recognized as internationally important for the long-term survival of threatened and vulnerable bird species during breeding, migration and winter.

Nationally protected areas for birds, because their main subjects of protection are the threatened birds.

Other small scale territories that do not fall in any of the above mentioned regions or set of sites but meet the sensitivity criteria.

Descriptions of identified areas of constraint in relation to bird species and birds related areas are summarized in Table 33.


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Table 33 Bird species and birds related areas - Summary table

SER Objective


constraint Data sources


3.1.1. Avoid impacts on migration bottleneck sites of globally and EU protected bird species (more than 5000 storks and pelicans or more than 3000 raptors)

Migration bottlenecks along Via Pontica route – well studied

Red

BSPB; Institute of Zoology at BAS;

publications

Migration along Via Pontica route – insufficiently studied Orange

Other migration routes – insufficiently studied Yellow

3.1.2. Avoid impacts on roosting sites of globally and EU protected bird species

Roosts of storks, pelicans and raptors Red BSPB; publications

3.1.3. Avoid impacts on staging areas and flying corridors of globally and EU protected raptors and vultures

Staging areas Red BSPB; Green Balkans

Federation Flying corridors Orange

3.1.4. Avoid impacts on staging and feeding areas of globally and EU protected wintering geese, swans and ducks

Staging and feeding areas of wintering geese, swans and ducks Red / Orange

BSBP; Institute of Zoology at BAS;

publications

3.1.5. Avoid impacts on wetlands with waterfowl concentrations and waterfowl colonies (regardless of season)

Waterfowl congregations Red / Orange / Yellow BSPB; Institute of

Zoology at BAS; publications Bird colonies Red

3.1.6. Avoid impacts on breeding and feeding areas of globally and EU protected raptors and vultures

Know nests of globally threatened species – occupied after 2000

Red

BSPB; publications Know nests of globally threatened species – occupied 1990-2000

Orange

Know nests of globally threatened species – occupied before 1990

Yellow

Known nests of EU threatened species – highly Red BSPB; Institute of


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SER Objective



vulnerable to wind power Zoology at BAS; Green Balkans Federation; publications

Known nests of other of EU threatened species Orange BSPB; Institute of Zoology at BAS; publications

Suitable habitats for globally threatened species, where species have been observed

Orange

Breeding Bird Atlas; BSPB

Suitable habitats for EU threatened species, highly vulnerable to wind power, where species have been observed

Orange

Suitable habitats for EU threatened species, where species have been observed

Yellow

3.1.7. Avoid impacts on areas of reintroduction of globally and EU protected bird species

Areas for reintroduction of Griffon Vulture (Gyps fulvus)

Orange / Yellow

Green Balkans Federation; Birds of

Prey Protection Society, Fund for Wild

Flora and Fauna

3.1.8. Avoid impacts on Important Bird Areas Important Bird Areas Red BSPB

3.1.9. Avoid impacts on areas around the boundaries of protected territories, specifically designated for bird protection

Protected territories, specifically designated for bird protection - buffer

Orange MoEW

3.4 Reduce the risk of potential impact on


Special Protection Areas (SPAs) – designated with explicit prohibition for wind power development

Black MoEW

Special Protection Areas (SPAs) – designated without Red MoEW


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SER Objective



NATURA 2000 sites.

explicit prohibition for wind power development

Special Protection Areas (SPAs) – expected to be designated with explicit prohibition for wind power development

Red with Black stripes MoEW

More information about the data gaps, data quality and data sources on bird species and birds related areas is presented in Appendix D3.

Figure 6 presents a map of all identified bird species and birds related areas constraints to wind power development in Bulgaria. Nevertless, it is important to mention that some areas, such as the Protected Territories are also important for definig bird’s constraints. However, since these areas are designated for different reasons, not only birds related issues, it was Consortium decision to include them in the previous Figure 5 and not repeat the layer in Figure 6. Nevertheless, due to the strict relation that exists between Figure 5 and Figure 6 layers and their complexitiy, it was decided by the Consortium to create a combined Fauna, Flora and Biodiversity map as shown in Figure 7. Figure 7.1 shows the legend of Figure 7.

Legend:

Fauna, Flora & Biodiversity (including bird species and birds related areas) Spatial Constraints Analysis - Legend

FIGURE 7.1Bulgaria

Title:

Rev.: PW/MC

Location:




Color

Key Data Set Data Source

Breeding areas - buffer zones around known breeding areas of globally threatened species

Imperial Eagle (Aquila heliaca)

Bulgarian Society for the Protection of Birds (BSPB) + Publications

Egyptian Vulture (Neophron percnopterus) Nests occupied after 2000 BSPB + Publications

Egyptian Vulture (Neophron percnopterus) Nests occupied 1990-2000

BSPB+ Publications

Egyptian Vulture (Neophron percnopterus)

Nest occupied before 1990 BSPB + Publications

Saker Falcon (Falco cherrug) BSPB + Publications

Red-footed Falcon (Falco vesperinus) BSPB

Breeding areas - buffer zones around known breeding areas of EU level threatened species

Griffon Vulture (Gyps fulvus) BSPB + Publications

Black Stork (Ciconia nigra) BSPB + Institute of Zoology at BAS (P.

Shurulinkov) + Publications

Honney Buzzard (Pernis apivorus)

Black Kite (Milvus migrans)

White-tailed Eagle (Haliaeetus albicilla)

BSPB + Green Balkans +

Publications

Short-toed Eagle (Circaetus gallicus) Institute of Zoology at BAS (P. Shurulinkov) Marsh Harrier (Circus aeruginosus)

Montagu’s Harrier (Circus pygargus)

BSPB + Institute of Zoology at BAS (P.


Levant Sparrowhawk (Accipiter brevipes)

Long-legged Buzzard (Buteo rufinus)

Lesser Spotted Eagle (Aquila pomarina)

Golden Eagle (Aquila chrysaetos)

Booted Eagle (Hieraaetus pennatus) Institute of Zoology at

BAS (P. Shurulinkov)

Peregrine Falcon (Falco peregrinus) BSPB + Publications

Capercallie (Tetrao urogallus) BSPB + Publications

Eagle Owl (Bubo bubo)


Shurulinkov) + publications

Breeding areas – suitable habitats for EU level threatened species, where species have been observed


BSPB + Publications


White-tailed Eagle (Haliaeetus albicilla)

Short-toed Eagle (Circaetus gallicus)

Marsh Harrier (Circus aeruginosus)

Montagu’s Harrier (Circus pygargus)

Levant Sparrowhawk (Accipiter brevipes)

Long-legged Buzzard (Buteo rufinus)


Golden Eagle (Aquila Chrysaetos)

Booted Eagle (Hieraaetus pennatus)

Osprey (Pandion haliaetus)

Peregrine Falcon (Falco peregrinus)

Color Key Data Set Data Source

Breeding areas – suitable habitats for globally threatened species, where species

have been observed

Corncrake (Crex crex)

BSPB + Publications Red-footed Falcon (Falco vesperinus)

Migration, roosting, staging and wintering areas

Migration bottlenecks along Via Pont ica route – well studied BSPB + Institute of Zoology at BAS (N. Karaivanov and P.


Migration along Via Pontica route – insufficiently studied

Other migration routes - insufficiently studied

Migration, roosting and wintering sites for storks, raptors and other birds Known roosting sites of White stork (Ciconia ciconia), White Pelican (Pelecanus onocrotalus), Dalmatian Pelican (Pelecanus crispus) and Raptors

BSPB + Publications

Staging areas of Imperial Eagle (Aquila heliaca) Areas where specie spends considerable time

BSPB + Green Balkans

Staging areas of Imperial Eagle (Aquila heliaca) Flying corridors


Staging areas of Black Vulture (Aegypius monachus) Green Balkans

Staging areas of Saker Falcon (Falco cherrug) Areas where specie spends considerable time BSPB

Staging areas of Saker Falcon (Falco cherrug) Flying corridors BSPB

Staging areas of Red-breasted Goose (Branta ruficollis) Feeding areas - well studied BSPB + publications

Staging areas of Red-breasted Goose (Branta ruficollis) Feeding area - requiring further studies

BSPB + publications

Staging areas of Dalmatian Pelican (Pelecanus crispus)

Institute of Zoology at BAS (P.

Shurulinkov)

Known wintering areas of geese BSPB + Publications

Waterfowl congregations and colonies

Wetlands, which are Ramsar sites, IBAs for waterfowls, or which have concentration of globally threatened species

BSPB + Publications Wetlands with more than 1% of the national population of Annex 1 species - regularly used

Wetlands with more than 1% of the national population of Annex 1 species - irregularly used

Bird colonies: Colonies of A. purphiea, P. falcinellus, Ph. carbo, H. pygnaetus, A. cinerea, P. leucorodia, N nycticorix, E. garzetta, A. ralloides

BSPB + IZBAS (P. Shurulinkov) + Publications


Natura 2000 SPA: Atanasovsko ezero, Vrachanski Balkan, Emine, Kaliakra, Kamenski bair, Complex Ropotamo, Zaliv Chengene skele, Ostrov Vardim, Ostrov Golya, Ostrov Tsibar, Ostrov Ibisha, Ostrov Lakat, Ostrov Pozharevo, Pomoriysko ezero, Ribarnitsi Mechka, Ribarnitsi Plovdiv, Yazovir Konush Melnishki piramidi, Derventski vazvisheniya, Durankulashko ezero, Shablenski ezeren complex , Rupite, Kresna

MoEW

Natura 2000 SPA expected to be published in SG: Mandra-poda, Sakar, Balchik, Belite skali, Batova, Galata, Varnensko-Beloslavsko ezero, Kamchiyska planina, Complex Kamchia, Zapaden Balkan (above 800m elevation), Bakarlaka, Trigrad-Mursalitsa, Vasiliovska planina, Mesta

Rest of proposed and designated SPAs

Important Bird Areas BSPB

Protected territories designated for bird protection MoEW + EEA

website

Areas of reintroduction of globally threatened or EU level threatened species

Reintroduction areas for globally threatened species (reintroduction expected within 1 year) Griffon Vulture (Gyps fulvus)

Green Balkans Federation, Birds of Prey Society, WFFS


Areas with high conservation importance for bats

National Museum of Natural History (B. Petrov)


NMNH (B. Petrov)


NMNH (B. Petrov)







Bear and wolf bottleneck sites outside pSCI/SCI NATURA 2000


Proposed plant microreserves Institute of Botany at BAS

Important plant areas Institute of Botany at BAS


and Water (MoEW)



Forests with high biodiversity value Bulgarian Society for the

Protection of Birds (BSPB)

Non fragmented large forest landscapes

WWF Bulgaria




Color Key:





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7.3.5 Soil and Water The descriptions of the identified areas of constraint in relation to the soil and water aspects are summarized in Table 34:

Table 34 Soil and Water

SER Objective


constraint Level of




4.1.1. Minimise the contribution to soil erosion.

Not suitable for spatial analysis


4.2.1. Minimise the mobilization of anthropogenic contaminants during construction.

Contaminated areas White

Regulation on the inventarization and investigations of areas with contaminated soils, required reclamation measures, as well as the maintenance of the implemented reclamation activities

Not Available


4.3.1. Minimise the area of soil resources with significant economic value which land use has been changed as a result of wind power development (ha).

Agricultural land – category I to IV

Yellow

Proposal for a law for amendment and supplementation of the Protection of Agricultural Lands Act, art. 23, new par. 2

Ministry of Agriculture and Food



4.4.1 Minimise the impacts on water quality of surface water bodies. 4.4.2 Minimise the impacts on water quality of groundwater water bodies.

Sanitary Water Protection zones I

Black

Ordinance 3 for the conditions and order of investigation, designing, approval and operation of the sanitary protection zones around the water sources and the potable water supply facilities… (SG issue 88/2000), art. 8

Basin Directorates


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Sanitary Water Protection zones II

and III

Red Orange Yellow

Ordinance 3 from 16.10.2000 for the conditions and order of investigation, designing, approval and operation of the sanitary protection zones around the water sources and the potable water supply facilities… (SG issue 88/2000), art. 10 par. 1, Annex 1, item 2

Basin Directorates

Table 35 summarizes the justification for designating the respective level of constraint in the provided data sets:

Table 35 Justification for designating the respective level of constraint for Soils and Water

Contaminated areas

Assigned as areas with no or unknown sensitivity to wind power development. In order to minimize the impacts on sensitive areas, wind power development should be encouraged in areas with significant anthropogenic alteration, including areas contaminated by industrial activities. There are even possibilities where wind power can contribute to the improvement of contaminated land conditions, such as by generating power required to drive remedial equipment, or by covering the land and thereby protecting the underlying contaminated soil from leaching by infiltrating rainwater. Therefore, contaminated areas are classified as having no sensitivity to wind power development.

Agricultural land – Category I, II, II and IV

Assigned as areas with low sensitivity to wind power development. According to the newest proposed amendments to the Agricultural Lands Protection Act, agricultural lands category 1st to 4th are expected to become prohibited for wind power development soon. The amendments to the act were approved in April 2010 by the Council of Ministers and now have to be voted in the Parliament. As shown in Section 6.1.4, the potential impact of wind power on soils with high economic value is assessed as being partial negative and because of that a low level of sensitivity has been assigned to agricultural lands category 1st to 4th. However, given the potential that the referred areas may become unavailable for wind power development if the amendments to the act are approved by the Bulgarian parliament, these areas have been assigned a special intermediate level, only applicable for this particular case - low sensitivity level (yellow) with black overlaying stripes. As this layer was not provided during the elaboration of this Final Report, these areas were not included in the final spatial constraints analysis.

Sanitary water protection zones

The land use of sanitary water protection zones is regulated under Ordinance 3/16.10.2000 for the conditions and order of investigation, designing, approval and operation of the sanitary-protective zones around the water sources and the potable water supply facilities and around the mineral water sources that are used for medicinal, preventive, potable and hygienic purposes. According to art. 8 (2), in sanitary water protection zone I only activities related to the water source and/or operation of the water


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Table 35 Justification for designating the respective level of constraint for Soils and Water

facilities are allowed. According to Annex 1 of the ordinance, in sanitary protection zones II around surface water sources, the construction of aboveground and underground facilities is restricted, with the exception of reconstruction and modernization of the main water supply facilities, while there are no such restrictions for zone III. According to Annex 2, in sanitary protection zones II around underground water sources, all activities which damage the integrity of the watertight layer above the underground water body are prohibited. In zones III around underground water sources those activities are restricted.

These areas are assigned with the following levels of sensitivity:

• Sanitary protection zones I around both underground and surface water sources - areas with explicit legislative prohibition for wind power development;

• Sanitary protection zones II around surface water sources – areas with high sensitivity to wind power development;

• Sanitary protection zones II around underground water sources – areas with high sensitivity to wind power development;

• Sanitary protection zones III around surface water source – areas with low sensitivity to wind power development;

Sanitary protection zones III around underground water sources – areas with medium sensitivity to wind power development.

More information about identified areas of constraint in relation to soil and water aspects is presented in Appendix D4.

Figure 8 displays the map of the available information regarding sanitary water protection zones in Bulgaria.

Soil and Water - Spatial Constraints Analysis

FIGURE 8Bulgaria

Title:

Rev.: PW/MC

Location:




Legend:


Sanitary protection zones I Basin Directorates – Pleven, Plovdiv and

Blagoevgrad

Sanitary protection zones II Basin Directorate

Blagoevgrad

Sanitary protection zones III around underground water sources

Basin Directorate Blagoevgrad

Sanitary protection zones III around surface water source





Color Key:




Note:








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7.3.6 Landscape The spatial constraints analysis for Landscape SER Objectives and indicators was not performed due to the following:

• SER indicator 5.1.1 Minimise the impacts on land use and land use change: can be spatially analyzed only if detailed maps would be available to show changes in land use patterns that might be associated to the introduction of wind energy over the last decade. However, no such maps are currently available in Bulgaria.

• SER indicator 5.1.2 Minimise the impacts on landscape sensitivity, vulnerability and resistance of landscape units: refers to the ecological notion of the term “landscape” and is difficult to quantify.

• SER indicator 5.2.1. Distance of wind power developments to protected zones, protected territories, tourist areas and recreation areas: is very site-specific – it depends on the topography of the area, the particular value of the site, the size, design, layout and color of the wind turbines, etc. Therefore, it cannot be spatially analyzed at the national level. Such analysis should be carried out at the location of each individual wind power project, as part of the EIA.

• SER indicator 5.2.2. Minimize the loss of aesthetic values: is also site specific and should be addressed as part of the EIA process of each individual wind power project.


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7.3.7 Public health, noise and vibration Table 36 presents the degree to which spatial analyses are applied to public health, noise and vibration SER objectives and indicators:

Table 36 Public health, noise and vibration

SER Objective


constraint Level of



6.1 Reduce the risk of impact from noise caused by the interaction of the turbine blades with the wind.

6.1.1. Minimum distance of wind power developments from settlements.

500m buffer zone around boundaries of

settlements Black

Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy (SG issue 73/2006), art. 141

CORINE Landcover 6.2 Reduce the risk of potential impact on public health due to shadow flicker effect.

6.2.1. Minimum distance and orientation of wind power developments in relation to settlements.

Table 37 summarizes the justification for designating the respective level of constraint in the provided data set:

Table 37 Justification for designating the respective level of constraint for Public Health, Noise and Vibration

Buffer zone around

boundaries of settlements

Assigned as areas with explicit legislative prohibition for wind power development. According to art. 141 from the Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy, wind power turbines should be at least 500 meters away from the territory of the closest settlement. Wind power development is forbidden in the buffer zone of 500 m from the boundaries of all settlements in Bulgaria.

In countries all over Europe such as Spain (except for some regions) and the Netherlands, there is no minimum mandatory distance from human settlements and wind power installations. It is recommended not to fix a specific minimum distance between human settlements and wind turbines. This distance should be decided according to the EIA and based on noise, shadow flicker effect and landscape considerations.

It is recommended that small size domestic wind turbines should be allowed on human settlements and all other wind power installations should be studied case by case in order to be authorized.

The most accurate data on settlement boundaries is present at the Cadastre Agency and the Ministry of Agriculture and Food. Since neither of them provided any infromation before the end the elaboration of this Final Report, buffer zones were defined using Class 1 CORINE Landcover.


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More information about identified areas of constraint in relation to the public health, noise and vibration aspects is presented in Appendix D5.

In order to visually represent the constraint above mentioned it was decided to combine it with constraint identified under the socio-economic and materials assets (Section 7.3.8.) topic since the data set used is the same. Nevertheless, for the creation of buffer zones only settlements were considered. Figure 9 displays the map of the available information regarding constraints identified on public health, noise and vibration and socio-economic and materials assets.

7.3.8 Socio-economic and material assets The identified Socio-Economic and Material Assets SER Objectives and their respective indicators cannot be analyzed spatially due to:

- their unsuitability for spatial analysis, namely:

• 7.1.1. Real estate values in areas affected by wind power development prior to and after the implementation of wind projects; • 7.2.1. Impact of wind power development on employment; • 7.2.2. Impact of wind power development on regional GDP; • 7.3.1. Coordination of wind power investment projects with existing economic regional development plans; • 7.4.1. Electromagnetic interference levels prior to and after implementation of wind projects. - lack of detailed information, namely: • 7.5.1. Length of power transmission and road infrastructure subject to construction, rehabilitation or modernization associated with wind-energy projects.

Nonetheless, it is important to include in the analysis social constraints that can represent or indicate constraints of importance to future wind power developments. The best available information on for this issue was derived from CORINE Landcover layer for Class 1, although this information is not specific related to these SER objectives or indicators.

Table 38 summarizes the justification for designating the respective level of constraint in the used data set:

Table 38 Justification for designating the respective level of constraint for Socio-Economic and Material Assets

Class 1 from the CORINE Landcover

(settlements)

Assigned as areas with explicit legislative prohibition to wind power development. According to art. 141 from the Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy, wind power turbines should be at least 500 meters away from the territory of the closest settlement. Wind power development is forbidden in the buffer zone of 500 m from the boundaries of all settlements in Bulgaria.

Class 1 from the CORINE Landcover database contains all major elements of the artificial surfaces: continuous urban fabric, discontinuous urban fabric, industrial or commercial units, road and railroad networks and associated land, port areas, airports, mineral extraction sites, dump sites, construction sites, green urban areas, sport and leisure facilities. All these site types have different restrictions for construction of industrial installations, including wind power turbines in their close proximity (governed by different legislative acts) – around some of them wind power development may be prohibited while around others it may be restricted in one way or another.

Therefore, according to the current legislation it can be concluded that wind power development


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More information about identified areas of constraint in relation to the socio-economic and materials assets aspects is presented in Appendix D6. Figure 9 displays the map of available information regarding to constraints identified in Public Health, Noise and Vibration and Socio-Economic and Materials Assets.

is prohibited in the settlement areas (represented in the available data set by continuous urban fabric and discontinuous urban fabric), while in the rest of the urbanized areas wind power development may or may not be allowed.

The most accurate data on settlement boundaries is present at the Cadastre Agency and the Ministry of Agriculture and Food. Since neither of them provided any infromation before the end the elaboration of this Final Report, buffer zones were defined using Class 1 CORINE Landcover.

Public Health, Noise and Vibration and Socio-economic and Material Assets Spatial Constraints Analysis

FIGURE 9Bulgaria

Title:

Rev.: PW/MC

Location:




Legend:


Settlements (Class I from CORINE Landcover) and 500m buffer zone around sett lement boundaries

Ministry of Regional Development and Public

Works Website




Color Key:




Note:








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7.4 Summary of Constraints Analysis Some of the information presented in Section 7.3 is summarized in Table 39 below. This table includes only these areas of constraint which are suitable for spatial analysis and for which data was available.

Table 39 Summary of Constraints Spatial Analysis

Data set # Spatial areas of constraint Sensitivity

level Color

designation Availability

Energy, climate and air quality

Not suitable for spatial analysis.

Cultural heritage

1 World Heritage Properties Prohibited Available

Flora, fauna and biodiversity

2

Areas with high conservation importance areas for bats

Areas with medium conservation importance areas for bats

Areas with low conservation importance areas for bats

High

Medium

Low

Available

3 Annex I habitats in pSCI/SCI NATURA 2000 zones

High

Available

4 Habitats of Annex II species in pSCI/SCI NATURA 2000 zones

High

Available

5 Bear and wolf avoidance in pSCI/SCI NATURA 2000 zones

High

Available

6 Bear bottleneck sites outside pSCI/SCI NATURA 2000 zones

Medium

Available

7 Proposed plant microreserves Low Available 8 Important plant areas Low Available

9

Protected Territories:

Strict nature reserves, Managed reserves, National parks

Natural parks, Protected sites, Natural monuments

Prohibited

High

Available

10 NATURA 2000 – pSCI/SCI Medium Available 11 Forests with high biodiversity value Medium Available 12 Non fragmented large forest landscapes Low Available


13 Migration routes: Available


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level Color


Migration bottlenecks along Via Pontica route – well studied


Other migration routes – insufficiently studied

High

Medium

Low

14

Known roosting sites of White stork (Ciconia ciconia), White Pelican (Pelecanus onocrotalus), Dalmatian Pelican (Pelecanus crispus) and Raptors

High

Available

15

Staging areas of Imperial Eagle (Aquila heliaca)

Areas where specie spends considerable time

Flying corridors

High

Medium

Available

16 Staging areas of Black Vulture (Aegypius monachus)

High

Available

17

Staging areas of Saker Falcon (Falco cherrug)

Areas where specie spends considerable time

Flying corridors

High

Medium

Available

18

Staging areas of Red-breasted Goose (Branta ruficollis)

Feeding areas - well studied

Feeding area - requiring further studies

High

Medium

Available

19 Staging areas of Dalmatian Pelican (Pelecanus crispus)

High

Available

20 Known wintering areas of geese High Available Waterfowl congregations and colonies

21

Wetlands with high waterfowl concentration:

Ramsar sites, IBAs for waterfowls, concentration of

globally threatened species

More than 1% of the national population of Annex 1

species – regularly used; insufficiently studied areas

More than 1% of the national population of Annex 1

High

Medium

Low

Available


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ES11BUL001 118



level Color


species – irregularly used

22

Colonies of A. Purphiea, P. Falcinellus, Ph. Carbo, H. Pygnaetus, A. Cinerea, P. Leucorodia, N nycticorix, E. Garzetta, A. Ralloides

High

Available

Breeding areas - buffer zones around know breeding areas of globally threatened species

23 Imperial Eagle (Aquila heliaca) High Available

24

Egyptian Vulture (Neophron percnopterus)

Nests occupied after 2000

Nests occupied 1990-2000

Nest occupied before 1990

High

Medium

Low

Available

25 Saker Falcon (Falco cherrug) High Available 26 Red-footed Falcon (Falco vespertinus) High Available


27 Griffon Vulture (Gyps fulvus) High Available 28 Black Stork (Ciconia nigra) Medium Available 29 Honney Buzzard (Pernis apivorus) Medium Available 30 Black Kite (Milvus migrans) Medium Available 31 White-tailed Eagle (Haliaeetus albicilla) High Available 32 Short-toed Eagle (Circaetus gallicus) Medium Available 33 Marsh Harrier (Circus aeruginosus) Medium Available 34 Montagu’s Harrier (Circus pygargus) Medium Available 35 Levant Sparrowhawk (Accipiter brevipes) Medium Available 36 Long-legged Buzzard (Buteo rufinus) Medium Available 37 Lesser Spotted Eagle (Aquila pomarina) Medium Available 38 Golden Eagle (Aquila chrysaetos) High Available 39 Booted Eagle (Hieraaetus pennatus) Medium Available 40 Peregrine Falcon (Falco peregrinus) Medium Available 41 Capercallie (Tetrao urogallus) Medium Available 42 Eagle Owl (Bubo bubo) Medium Available

Breeding areas – suitable habitats for globally threatened species, where species have been observed

43 Corncrake (Crex crex) Medium Available


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level Color


44 Red-footed Falcon (Falco vesperinus) Medium Available Breeding areas – suitable habitats for EU level threatened species, where species have been observed

45 Honney Buzzard (Pernis apivorus) Low Available 46 Black Kite (Milvus migrans) Low Available 47 White-tailed Eagle (Haliaeetus albicilla) Medium Available 48 Short-toed Eagle (Circaetus gallicus) Low Available 49 Marsh Harrier (Circus aeruginosus) Low Available 50 Montagu’s Harrier (Circus pygargus) Low Available 51 Levant Sparrowhawk (Accipiter brevipes) Low Available 52 Long-legged Buzzard (Buteo rufinus) Low Available 53 Lesser Spotted Eagle (Aquila pomarina) Low Available 54 Golden Eagle (Aquila chrysaetos) Medium Available 55 Booted Eagle (Hieraaetus pennatus) Low Available 56 Osprey (Pandion haliaetus) Medium Available 57 Peregrine Falcon (Falco peregrinus) Low Available


58 Griffon Vulture (Gyps fulvus) – reintroduced within 1 year

Medium

Available


59 Important Bird Areas High Available

60

NATURA 2000 SPA:

Atanasovsko ezero, Vrachanski Balkan, Emine, Kaliakra, Kamenski bair, Complex Ropotamo, Zaliv Chengene skele, Ostrov Vardim, Ostrov Golya, Ostrov Tsibar, Ostrov Ibisha, Ostrov Lakat, Ostrov Pozharevo, Pomoriysko ezero, Ribarnitsi Mechka, Ribarnitsi Plovdiv, Yazovir Konush, Melnishki piramidi, Derventski vazvisheniya, Durankulashko ezero, Shablenski ezeren complex , Rupite, Kresna

Prohibited

Available

NATURA 2000 SPA expected to be published in SG:

Mandra-poda, Sakar, Balchik, Belite skali, Batova, Galata, Varnensko-Beloslavsko ezero, Zapaden Balkan (above 800m), Kamchiyska planina, Kompleks

High


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level Color


Kamchiya, Bakarlaka, Trigrad-Mursalitsa, Vasiliovska planina, Mesta

Rest of proposed and designated SPAs High

61 Protected territories designated for bird protection

Medium

Available

Soil and water

62

Sanitary protection zones I

Sanitary protection zones II



Prohibited

High

Medium

Low

Available

Partly available

Landscape

Not suitable for spatial analysis.

Public health, noise and vibration

63 Buffer zone around settlement boundaries Prohibited Available

Socio-economic and material assets

64 Class I from CORINE Landcover - settlements

Prohibited

Available


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7.5 Composite Constraints Analysis The final stage of spatial constraint analysis was the aggregation of all constraints in order to understand the level of environmental and social sensitivity that Bulgaria is subject to in relation to wind power development. It is important to mention that this analysis is based on certain assumptions (mentioned in Section 7.2, 7.6 and Annex D of this report), as well as on the best available information.

A map with all areas with explicit legislative prohibition for wind power development is presented in Figure 10. According to the available information, it is expected that more areas, such as the new SPA´s areas or the Agricultural lands – categories I, II, III and IV, might be included in this map in the future.

Moreover, a composite map has been produced based on the sensitivity levels defined in the previous sections. The combined map indicates the range of environmental and social sensitivities to wind power development in Bulgaria and rates vulnerability from explicit legislative prohibition to no or unknown sensitivity to wind power development.

All data sets are overlaid in a decreasing order of their sensitivity. All data sets (or parts of data sets) for which there is an explicit legislative prohibition for the development of wind power are placed “on top” of all other data sets, followed by all data sets (or parts of data sets) which have high sensitivity and so forth. This approach leaded to a composite map, in which each area of the map is depicted with the colour of the data set with has the highest sensitivity level.

Figure 11 displays a composite map of the available information regarding to all the constraints identified as describe in the previous sections. Figure 11.1 presents the key to the aggregated map with the level of vulnerability for all the data sets that were used in this composite analysis.

It is important to reiterate that this analysis should not be seen as a final product. Even though the analysis is based on the best scientific data that was available to the Consortium regarding the social and environmental issues that may be affected by wind power development, the information should be cross-checked and validated by experts from the MoEW. As was indicated above, the MoEW should consider establishing workgroups with regional and national experts to review periodically the grounds of the sensitivity classification. Additional information will become available in the future and may modify the current interpretation of the sensitivity of certain areas.

The database and its interpretation, as described in this report, are intended to be the starting point for a dynamic policy development program that should safeguard in the best way the interests of Bulgarian society and the country’s natural heritage.

Areas with explicit legislative prohibition for wind power development - Spatial Constraints Analysis

FIGURE 10Bulgaria

Title:

Location:



Date: June 2010Drawn: TL/DD/JS Rev.: PW/MC

Legend:Color Key



Natura 2000 SPA: Atanas ovsko ezer o, Vrachanski Balkan, Emine, K aliakra, K amenski bai r, Complex Ropotamo, Zal iv Chengene skele, Ostrov Vard im, Ostr ov Golya, Ostrov Tsibar, Ostrov Ibisha, Ostrov Lak at, Os trov Pozhar evo, P omoriysk o ezero, Ribarn itsi Mechka, Ribarni tsi Plovdiv, Yazovi r K onush Meln ishki p iramidi , Derventski v azvisheniya, Durankulashko ezer o,

Shablenski ezeren c omplex , Rupite, Kresna Ministry of Environment and Water (MoEW)

Natura 2000 SPA expected to be published in SG: Mandra-poda, Sakar, Balchik, Belite skali, Bat ova, Galata, Varnensko-Beloslavsko ezero, Kamchiyska planina, Complex Kamchia, Zapaden Balkan (above 800m elevation), Bakarlaka,

Trigrad-Mursalitsa, Vasiliovska planina, Mest a

Areas specifically designated for fauna, flora and biodiversity protection

Protected Territor ies: Str ict nature reserves, Managed reserves, N ational parks MoEW

Areas specifically designated for soil and water protection

Sanit ary protection zones I Basin Directorates – Pleven, Plovdiv and

Blagoevgrad

Areas specifically designated for Public Health, Noise and Vibration and Socio-economic and Mater ial Assets protection

Settlements (Class I from CORINE Landcover) and 500m buffer zone around settlement boundaries

Ministry of Regional Development and

Public Works W ebsite Areas specifically designated for World Cultural Her itage protection

World Herit age Properties UNESCO Websit e




Color Key:




Note:







Legend:

Composite Map - Spatial Constraints Analysis - Legend

FIGURE 11.1Bulgaria

Title:

Rev.: PW/MC

Location:







Color Key:




Birds species and birds related areas Color Key Data Set Data Source

Breeding areas - buffer zones around known breeding areas of globally threatened species

Imperial Eagle (Aquila heliaca) Bulgarian Society for

the Protection of Birds (BSPB) + Publications

Egyptian Vulture (Neophron percnopterus) Nests occupied after 2000

BSPB + Publications

Egyptian Vulture (Neophron percnopterus) Nests occupied 1990-2000 BSPB+ Publications

Egyptian Vulture (Neophron percnopterus) Nest occupied before 1990 BSPB + Publications

Saker Falcon (Falco cherrug) BSPB + Publications

Red-footed Falcon (Falco vesperinus) BSPB


Griffon Vulture (Gyps fulvus) BSPB + Publications

Black Stork (Ciconia nigra) BSPB + Institute of Zoology at BAS (P.




White-tailed Eagle (Haliaeetus albic illa)

BSPB + Green Balkans +

Publications

Short-toed Eagle (Circaetus gallicus) Institute of Zoology at BAS (P. Shurulinkov) Marsh H arrier (Circus aeruginosus)

Montagu’s Harrier (Circus pygargus )



Levant Sparrowhawk (Acc ipiter brev ipes)

Long-legged Buzzard (Buteo rufinus )


Golden Eagle (Aquila chrysaetos)

Booted Eagle (H ieraaetus pennatus) Institute of Zoology at

BAS (P. Shurulinkov)

Peregrine Falcon (Falco peregrinus ) BSPB + Publications

Capercallie (Tetrao urogallus) BSPB + Publications

Eagle Owl (Bubo bubo)



Breeding areas – suitable habitats for EU level threatened species, where species have been observed


BSPB + Publications


White-tailed Eagle (Haliaeetus albic illa)

Short-toed Eagle (Circaetus gallicus)

Marsh H arrier (Circus aeruginosus)

Montagu’s Harrier (Circus pygargus )

Levant Sparrowhawk (Acc ipiter brev ipes)

Long-legged Buzzard (Buteo rufinus )


Golden Eagle (Aquila Chrysaetos)

Booted Eagle (H ieraaetus pennatus)

Osprey (Pandion haliaetus)

Peregrine Falcon (Falco peregrinus )

Color Key


Breeding areas – suitable habitats for globally threatened species, where species have been observed

Corncrake (Crex crex)

BSPB + Publications Red-footed Falcon (Falco vesperinus)


Migration bottlenecks along Via Pont ica rout e – well studied BSPB + Institute of Zoology at BAS (N. Karaivanov and P.

Shurulinkov) + publicat ions


Other migration routes - insufficiently studied

Migration, roosting and wint er ing sites for storks, raptors and other birds Known roosting sites of White stork (Ciconia ciconia), White Pelican (Pelecanus onocrotalus), Dalmatian Pelican (Pelecanus cr ispus) and Raptors

BSPB + Publications

Staging areas of Imperial Eagle (Aquila heliaca) Areas where specie spends considerable time


Staging areas of Imperial Eagle (Aquila heliaca) Flying corridors


Staging areas of Black Vulture (Aegypius monachus) Green Balkans

Staging areas of Saker Falcon (Falco cherrug) Areas where specie spends considerable time BSPB

Staging areas of Saker Falcon (Falco cherrug) F lying corridors BSPB

Staging areas of Red-breast ed Goose (Branta ruficollis) Feeding areas - well studied BSPB + publicat ions

Staging areas of Red-breast ed Goose (Branta ruficollis) Feeding area - requiring further studies

BSPB + publicat ions

Staging areas of Dalmatian Pelican (Pelecanus crispus)

Institute of Zoology at BAS (P.

Shurulinkov)

Known winter ing areas of geese BSPB + Publications


Wetlands, which are Ramsar sit es, IBAs for w aterfowls, or which have concentration of globally threatened species

BSPB + Publications Wetlands with more than 1% of the national population of Annex 1 species - regularly used

Wetlands with more than 1% of the national population of Annex 1 species - irregularly used

Bird colonies: Colonies of A. purphiea, P. falcinellus, Ph. carbo, H. pygnaetus, A. cinerea, P. leucorodia, N nycticor ix, E. garzetta, A. ralloides

BSPB + IZBAS (P. Shurulinkov) + Publications


Natura 2000 SPA: Atanasovsko ezero, Vrachanski Balkan, Emine, Kaliakra, Kamenski bair, Complex Ropotamo, Zaliv Chengene skele, Ostrov Vardim, Ostrov Golya, Ostrov Tsibar, Ostrov Ibisha, Ostrov Lakat, Ostrov Pozharevo, Pomoriysko ezero, Ribarnitsi Mechka, Ribarnitsi Plovdiv, Yazovir Konush Melnishki piramidi, D erventski vazvisheniya, Durankulashko ezero, Shablenski ezeren complex , Rupite, Kresna

MoEW

Natura 2000 SPA expected to be published in SG: Mandra-poda, Sakar, Balchik, Belite skali, Batova, Galata, Varnensko-Beloslavsko ezero, Kamchiyska planina, Complex Kamchia, Zapaden Balkan (above 800m elevation), Bakarlaka, Trigrad-Mursalitsa, Vasiliovska planina, Mesta

Rest of proposed and designated SPAs

Important Bird Areas BSPB

Protected territories designated for bird protection MoEW + EEA

website


Reintroduction areas f or globally threatened species (reintroduction expected within 1 year) Griffon Vulture (Gyps fulvus)

Green Balkans Federation, Birds of Prey Society, WFFS

Fauna Flora and Biodiversity Color


Areas with high conservation importance for bats

National Museum of Natural History (B. Petrov)


NMNH (B. Petrov)


NMNH (B. Petrov)



Habitats of Annex II species in pSCI/SCI NATURA 2000 zones Balkani Wildlife Society



Bear and wolf bottleneck sites outside pSCI/SCI NATURA 2000


Proposed plant microreserves Institute of Botany at BAS

Important plant areas Institute of Botany at BAS


and Water (MoEW)



Forests with high biodiversity value Bulgarian Society for the

Protection of Birds (BSPB)

Non fragmented large forest landscapes

WWF Bulgaria

World Cultural Heritage


World Heritage Properties UNESCO Website

Public Health, Noise and Vibration and Socio-economic and Material Assets


Settlements (Class I from CORINE Landcover) and 500m buffer zone around settlement boundaries

Ministry of Regional Development and Public

Works Website

Soil and Water Color


Sanitary protection zones I Basin Directorates – Pleven, Plovdiv and

Blagoevgrad

Sanitary protection zones II Basin Directorate Blagoevgrad






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ES11BUL001 125

7.6 Limitations of the performed spatial constraints analysis As described above, a large amount of data sets, related to the identified environmental and social topics, were compiled and analysed. Recognizing the importance that the quality of used data has for the final visual presentation of the spatial data and the spatial analysis which have been performed (or can be performed in the future), the issue of data quality has seriously been taken into consideration during this project.

The data quality and data gaps have been evaluated for each of the data sets, used in the spatial analysis. This information is presented in detail in Annex D of this report. Data gaps which have been identified in the current database include issues such as information regarding the bird migration patterns within the territory of Bulgaria, locations of the nests of some globally and EU protected bird species, and spatial information on the sanitary water protection zones in the Varna Basin Directorate. All stakeholders and readers of this report are encouraged to review Annex D, so that they can gain a better understanding of the extent and limitations of each data set.

Even though each data set has been examined, it should be noted that the Consortium cannot provide any further guarantees about the quality and accuracy of the collected data sets beyond the information supplied by the data providers and some general data verification conducted by the Consortium. The Consortium relies that if any major data deficiencies exist, they will be identified though the consultation process of the current report.

Additionally, should the Bulgarian Authorities choose to adopt the spatial constraint approach outlined in this report and utilize the collected database for future policy making or setting restrictions in particular areas, it is recommended that all data sets are carefully verified (polygon by polygon) and some data imperfections are eliminated (slightly overlapping adjacent polygons, gaps between adjacent polygons, etc.). Such detailed data verification was beyond the scope of work for this project.

Furthermore, it is recognized that the compiled database contains only information on the environmental and social constrains, while for the proper identification of areas suitable for wind power development, spatial information should be gathered also for other factors, such as wind potential, grid capacity and opportunities to connect to the grid, radar interference, etc. The scope and timeline of this project did not permit the detailed investigation of these additional data sets. However, preliminary conversations with representatives of governmental institutions, private companies and associations, active in the RES sector, have indicated that most of this information is not available, outdated or incomplete. In the absence of information on the wind potential and the grid carrying capacity, it is not possible to identify areas, which are most suitable for wind power development from technical, economical, environmental and social point of view.

It should be noted that the spatial database is compiled at the national level for a strategic environmental review and many of the datasets contain polygons which do not follow land plot boundaries. Therefore, the maps generated from this spatial database should be used primarily as guidance and cannot substitute the EIA process. The exception is for areas which have been designated with a legislative act with precise boundaries and where wind power development is explicitly prohibited. With regards to projects proposed in areas with high, medium and low levels of sensitivity, the Consortium strongly recommends that the EIA procedure is implemented with the level of detail and scrutiny described in Section 8.4 of this report.

The database that has been compiled for this project is being continuously expanded as additional information is provided and will continue to be enriched until the end of the consultation process for the draft SER report. In order for Bulgarian Authorities and investors in wind power to be able to base their policies and investment decisions on the best available science and information, this database should be regarded as a dynamic instrument that needs to be continuously updated as new


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information becomes available. Further studies are inevitably necessary in order to assess local conditions in specific areas and their real implications on local wind power development.

Data has been collected only for the territory of Bulgaria, and the compiled database will be useful primarily for onshore wind power developments. If off-shore wind projects are considered in the future, the database has to be further expanded with data covering the Bulgarian territorial waters of the Black Sea.

7.7 Recommendations for further spatial analysis Further analysis, which can be performed by MEET and/or MoEW in order to more fully assess the future wind power development could include:

• Estimation on the percentage of the territory occupied by each of the sensitivity levels, identified for the development of the current wind technology;

• Overlaying of the identified levels of sensitivity with spatial data on the wind potential in Bulgaria and identification of the areas which have economically viable wind resources and at the same time are with lower level of environmental and social sensitivity;

• Calculation of the wind power capacities which can theoretically be placed in areas which are suitable both from the point of view of the available resources and from the point of view of the existing environmental and social constraint. Such calculations may provide invaluable insight on the theoretical contribution of wind power to the overall RES mix in order for Bulgaria to comply and ever outperform its European and international commitments related to RES and indirectly to GHG emissions.

7.8 Spatial analysis of current wind power development in Bulgaria This section would not be complete without the spatial representation of the wind turbines in Bulgaria – this includes the already operational wind power projects, as well as wind power projects at various stages of the permitting process.

7.8.1 Data sources Information has been requested from the three electricity distribution companies (EON, EVN and CEZ) and the electricity transmission company (NEC) about the location of operational wind projects, as well as about the wind projects which have preliminary contracts for connection to the grid. The information was received by the four companies in tabular format. Even though, all four companies were requested the same information, the level of detail of the received information varied from one company to another. This provided information dates from March 2010.

In addition, information has been requested from all RIEWs about all wind power projects which have been approved by the RIEWs (either with a statement that do not require an EIA or with an approval of the conducted EIAs). This information was provided either in tabular format or as paper copies of the available documentation. The information was with varying level of detail not only from one RIEW to another but also from one project to another, within the same RIEW. Further information was obtained from the websites of the RIEWs where periodically information is posted about EIA decisions. It should be noted that there are wind power projects for which information was available on a RIEW website but they were not mentioned in the information provided officially by the respective RIEW. This provided information dates from December 2009.

Finally, neither the electricity distribution/transmission companies nor the RIEWs provided information about the coordinates of the wind turbines, so the turbines were located on a map with the use of the Cadastre map, which is publically available on the website of the Ministry of Regional Development


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and Public Works (MRDPW)70. Since this was the only way to localize wind turbines, only turbines for which there are land plot numbers could be mapped.

As already mentioned, the level of detail varies significantly from one data set to another, which significantly limited the spatial analysis.

7.8.2 Discussion on the available spatial data on planned and installed wind turbines in Bulgaria

According to the information officially provided by the RIEWs and according to the publically available information on internet about EIA decisions regarding wind turbines, it was found that in the period January 2003 – December 2009 at least 2.840 wind turbines were approved by the RIEWs in Bulgaria.

Out of these 2.840 approved wind turbines, 2.365 turbines (or 83%) have been approved by the RIEWs without an EIA - during the screening phase of the EIA process it was decided that an EIA was not needed. Most of the turbines approved without an EIA are described as either single turbines or small scale projects (up to 7 turbines), however, many of them are located on adjacent land plots and in some cases, the notifications for the construction of a series of turbines on adjacent plots have been submitted at about the same time. Therefore, the practice of project splitting seems to have been used in a number of occasions to split larger wind projects into smaller ones, in order to avoid the conduct of an EIA. Using this approach, wind farms with up to 70 wind turbines have been split into pieces and have been approved without an EIA. There are also cases where entire wind farms with up to 20 turbines have been processed as one project but have been approved without an EIA. There are also 33 approved turbines (of the 2.840) for which it is not clear what kind of decision has been taken by the corresponding RIEW. It is likely that these turbines have been approved without EIA.

In addition, there are 68 wind turbines with decisions for change in the General Spatial Plan or which have been reflected on the Cadastre map, but for which no information was provided by the RIEWs. Therefore, the total number of turbines which have been permitted is at least 2.908.

There is also information regarding 1.177 wind turbines which have to undergo EIA, 506 wind turbines for which notification has been submitted to the respective RIEW but no decision was taken as of December 2009. Therefore, the total number of planned turbines is

The breakdown of all turbines which have been approved or which are being processed by the RIEWs is presented in Table 40.

Table 40 Turbines approved or being processed by the RIEWs

Type of wind turbines Number of turbines Data sources

Turbines approved without EIA 2.365 Data provided by RIEWs

Turbines approved with EIA 442 Data provided by RIEWs

Turbines approved but unclear whether with or without EIA

33 Data provided by RIEWs

70 http://212.122.182.101/pmapper/bgmapsv31.phtml?winsize=small&language=bg&config=cadaster


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Table 40 Turbines approved or being processed by the RIEWs

Type of wind turbines Number of turbines Data sources

Turbines without information in RIEW but with approval by other competent authorities

68 Cadastre map at the MRDPW’s website

Turbines, which have to undergo EIA 1.177 Data provided by RIEWs

Turbines for which notification has been submitted at RIEW but no determination has been issued yet

506 Data obtained from RIEWs’ websites

Total approved wind turbines 4.591

Table 41 summarizes the information from CEZ, EON, EVN and NEC on the number of turbines - both installed/operational and with preliminary contracts for connection, which dates from March 2010.

Table 41 Number of turbines - both installed/operational and with preliminary contracts for connection

Company Installed/operational

wind turbines Wind turbines with preliminary

contracts for connection

CEZ 16 8

EVN 58 118

EON 122 ???

NEC 87 600

Total wind turbines 283 726*

* This aggregate number does not include information from EON because EON has not submitted information on the number of turbines with preliminary contracts – information has been submitted only about the capacity.

An attempt was made to compare the wind projects already approved or currently processed by the RIEWs with the installed/operational wind power projects and the wind projects with preliminary contract for connection. Such comparison proved to be not feasible for the following reasons:

• none of the electrical companies provided GPS data about wind turbine locations;

• the information provided by the electrical distribution companies often does not include the exact location of wind turbines (as land plot number);

• wind projects are often sold after all permits are obtained, so the names of the companies which have received the permits rarely match the names of the companies which operate/own the installed wind farms;

• the data provided by the RIEWs rarely include information on the capacity of the wind turbines, etc.


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Because of these gaps and insufficiencies of the provided data, the comparison between the planned and installed wind power capacities has been initiated but could not be completed. Such comparison will be possible only if there is a single database where all wind projects are tracked and updated – from the very beginning to the very end of the project.

In the process of comparing the two types of data sets (planned vs. installed/operational/contracted), it was found that there are cases where the RIEW has permitted a certain number of wind turbines (with a particular capacity), while the number and/or the capacity of the constructed or contracted turbines is larger.

7.8.3 Spatial representation of the planned wind turbines A GIS map was generated by localizing 3.681 wind turbines (80%) out of the 4.591 which are at various stages of the environmental permitting process. The remaining 20% of the wind turbines (mostly turbines for which notifications have been submitted to the RIEWs) could not be located on the Cadastre map because one of the following reasons:

• No infromation was provided by the RIEW regaring the land plot number, and/or • The land plot could not be located on the Cadastre map available on the MRDPW’s website,

either because the land plot number is inaccurate or because the land plot number has been changed but this has not been reflected in the Cadastre map available on the MRDPW’s website.

Table 42 shows the number of turbines of each type which have been included in the GIS map and the number which are not yet included.

Table 42 Number of turbines of each type which have been included in the GIS map and the number which are not yet included

Type of wind turbines

Number of turbines for

which there is information

Number of turbines

included in GIS map

% of turbines included in

GIS map

Turbines approved without EIA 2.365 1.911 80,8%

Turbines approved with EIA 442 441 99,8%

Turbines approved but unclear whether with or without EIA

33 29 87,9%


68 68 100,0%

Turbines, which have to undergo EIA 1.177 1035 87,9%


506 197 38,9%

Total number of turbines 4.591 3.681 80,2%

Figure 12 shows the GIS map with the wind turbines which have been spatially localized.

Spatial Representation of the Planned Wind Turbines

FIGURE 12Bulgaria

Title:

Rev.: PW/MC

Location:




Legend:

Turbines approved without EIA

Turbines approved with EIA

Approved turbines approved but unclear whether with or without EIA


Turbines which need to undergo EIA



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Due to the fact that maps are not fully complete and because of the presence of many data gaps, no further spatial analysis with the wind turbine locations has been conducted.

7.8.4 Discussion on the results of the spatial representation of the planned wind turbines

After analysing Figure 12, the following conclusions can be made.

• There is a very dense concentration of many wind projects in the North-Easter part of the country and most of the projects are located within the jurisdiction of a single RIEW (RIEW Varna). This by itself may not be problematic if the cumulative effects from all these planned installations are properly addressed. However, this dense concentration of so many wind projects in a relatively small area, combined with the poor state of the Bulgarian electricity transmission grid may give rise to problems for the electricity supply in the region, and the connection of all projects to the grid may also present technical difficulties.

• There is a disproportionate number of wind turbines which have been permitted without EIA (83%). Some of these projects are single turbines, others are large projects split in order to avoid the EIA and some are large projects for which the respective RIEWs have decided that EIA is not needed.

• The presence of so many projects in a relatively small area of the country, many of which have been permitted without an EIA testify that the cumulative effects, which these projects are likely to have on the environment, are not properly assessed, and in many cases not assessed at all.

• There has been an increase in the number of projects for which and EIA is required, which indicates that there has been a change in the manner in which the wind power projects are assessed by the RIEWs in Bulgaria. While this is a positive trend, there is a clear need for a improvement of the environmental over the implementation of wind power projects.

Even though this map contains only 80% of the wind turbines permitted or under review by the RIEWs, they provide a very good initial indication of the spatial allocation of wind projects in Bulgaria. The Consortium believes that this will be very useful to the MEET in the future strategic planning of the wind power in Bulgaria, as well as to the RIEWs and MOEW.


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8 Recommendations on future wind power development in Bulgaria

This section outlines recommended mitigation and monitoring measures which should be taken into account during development and implementation of new wind power projects in Bulgaria. This section also provides best practice guidance for undertaking Environmental Impacts Assessments (EIAs) in connection with proposed wind farm developments.

The recommendations have been compiled with the aim of increasing the Country’s capacity for generating sustainable wind power in the future.

8.1 Recommended mitigation measures This section outlines mitigation measures envisaged to prevent, reduce and as fully as possible offset any significant adverse effects on the Bulgarian environment arising from the development of wind power, as identified in Section 6 and Section 7.

The mitigation measures given in this section have been devised to avoid, reduce or off-set any likely significant adverse environmental effects of developing wind power. As this SER provides a strategic overview of developing wind power in Bulgaria in the future, the mitigation measures given in this report are intended for strategic planning purposes only. Therefore, more detailed EIA would need to be carried out, and bespoke mitigation measures devised, in connection with individual wind power development projects.

Accordingly, a generic approach to mitigation is given for each SER topic covered in this report, without consideration the significance of the effects, which can only be assessed in relation to specific projects on a case by case basis.

Mitigation measures can be generally divided into the following categories:

• Preventing or minimising impacts before they occur by limiting the extent or timing of an action and its implementation;

• Eliminating or reducing an actual impact over time by maintenance or contingency planning during the life of the project;

• Rectifying an impact by repairing, rehabilitating or restoring the affected environment;

• Compensating for an impact by replacing or providing substitute resources or environments; and

• Maximising beneficial impacts through specific additional actions.

As stated in Section 6 of this SER, there are considerable uncertainties regarding some impacts of wind power development on environmental and social topics; further work is required to fill some of these ‘information gaps’, so that future decisions can be made on a more informed basis.

The generic mitigation of likely significant effects are dealt with by considering each SER topic in turn below.


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8.1.1 Energy, Climate and Air Quality In terms of the SER Objectives assessment Section 6.2.1, only significant positive effects on Energy, Climate and Air Quality have been identified. Therefore, mitigation measures are not necessary at the strategic level.

The Government of Bulgaria is in the process of developing detailed RES Development Plan which will evaluate the environmentally, socially, economically and technically viable contribution of wind power development to the RES mix, and which will allow Bulgaria to achieve its RES targets.

For further consideration of air quality in the future, there would be merit in analyzing the spatial relationship between (i) the location and capacity of conventional (fossil fuel based) electricity producing power plants, (ii) the location and capacity of operating wind turbines, and (iii) the combined effect that current electricity generation by conventional means and from wind turbines has on air quality across Bulgaria. However, in order for such analysis to be meaningful, data would need to be collected from a dense grid of air quality monitoring stations over a number of years.

8.1.2 Cultural Heritage In Section 6.3.2 of this report, the World Heritage Properties have been identified as areas where no wind power development projects should take place. This prohibition is in accordance with Convention Concerning the Protection of the World Cultural and Natural Heritage, 1972, art. 4, art. 5 and the Cultural Heritage Act (SG issue 19/2009), art. 50, art. 65.

Additionally, the Bulgarian Cultural Heritage Act stipulates the creation of protected territories – architectural and historic reserves. These territories generally include a clearly defined buffer zone, with clearly delimited boundaries and management regimes. According to this law, all projects for new constructions in protected areas must be submitted for approval by the National Institute for Monuments of Culture (NIMC).

In the event that excavation works would be carried out during construction of wind power installations, appropriate archaeological monitoring of the excavation should be agreed with the NIMC and local authorities, and implemented to ensure that, if any objects of cultural heritage interest are found, they are appropriately recorded and handled.

8.1.3 Flora, Fauna and Biodiversity Areas with various levels of sensitivity regarding wind power development from the point of view of flora, fauna and biodiversity have been identified in Section 7. Furthermore, some areas with explicit legal prohibition for wind power development have been identified, such as National Parks, Strict Nature Reserves, Managed Reserves and some of the SPAs.

Regardless of the identified sensitivity levels, some general mitigation and compensation measures concerning flora, fauna and biodiversity should be taken into consideration in the development of wind power projects.

General mitigation measures for Flora, Fauna and Biodiversity protection

• Turbine Sitting and Layout: Pre-permitting studies with a sufficient level of detail should be conducted in order to establish the normal movement patterns of the resident and migratory species. This will inform suitable wind farm sitting, as well as microstting decisions about turbine configuration. Careful sitting of new wind turbines contributes substantially to the reduction of bird fatality risk. Conversely, turbine alignments that separate roosts and feeding sites, as well as those which lay on intensive migratory routes of birds and bats pose a permanent collision threat. With specific regard to bats, it is important to maintain linkages


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between areas of woodland and shelterbelts and habitats adjacent to the site and to retain woodland and shelterbelts, where possible.

• Lighting schemes: The effect of lighting scheme on birds and bats is still poorly understood. Nevertheless, it is known that constant sources of lights attract insects and, thus, indirectly increase the potential for large-scale fatality events, as a result of birds and bats colliding with the turbines. The use of flashing lights operating at minimum power is recommended, while still maintaining safety and security standards. It is also recommended to use white lights with sensors and switches that keep lights off when they are not needed.

• Power Lines: To prevent avian collisions and electrocutions, it is recommended, where feasible to place all connecting power lines associated with wind power development underground, unless burial of these lines would result in greater impacts to biological resources or other sustainability considerations. If any above-ground power lines are installed, the following mitigation measures should be considered:

o Use of guy wires should be minimized, whenever possible.

o Use of bird deflectors on power transmission lines is recommended.

o Installation of raptors perch prevention devices on aboveground power line poles is advised.

o The space between power lines wires should be planned in accordance with identified birds in the area of wind power development, in order to avoid bird electrocution.

• Turbine Shut Down System: This system could be implemented along with long term monitoring program, which can include visual observers and a radar system. In the event that a significant ‘at risk’ movement (within the swept path of the turbines) of wintering or migrating birds is observed, then single turbines, groups of turbines or the entire wind farm may have to be shut down to minimize the potential for collision. The scale of shutdown has to take into account the size of the ‘at risk’ flock, the direction of flight and the prevailing weather conditions and should be established in a mitigation plan agreed with the competent authorities.

• Avoiding fencing: Where possible, the construction of additional fencing as part of wind power projects should be avoided in order to protect habitat and animal species. Where the provision of additional fencing is unavoidable, where feasible the new fences built as part of the project should be wildlife friendly (smooth wire on top and minimum of 40 cm between ground and bottom wire).

• Decommissioning of non-operational turbines: This measure refers to the removal of wind turbines when they are no longer operational, so they do not present a collision hazard to bird and bats. As part of the permitting application, developers should submit a decommissioning and reclamation plan. The plan should discuss in reasonable detail how wind turbines and associated structures will be dismantled and removed at the end of the project. Decommissioning a project typically involves removal of turbine foundations (to one meter below ground level) and removal of access roads, unnecessary fencing, and ancillary structures. The decommissioning plan should also include documentation showing financial capability to carry out the decommissioning and restoration requirements. Plans for decommissioning can also be addressed as an obligation to the property owner as part of the lease arrangement with the wind developer.


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General compensation measures for Flora, Fauna and Biodiversity protection

Regardless of the form of the compensatory mitigation, Regional Inspectorates of Environment and Water should establish a balance between the level of impact and the amount of mitigation. Unlike habitat impacts, in which 1 ha habitat loss can be compensated with an appropriate number of hectares of habitat protected or restored, there are no obvious compensation ratios for bird and bat collisions with wind turbines.

As a guide, the following potential compensation could be used to protect and enhance bird and bat populations, as part of a compensatory program:

• Offsite conservation and protection of essential habitat, including nesting and breeding areas, foraging habitats, roosting or wintering areas, migratory rest areas and habitat corridors and linkages.

• Offsite conservation and habitat restoration, including restored habitat function and increased carrying capacity of the habitats.

• Offsite habitat enhancement, including predator control programs and exotic/invasive species removal from the habitats.

8.1.4 Soil and Water In accordance with Ordinance 3 for the conditions and order of investigation, design, approval and operation of the sanitary protection zones around the water sources and the potable water supply facilities (SG issue 88/2000), areas with high, medium and low sensitivity have been identified, as well as areas with explicit legal prohibition for wind power development – no wind turbines can be installed within Sanitary water protection zones I (described in Section 7.3.4 of this report). Further, in accordance with the currently amended Agricultural land protection act, a ban on wind power projects on agricultural land categories I to IV is anticipated.

As described in Section 6.2.4 of this report, it is considered that there are only partial minor negative potential effects on soil and water from wind power projects. Nevertheless, the Consortium recommends the following general mitigation measures are considered where necessary:

• Soil Erosion: In order to mitigate these potential effects, measures which include the shaping of excavated soils in such a way as to minimize the potential for erosion.

• Soil protection: Following construction, the site should be reinstated and return to its original use. Measures should be taken to ensure that soil compaction is minimized.

• Groundwater and surface water protection: Measures should be put in place to ensure that no chemicals are spilled during construction, operation and decommissioning of wind power projects thus minimizing the risk of ground and surface water pollution.

8.1.5 Landscape Based on Section 6.2.5 of this report, potential significant negative effects of wind power development on the visual value of landscape have been assessed and generic mitigation measures are suggested as follows.

To minimize the probability of the effect, a detailed assessment of the potential visual and landscape impact(s) of the proposed development, including visualizations from different viewpoints should be performed during the EIA process. A detailed description of how negative impacts on the landscape will be addressed in the project should be presented with the project description.


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Mitigation measures can include: (i) the creation of links between wind turbines and other landscape elements by making lines or clusters of wind turbines that follow natural or man-made structures in the landscape, (ii) locating wind turbines on existing industrial sites or areas proposed for industrial development, and (iii) locating wind turbines on the border of open areas, etc.

A number of mitigation measures involving the appropriate colour and finish of turbines also help to minimize adverse visual effects. The use of flat gray or white, non-reflective paint (depending on the location of the turbines) would cause wind turbines to appear to recede more quickly as viewing distance increases.

To mitigate short-term visual resource impacts, vegetation disturbance and the number of cuts and fills for access roads should be minimized. As soon as construction works finish, the landscape should be reshaped to its original contour and disturbed areas should be promptly re-vegetated.

Local communities should be consulted and involved in early stages of the development process to ensure that their concerns regarding visual impacts are considered. To ensure that this consultation process has been conducted appropriately, the public should be provided access to visualizations of the proposed wind turbines.

Clearly, the visual impacts of wind farms located in proximity to protected territories and NATURA 2000 areas should be subject to careful examination.

Finally, it is recommended that detailed assessments should be carried out on sensitive landscapes, which require protection under the European Draft Landscape Convention or are designated by local authorities’ development plans, to ensure that no significant impacts can arise from future wind power developments.

8.1.6 Public Health, Noise and Vibration Wind power development is likely to have a minor adverse effect on public health, noise and vibration SER Objectives. However, appropriate data is limited and as further information on the exposure of the Bulgarian population to noise and disturbance becomes available, this assessment should be reconsidered. Since the level of uncertainty is high, and there is no evidence on which to assess ‘significance’, the following mitigation measures are necessarily generic in nature.

General mitigation measures regarding noise

Beyond a certain distance, noise produced by wind turbines are generally is not a major concern for humans. According to Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy wind turbines should not be installed within 500 m from settlements. However, in countries all over Europe such as Spain (except for some regions) and the Netherlands, there is no minimum mandatory distance from human settlements and wind power installations.

It is recommended that the Bulgarian legislation should not establish a specific minimum distance between human settlements and wind turbines. This distance should be decided according to the EIA and based on noise, shadow flicker effect and landscape considerations. It is recommended that small size domestic turbines should be allowed on human settlements and wind power installations above 100 kW should be studied case by case in order to be permitted.

Various measures to reduce noise can be implemented in the design of modern turbines. The mechanical sound emanating from rotating machinery can be controlled by sound-isolating techniques. Furthermore, different types of wind turbines have different noise characteristics. Upwind turbines are less noisy than downwind turbines (additional aerodynamic noise). Variable-speed turbines (where rotor speeds are lower at low wind speeds) create less noise at lower wind speeds


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when ambient noise is also low, compared with constant-speed turbines. Direct-drive machines, which have no gearbox or high-speed mechanical components, are much quieter.

Operational noise can be dramatically reduced by the regular maintenance of turbines and continual monitoring for vibration. Careful modelling of layout and orientation to minimise wind effects on the turbine support structures also aids the mitigation of noise effects from these factors.

General mitigation measures regarding shadow flicker effect

An effective solution to prevent shadow flicker effects is to conduct preliminary studies on the turbines sitting and to locate them in such a way that their shadow paths avoid nearby dwellings. The potential shadow flicker effect should be clearly assessed in the project´s EIA document.

In order to minimise the shadow flicker effect of already constructed turbines or turbines which cannot be located at a greater distance from dwellings, it is recommended to shut down the particular wind turbines causing the effect at times when the turbines have been predicted or demonstrated to cause shadow flicker effects that are unacceptable.

8.1.7 Socio-Economic and Material Assets The lack of detailed information on the Socio-Economic and Material Assets topic precluded a detailed assessment of the corresponding SER Objectives.

Nonetheless, as was mentioned earlier, applicable legislation in Bulgaria states that wind power turbines should be at least 500 meters away from the closest settlement.

The character of urban areas may change as a result of wind power development. Future wind power policies should require the use of design-led approaches to take into account local urban characteristics in determining layout, design and construction of new wind power developments.

The development of wind power could highlight the need for appropriate management of land use pressures (e.g. preparation of management plans). Where there are potential conflicts with other land uses (conventional tourism, hunting, eco-tourism, etc.), it is recommended to strike a balance between encouraging access and enjoyment of the region for recreational use, and the positive contribution that wind power development can contribute to local communities, local employment and the secondary economy.

8.2 Recommended monitoring measures The SEA Regulations require the Responsible Authority for the draft plan/programme to “….monitor the significant environmental effects of the implementation of each plan or programme with the purpose of identifying unforeseen adverse effects at an early stage and being able to undertake appropriate remedial action.”

Since the current project is strategic in nature and does not assess a particular plan, no overall monitoring program is recommended. Nonetheless, as an overall approach, the Consortium recommends SER indicators to be monitored by the MEET and the MoEW to track wind power developments performance over time.

Monitoring the SER indicators would allow a quantitative assessment of the trends and progress over time. Special focus should be given to indicators which can be significantly affected by wind power development. If there are any existing monitoring arrangements (e.g. field surveys already developed or monitoring programs), they should be used to monitor selected indicators where possible.

Where unforeseen adverse effects are identified, the MEET and the MoEW (or other competent authorities) should seek to establish the cause in consultation with the Consultation Bodies/Authorities


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and other stakeholders. Preventive and corrective actions should be developed and agreed with relevant parties and implemented, as appropriate.

Monitoring SER Objectives over time could be used in future initiatives as the future RES plan.

During the baseline information gathering and the preparation of this report, a number of gaps in the environmental information were identified. At present, access to some data is difficult as data is dispersed and non-structured (as discussed in detail in Section 7 and Appendix D). Similarly, data acquisition techniques and formatting of data differs from one data resource to another. These difficulties act as constraints to the establishment of an appropriate monitoring system, particularly for data analysis and evaluation as part of the monitoring process.

As a main recommendation, the Consortium advises the creation of a National GIS infrastructure that could be prepared to allow for the development of a proper system for monitoring wind power development. At present it is very time consuming to spatially locate existing and planned wind power installations, and it is virtually impossible to establish the connection between the planned and installed capacities (i.e. to determined which planned plojects have actually been implemented). To overcome these obstacles, a system can be created which tracks wind power projects from the initial stages of the permitting process to the exlploatation and decommissioning stages. Such a database will be useful only if it is continuously updated and if there is a specifically designated organization charged with the responsibility for its update.

Additionally or as part of this National GIS infrastructure, the Consortium recommends that the extensive spatial database, complied as part of this project, is made publically accessible by either MEET or MoEW. Of course, if the compiled spatial database is made public, this should be done with careful consideration of the sensitivity and the authorship of the individual data sets, and authorizations should be sought from the respective data producers.

The development of a spatial data infrastructure and making the spatial database publically accessible would facilitate access to environmental information, support stakeholder’s participation and allow an appropriate base for the implementation of a monitoring system.

8.3 Recommended considerations for the Environmental Impacts Assessments (EIA) process

Even though spatial analysis of the environmental sensitivity of the territory of Bulgaria has been carried out as part of this project, due to the scale of the project and the existence of data gaps, the performed spatial analysis should be used for strategic planning purposes only and in support of detailed EIAs of individual projects. Further studies have to be conducted in order to properly evaluate the environmental constraints of specific projects.

Areas where explicit legislative prohibition to wind power development has been identified will not be discussed here because if the legislation is implemented properly, wind power development will not occur in these areas. Also, areas with no or unknown sensitivity for wind power development are not addressed in this section, given that these areas are subject to a standard EIA process and therefore supplementary guidance is not needed. Nevertheless, since the sensitivity of these areas may change as more information become available, it is recommended that the applicable additional requirements are integrated in the standard EIA.

8.3.1 Bulgaria Legal Framework for the development of EIA According to Bulgarian environmental legislation, wind power development projects should undergo a determination for the necessity of an EIA.

The main pieces of legislation governing the EIA process are briefly addressed in the text below.


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Environmental Protection Act (EPA)

This is the main legislative act regarding environmental protection, biological diversity conservation, and the protection of the Bulgarian biological heritage. The EPA (promulgated SG № 133/ 01.11.1998, last amended SG № 103/ 29.12.2009) sets all requirements regarding the management and control of environmental activities, factors detrimental to the environment, and the condition of different environmental elements.

The Act further regulates the creation and operation of the National environmental monitoring system, as well as the elaboration of a number of strategies, plans and programs regarding environmental protection. Duties and requirements for state authorities, municipalities, physical and legal persons with regard to environmental protection are defined by this Act.

Finally, the EPA is the framework document, which defines the general requirements for environmental permitting (EIA, IPPC permits), protected territories, and the setting of various financial mechanisms for environmental management.

Regulation on the terms and procedure for conducting Environmental Impact Assessments

This Regulation (promulgated SG No 25/18.03.2003, last amended SG No 3/10.01.2006), sets the terms and procedure for conducting EIA of investment proposals for construction, activities and technologies. It also provides developers with information on assessing whether they need to carry out EIA procedures. The methodology will help to collect representative and adequate data for the species of conservation importance.

Regulation on the conditions and rules for conducting compatibility evaluation of plans, programmes and investment projects with respect to the goals for preservation of protected areas (Appropriate Assessment)

This regulation (promulgated SG No 73/11.09.2007), stipulates the terms and procedure for making an assessment under art. 31 of the Biodiversity Act with regard to plans, programmes, projects and investment proposals and their compatibility with the subject and purposes of conserving protected areas.

The measures proposed in the assessment for the avoidance, reduction and possible elimination of unfavorable impacts and the compensation of damages resulting from the realization of the investment proposals, plans, programmes, projects, must correspond to the measures stipulated for each particular case (as per art. 22 of this regulation).

8.3.2 Additional EIA requirements to be undertake in areas with high sensitivity to wind power development (Red Areas)

As previously stated, given the likelihood that the implementation of new wind turbines and the re-powering of existing wind turbines with larger ones in these areas is likely to cause significant negative impacts on the environment, wind power development in these areas should be approached with upmost care. In the event that wind power development is considered within an area with high sensitivity, a detailed assessment of the environmental impacts should be required. To ensure that the EIAs of projects proposed in areas with high sensitivity have the quality, which is adequate to properly assess the existing risks, the Consortium recommends the following:

All wind power projects proposed in these areas should be subject to comprehensive EIAs, except for small size domestic turbines. These EIAs should cover all new or upgraded infrastructures, associated with the proposed project (e.g. power lines, access roads onshore). More specific guidelines on the EIAs of projects proposed in areas with high sensitivity are presented below.

EIA Approval


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The EIA, with the additional requirements that are proposed below, should be evaluated at national level by the MoEW. Clarifications and support may be asked from the regional inspectorate, within which jurisdiction the project falls, but the final official decision should be taken by the MoEW.

Such centralized decision making is expected to ensure that these projects are assessed with the highest attention by the public and by the competent authorities because decisions on the EIAs will be taken by the Supreme Environmental Expert Council, which consists of highly knowledgeable and experienced experts from the MoEW (Preventive Activities Directorate, National Nature Protection Service, etc.), Ministry of Regional Development and Public Works, Ministry of Health, Ministry of Agriculture and Food, academic institutions, NGOs, etc.

Evaluation of Cumulative Effects

Cumulative effects should be identified and analyzed not only at regional level but also at the national, European and international level. This is important for migratory birds.

Public Consultation Process

Consultations for the EIA scoping and EIA draft report should be conducted with the participation of not only the respective competent authorities (MoEW, RIEWs, Basin Directorates, etc.), but also with the participation of NGOs, academic institutions and other relevant stakeholders. The MoEW should prepare and provide investors with a list of organizations, which have to be invited for consultation. This list should set the minimum involved stakeholders and investors would be free to invite additional stakeholders. The MoEW should update the list periodically. Involving a diverse group of stakeholders at early stages of the EIA process is expected to contribute significantly to the completeness and objectivity of the resulting EIA report.

The EIA scoping consultations and the EIA draft report consultations should include consultation meetings and submission of statements. Organizing meetings will allow for face to face discussions, which can help better identify and resolve differences in opinions.

Besides the standard methods for notification of consultation meetings, such as newspaper ads, announcements posted in the municipal building of the respective municipality, etc., the identified stakeholders should be invited by letter, fax or e-mail and a notification should be posted on the MoEW website.

Additional requirements regarding specific environmental components

In order to assess whether locating a wind power project in these highly sensitive areas is viable, detailed analysis/studies (EIAs) need to be carried out. The following considerations should be taken into account in relation to the scope of the EIAs.

1. Areas with high importance for the protection of bats: Some of the key components which are recommended to be addressed in the EIA and AA of projects planned within areas with high importance for bats71 are presented below:

• STEP 1. Collection and analysis of available information - This stage has to include at least one site visit and survey of the region where the wind power developments are planned.

• STEP 2. Preliminary evaluation of the need for additional studies to establish the level of risk and the potential impact of the wind power project - Conclusive evaluation on the level of significance of conflicts must be arrived at in consultation with a bat expert. Additional field studies may be needed for the identified priority conflicts.

71 A manual for developers, environmental experts and planning authorities prepared by the National Museum of Natural History – BAS.


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• STEP 3. Developing and carrying out studies on bats and the related functional elements of the environment - The duration of field research should take into account the one-year life cycle between two breeding periods, which is summarized below:

- Breeding period (late May - late July);

- Period of active communication between the summer roosts (June – August);

- Activity of local populations (May – September);

- Dispersal of colonies and the start of the autumn migration (August – September);

- Autumn migrations and swarming behaviour at some roosts (September – October);

- Hibernation (December – March);

- Spring migration and mating (March – April).

• If the wind power development is planned to be implemented within the boundaries of a NATURA 2000 zone, at least 4–6 field studies must be carried out for each square kilometre of affected area. For projects outside NATURA 2000 zones, 2–3 field studies must be performed for each 1–5 square kilometres of affected area.

• STEP 4. Final assessment of the impact of the investment proposal and measures to prevent, mitigate or offset negative impacts - The measures for avoidance, reduction and/or compensation of damages should be consulted with a bat expert and the developer’s engineering and technical consultants.

2. Appropriate Assessment for Habitats, included in Annex 1 and 2 of the Habitat Directive, in pSCI/SCI NATURA 2000 zones

Appropriate assessment (AA), required under art. 6 (3) of the Habitat Directive, is one of the most powerful tools currently available to control the environmental impacts of project development on NATURA 2000 sites. AA is often described as a decision-making tool because it has the potential to stop development.

The Habitats Directive provides two main instruments: the NATURA 2000 network of protected sites and the species protection provisions. The provisions for species protection apply to the whole Member State’s territory and concern the physical protection of specimens as well as their breeding sites and resting places. Both regimes allow for exceptions under certain conditions. Both instruments are complementary and jointly aim to ensure a favourable conservation status for all species of Community interest.

The Commission services have produced two guidance documents explaining in detail the provisions of Article 6 of the Habitats Directive:

• “Managing NATURA 2000 sites: The provisions of Article 6 of the Habitats Directive 92/43/EEC”, European Commission, 2000, ISBN 92-828-9048-1

• “Assessment of plans and projects significantly affecting NATURA 2000 sites - Methodological guidance on the provisions of Article 6(3) and (4) of the Habitats Directive 92/43/EEC”, European Commission, 2002, ISBN 92-828-1818-7

The first document deals with the management of NATURA 2000 sites in general, while the second document focuses on the procedures for the nature impact assessment and its consequences under Article 6(3) and 6(4)72.

72 Both documents are available at http://www.europa.eu.int/comm/environment/nature/home.htm.


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A species-by-species approach also needs to be adopted. The specific targets may differ significantly from one species to another and also can evolve as better scientific knowledge becomes available. Bulgaria should therefore always consider its implementation of the Directives in the light of the intended objective, the species concerned and the circumstances of each case. Thus, it becomes an important factor for the flexible implementation of species conservation.

Disturbance might not directly affect the physical integrity of a species but can nevertheless have a direct negative effect. Disturbance is detrimental for a protected species e.g. by reducing survival chances, breeding success or reproductive ability. A species-by-species approach needs to be taken as different species will react differently to potentially disturbing activities. The periods of breeding, rearing, hibernation and migration are considered as especially sensitive periods in relation to disturbance. These periods can be defined only using a species-by-species approach, due to ecological, biological and behavioural differences between species.

3 Protected Territories: Natural Parks, protected sites and natural monuments

These areas should be taken into account and surveys must be undertaken to evaluate impacts that wind power development can cause. The EIA should evaluate how the restriction levels, as established by the Bulgarian Protected Areas Act and by the management plan of each individual territory, are addressed. According to the Protected Areas Act, the restrictions are as follows:

• Nature Parks – all activities and construction, which are not permitted in the park designation orders, park management plans and the spatial and technical plans and projects, as well as all activities which are specifically prohibited in the parks designation orders and the management plans, shall be prohibited in Nature Parks (art. 31).

• Protected Sites – any activities contrary to the requirements for conservation of the specific features subject to protection shall be prohibited in Protected Sites (art. 34).

• Natural Monuments – any activities that may disturb the natural state of natural monuments or impair the aesthetic value thereof shall be prohibited in Natural Monuments (art. 24).

4. Sanitary protection zones II

These areas should be identified through contacting the respective Basic Directorate and surveys must be undertaken to evaluate impacts that wind power development can cause in these areas. EIA should describe how the restrictions levels established by the Bulgarian Ordinance 3/16.10.2000, on the land use of sanitary water protection zones, were addressed.

According to Annex 1 of the ordinance, in sanitary protection zones II around surface water sources, the construction of aboveground and underground facilities is restricted, with the exception of reconstruction and modernization of the main water supply facilities. Moreover, according to Annex 2, in sanitary protection zones II around underground water sources, all activities which damage the integrity of the watertight layer above the underground water body are prohibited.

Although, this is not likely to occur during the installation of wind turbines, but even so the necessary precautions should be taken to assess this issue.

5. Areas defined as Class I from CORINE Landcover

Class 1 from the CORINE Landcover database contains all major elements of the artificial surfaces: continuous urban fabric, discontinuous urban fabric, industrial or commercial units, road and railroad networks and associated land, port areas, airports, mineral extraction sites, dump sites, construction sites, green urban areas, sport and leisure facilities.

Different legislative acts considering the operation of ports, airports, railroads, etc. pose various restrictions for the construction of industrial installations, including wind power turbines, in close


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proximity to these built structures. EIA should explicitly refer how these restrictions have been taken into account and addressed by the project.

It is recommended that wind turbines should be placed at a distance of at least the rotor radius from the edge of roads, railways or waterways to the turbine tower. If an icing risk exists, the distance should be greater. Also for main railways, highways and intersections, a risk analysis could be implemented.

In regards to wind turbines to be placed close to airports, ports and defense facilities, competent authorities should be consulted for development and conditions.

Wind power development could be encouraged in areas such as dump sites, mining sites and other degraded areas. For instance, by concentrating wind turbines in industrial areas there may be less of a need to install installations in more sensitive areas. Also, electrical energy generated by turbines in industrial or populated areas can be delivered to the users directly, minimizing the energy transportation requirements. From a landscape protection point of view, turbines can be integrated into industrial or built-up landscapes much more easily than in natural areas.

6. Birds Protection73

In the event that areas identified as being highly sensitive for birds, as addressed in Section 7.3.2, are considered as potential locations for the installation of wind turbines, the following elements should be taken into account.

The EIA will benefit from the development of spatial (GIS) analysis, covering the known roosting areas, staging areas, feeding and foraging areas, flyways, migration bottlenecks and all other areas important for the bird species present in the area of interest and vulnerable to wind power development. The spatial constraint data on birds should be overlaid with the proposed location(s) of the wind farm project in order to identify the suitability of the particular proposed site, as well as other alternative locations. To aid this process, it is recommended that either the MEET or the MoEW make the spatial database compiled as part of this project publicly accessible.

The EIA should address the habitats and locations that support essential functions throughout all stages of the life cycle of birds, including feeding, breeding, moulting, resting areas and migration stopovers.

It is recommended that standardised study methods for monitor distribution and density over time and behavioural studies (fixed point observations) for assessing the site use and collision risk/mortality are employed to ensure comparability and consistency before, during and after construction in the wind farm area (BACI - Before-After Control-Impact).

Summarized information is also provided on Appendix F of this report, with main directions for investigating the behaviour of birds and bats, as a risk indicator at operational wind farms and future wind projects.

Field studies are recommended for a minimum of 2 years. This will enable to identify the key species of concern and well as the time of the year which is most important to the site. Also, field studies conducted for at least two years for the key species of concern, will increase the reliability of the assessment by allowing for weather conditions and year-to-year variations.

73 Information based on several published reports: - Wind farms and Birds: An analysis of the effects of wind farms on birds, and guidance on environmental assessment criteria and site selection issues. For more information: http://www.birdlife.org/eu/pdfs/BirdLife_Bern_windfarms.pdf - Wind Energy developments and NATURA 2000. For more information: http://www.vpvb.gov.lv/data/files/ivn/wind.energy.and.n2000.pdf.


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The sampling design should enable representative sampling of the wind farm area, plus the buffer (as presented in Appendix D3 FF) and reference/control area(s), and ideally provide enough data points to permit statistical analysis74. Sampling intensity may be increased at times of particular concern, e.g. waders or raptors during the breeding season, peak migration times, and offshore post-breeding moulting flocks of sea ducks.

These preliminary studies will enable an assessment to be made about the potential impacts of the proposed wind farm and will provide the baseline for subsequent comparison, if the wind farm proceeds.

For some species that are strongly traditional in their activities, such as golden eagle, year-to-year variation in the use of a site is minimal (unless alternate nest sites are used), but for most other species the use of a site may be variable from one year to the next. Year-round resident species may show seasonal variation in their use of a site and it is necessary for the assessment to account for this. Species and abundance may also vary seasonally or according to breeding status and assessments should account for such variation.

A typical assessment will seek to predict what the effect of the wind farm will be over a period for which consent for the wind farm is being sought (usually 25 years). If the assessment is based on information from only 2 years, it is vital that potential changes between years and any underlying trends are taken into account as an integral component of the assessment. There are many species for which there is either no information, or no conclusive information, to date. Focal species are likely to be site and issue specific and may change in the light of further research or change in conservation status. Appropriate sampling design and duration of research and monitoring will depend on the location, species present, their sensitivity and conservation importance, and the size of the proposed wind farm development66. Early and continued consultation with the relevant conservation agencies, NGOs and experienced researchers will ensure that the study methods are site-specific. It is essential that the study objectives and methods are clear from the outset and are clearly documented in reports.

In reality, there will be a spectrum in the scales of the studies - more data will be needed for locations of considerable bird interest and where there are uncertainties regarding the potential impacts. Where raptors are the main concern, studies need to focus on raptor ranges rather than just on the proposed wind farm site. This will provide contextual information on the raptors use of the area.

The assessment of effects on birds attributable to wind farms is complicated by the relatively large area potentially affected, the dispersed distribution of some of the species of concern and the relative rarity of the events being measured (e.g. collision). Thus, the weight of evidence from studies at different locations over extended periods of time will generally be needed to enable an informed judgment to be made about the impacts of wind farms.

7. Landscape

Even if landscape topic was not addressed in the spatial constraints analysis (Section 7.3.6), likely significant effects were identified (Section 6.1.5). For this reason, the EIA should include a detailed assessment of the potential visual and landscape impact(s) of the proposed development including visualizations from different viewpoints.

8. Public Health

Due to the lack of available information on wind farms development and public health in Bulgaria, EIA are recommend to include an assessment on the potential impacts on human health particularly addressing noise issues and the shadow flicker effect. 74 Effects of wind farms on birds by R. H. W. Langston,J. D. Pullan,Council of Europe


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8.3.3 Additional EIA requirements to be undertaken in areas with medium sensitivity to wind power development (Orange Areas)

In order to assess the viability of wind power projects in these areas, as well as their most suitable layout, detailed analysis/studies should be carried out. To ensure that the EIAs of projects proposed in these areas have the quality, which is adequate to properly assess the existing risks. If wind power is implemented in such areas, relevant mitigation measures to reduce the impacts are likely to be required.



Additional requirements

The following considerations should be followed when conducting an EIA in areas, determined to be with medium sensitivity.

1. Areas with medium importance for the protection of bats

Methodology for EIA and AA of areas important for bats17 should be followed as previously presented in Section 8.4.2.

2. Areas with medium sensitivity to flora, fauna and biodiversity (except birds), as identified in Section 7.3.3 - one year monitoring/inventory is recommended.

3. Areas with medium sensitivity to birds, as identified in Section 7.3.4 - one to two years of monitoring is recommended.

4. Sanitary protection zones III – around underground water sources

Similar to the scope recommended for the Red Zones.

According to Annex 2, in sanitary protection zones III around underground water sources, activities which damage the integrity of the watertight layer above the underground water body are restricted.

5. Landscape

Similar to the scope recommended for the Red Zones.

6. Public Health

Similar to the scope recommended to the Red Zones.

8.3.4 Additional EIA requirements to be undertake in areas with low sensitivity to wind power development (Yellow Areas)

In order to assess the viability of wind power projects in these areas, as well as their most suitable layout, EIAs should be carried. If wind power is implemented in such areas, mitigation measures to reduce impacts may be required. As more data becomes available, the sensitivity of these areas may vary.



Additional requirements

In order to assess the viability of wind power in these areas, detailed analysis/studies need to be carried out in order to position the wind farm. The following considerations should be followed.


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1. Areas with medium importance for the protection of bats

Methodology for Environmental Impact Assessment and Appropriate Assessment for Bats17 should be followed as previously presented.

2. Areas with low sensitivity to flora, fauna and biodiversity, including birds, as identified in Section 7.3.3 and Section 7.3.4 - one year monitoring/inventory is recommended.

3. Sanitary protection zones III – around surface water sources


Although the Bulgarian Ordinance 3/16.10.2000, on the land use of sanitary water protection zones, does not refer to particular restrictions on these areas, the precautionary principle should be applied and the EIA should explicit refer on how these areas were addressed in the project design.

4. Landscape


5. Public Health


8.3.5 Additional recommendations for future wind development in Bulgaria For a future assessment of the development of wind power in Bulgaria, it is recommended that the MEET and the MoEW carefully evaluate the results and considerations from this SER. The SER should be taken into account in the drafting process of future RES plans. In this context it is important to note that the spatial constraints analysis section, and its supporting data, need to be constantly updated in order to always contain the most up-to-date scientific information, which will allow more accurate assessments. Furthermore, it should be noted that the considerations and conclusions may not be totally applicable to other types of RES, different than wind energy, and may not apply to new types of wind technology.

Therefore, it is the Consortium’s opinion that the approach and information developed for this SER should be integrated in future work including individual studies developed by the regional inspectorates and that it should feed into strategic RES plans and programs.

Additionally, the Consortium recommends that competent environmental authorities carefully review the series of matrices outlined in Section 6 of this report. These matrices assess the potential effects on the environmental and social SER Objective from the development of wind power. It should be pointed out that:

• Where the matrices have identified a likely negative significant effect, consideration should be given to mitigation measures in future wind projects.

• Where it was considered that an objective is experiencing likely positive significant effect, then consideration should be given as to how this positive effect can be enhanced.

• Where it was considered that an objective is experiencing no effect, consideration may be given as to how positive effect on this objective can be achieved.

• Finally, where the effects on an objective are uncertain, consideration should be given as to what further information is needed to clarify the effects.


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9 Conclusions Over the past decade the use of wind power has increased dramatically in Europe, and Bulgaria is no exception to this.

In many cases the development of wind power has occurred at greater pace than the evolution of the associated national legislation and energy policy. It is precisely in this respect that the SER of wind power development in Bulgaria intends to assist the country’s authorities, and ultimately the Bulgarian society as a whole, with recommendations regarding a way forward for the sustainable implementation of wind power in the country.

Wind power provides clean energy and its incorporation into the Bulgarian energy mix will help the country to meet its acquired obligations towards the EU with respect to the percentage share of energy from RS in the gross final energy consumption in 2020. The use of wind power will also reduce the dependency on foreign energy suppliers.

As with all energy sources, wind energy also has some negative side effects, where the impact on avifauna and bats, and the visual impact on landscapes, are amongst the most important. As part of modern wind power technology many ways have been developed to reduce these impacts to adequate levels. EIA can determine the scope of the mitigation measures that are required in order to reduce the risks associate with the implementation of wind power to acceptable levels.

However, Bulgaria is a country with a valuable natural heritage, and given its great richness in biodiversity and the occurrence of many species that are at risk of extinction, care should be taken during the site selection and the detailed design of wind farms.

In order to provide a basis for sustainable wind power development in Bulgaria, this SER has generated the following main elements:

Overview of the environmental baseline

In order to establish the general context in which wind power needs to be developed, an overview has been made of (i) the policy context including the relevant environmental and RES regulations and the national goals related to environmental protection and the development of the RES sector, (ii) the environmental and social baseline and (iii) the identified key issues.

Based on this overview a series of SER objectives and indicators were identified in order to assess potential impacts, and to identify strategies to advance towards these objectives.

Stakeholders’ involvement

The consultation with all relevant stakeholders is a crucial component of the successful outcome of the project. During the performance of the SER, relevant stakeholder groups, including institutional and regulatory bodies, the wind energy business, the non-governmental organizations, the academia and the general public in two selected areas were invited to voice their opinions, concerns and recommendations regarding the environmental and social aspects of the development of wind power in Bulgaria.

The input of the stakeholders has been received through the conduct of a series of consultation meetings and by using a publicly accessible project website where relevant information was published and which indicated the procedure to submit queries and comments. In addition to this, many workshops and meetings were organised to obtain more detailed feedback and data from all stakeholder groups.


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Assessment of the effects of wind power development on environmental and social aspects

The SER report presents a methodology for the assessment of the potential effects of wind power development on the identified SER objectives and indicators. This assessment has been carried out in a semi quantitative manner through a scoring system, which distinguishes major, minor and partial positive and negative effects, as well as no effects.

A major positive effect from the further expansion of wind power is expected on the achievement of the Bulgarian RES targets for 2020, the reduction of the dependence on energy imports in the country, the reduction of GHG emissions and the reductions of air pollution emissions from the energy sector. Estimations point out that the share of wind power in Bulgaria can rise to about 13% of the gross inland electricity consumption in the near future.

The potential effects of wind power development on threatened and migratory birds and bats, on Protected Territories, NATURA 2000 sites and landscapes have been assessed as potentially major and negative.

Spatial (GIS) analysis of the constrains

In order to distinguish areas where wind power implementation is less likely to cause negative impacts from those where the potential for environmental damage is greater, a database has been constructed in which the best available scientific information regarding environmental issues relevant for wind power development have been stored. This database currently contains 65 spatial data sets. Some of the data sets have been obtained from various stakeholders, while others have been created by the Consortium, based on published and non-published information.

The huge volume of spatial data could be assessed only through the application of a Geographic Information System (GIS). The use of a GIS allowed the Consortium to perform various spatial analyses regarding the identified environmental and social constraints. A separate system (metadata collection) has been created to documents the origin and quality of the data, which enhances the transparency of data management and interpretation.

This compilation and analysis of information on the environmental and social constrains of wind power development is something that has never been done before on Bulgaria - at least not on this scale and not for these purposes.

Five levels of sensitivity were identified regarding the development of wind power in Bulgaria: areas with explicit legislative prohibition, areas with high, medium and low sensitivity and areas with no or unknown sensitivity.

In limited regions within the territory of Bulgaria the implementation of wind power is currently legally prohibited. These are mainly specially protected natural areas, where also most other forms of economic activities are also prohibited. There is also a current prohibition to implement wind power within 500 m from settlements.

The rest of the country shows various types of sensitivity based on local and regional conditions. The eastern and southern portions of the country generally are the most sensitive, and this is mainly due to the presence of threatened bird species.

It is important to note that the levels of sensitivity have been based on expert opinions of Bulgarian scientists and renowned environmental NGOs. However, it is recognised that many data gaps exist, and that the opinions regarding the sensitivity of specific species and habitats may not be shared among all experts. It was beyond the scope of the current project to perform extensive cross-checking of the received information. Therefore, the Consortium recommends that work groups are established by the MoEW in collaboration with the MEET to review the data base and the sensitivity classification, in order to finalise the basic sensitivity classification of the country with regards to wind power.


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Furthermore, it is recommended that this classification, and the underlying data base are periodically updated with information from the various governmental institutions, the investors and the NGOs. The database should therefore also be publicly accessible.

Site selection criteria and mitigation measures

Specific recommendations have been made for the conduct of EIAs of projects falling within each of the sensitivity area, where the proposed level of detail and stringency of the EIA corresponds to the level of sensitivity. In highly sensitive areas, wind power development should be approached with upmost care. It is very likely that the detailed EIA of projects proposed in such areas show that the implementation of wind power is not viable as the associated risks cannot be mitigated to acceptable levels, at least not with current wind power technology. If it is proven that wind power projects are viable in such areas, the implementation of mitigation measures is very likely to be required. In areas with lesser sensitivity, the EIAs can be less detailed, and the scope of the required mitigation measures is likely to be more limited.

It is considered to be important that the EIAs that are performed for the high sensitive areas are reviewed at national level by the MoEW. Clarifications and support may be asked from the regional inspectorate, within which jurisdiction the project falls, but the final official decision should be taken by the MoEW. Such centralized decision making will ensure that these projects are assessed with the highest attention by the public and by the competent authorities with the highest level of expertise.

The cumulative effects of wind power development on the environment have not been properly taken into account in the past, which has resulted in the permitting of a large number of turbines in a relatively small area in the North-Eastern part of the country. It has also become apparent that the installation of an unproportionally large percentage of the existing wind turbines was authorised by the RIEWs without the performance of an EIA. This makes clear that in the future, the cumulative impact of wind power development should be better addressed by the investors during the conduct of EIA studies and by the competent authorities in the the strategic planning of the sector.

The cumulative effects related to wind power development should be assessed very carefully and systematically for all wind power projects, regardless of the area where they are implemented. It is recommended that all wind projects with capacity exceeding 100kW are subject to EIAs.

Wind Potential and Grid Capacity

It is considered to be essential for the development of wind power that a national map of wind potential and the grid capacity becomes available that will show to companies and investors which areas offer the best locations from a technical point of view.

Guidance notes

Additional guidance notes for streamlining the wind power project appraisal and environmental permitting process in Bulgaria and a Best Practice Guide for wind power investors in Bulgaria will also be produced as relevant outputs of this Project.


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10 ANNEX


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APPENDIX A: Performance of the SER Report


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APPENDIX A: Performance of the SER Report Criteria required by the SEA Directive Performance of SER Report

Objectives and context The plan’s purpose and objectives are made clear. The draft SER Report includes an explanation on section 1.2 Strategic Environmental Review where it is

described the SER process and therefore explained that no plan is being currently assessed.

Additionally under subheading 2.4 within Section 2, regulatory framework and policy context sets out the purpose of this assessment.

Links with other related plans, programmes and policies are identified, explained and used to inform the SEA framework and assessment process.

Key messages from a review of policies, plans and programmes are set out in Section 2.4 on the national level for the implementation of wind power in Bulgaria.

The relationship between the Core Strategy and some plans, such as the regional spatial strategy, is touched on in Section 5.1. Reference is made to the Final Scoping Report where a list of documents that are deemed relevant to each of the environmental topics.

Conflicts and synergies that exist between SEA objectives, between SEA and plan objectives, and between SEA and other plan objectives are identified and described.

Conflicts and synergies that exist between SER Objectives have been dealt with in the Final Scoping Report.

Scoping

The environmental consultation bodies are consulted in appropriate ways and at appropriate times on the content and scope of the SEA Report.

Section 4 of the SER Report is dedicated to describe Scoping Consultation process and achievements and how the SER Consultation will be conduct.

The final Scoping Report, following consultation on the Scoping Report, provides thorough and robust records of how consultation on the scope of the SER has been taken into account.

Consultation process has and will follow Bulgarian legal requirements.

A summary of consultation undertaken on the SER scope is provided in Section 4.2.

Technical, procedural and other difficulties encountered are discussed; assumptions and uncertainties are made explicit.

Section 7 and Appendix D discusses difficulties encountered in compiling information or carry out the assessment, although it focuses more on difficulties in compiling information.

This section also discusses limitations of the information. Information gaps and assumptions identified/made during the assessment process (identified in the describing text within the matrices).

Options/Alternatives

Realistic alternatives are considered for key issues, and the reasons for choosing them are documented.

Section 3.3 explains the approach followed to the creation of alternatives.


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APPENDIX A: Performance of the SER Report Criteria required by the SEA Directive Performance of SER Report The sustainability effects (both adverse and beneficial) of each alternative are identified and compared.

This is set out in the matrices in Section 6 and key effects briefly identified within text which compares groups of related options.

Section 6 describes how the results of the assessments have been taken on board to date.

Some of the supporting text has been updated as more information has become available or decisions have been taken.

Reasons are given for selection or elimination of alternatives.

As explained in Section 3.3 alternatives were not identified.

Baseline information

The relevant aspects of the current state of the environment (and sustainability aspects) and the likely evolution without the plan are described.

The Scoping Report contains baseline data and a useful summary in Section 5 of the draft SER Report. This contains trend information where available. Some data sources are several years out of date. The Topic Papers developed during Stage A of this project address in detail each of the 7 environmental topics.

Issues are described in Section 5 and reference is made to the Scoping Report.

The evolution of the environment without the plan is not described, since currently no plan is being assessed.

Characteristics of areas likely to be significantly affected are described, including areas wider than the physical boundary of the plan area where it is likely to be affected by the plan where practicable.

Section 7 of the draft SER Report provides a spatial analysis on the environmental and social constraints identified. Within this section an aggregated map with several sensitivity areas was created and therefore evaluated the effects that may occur when wind power projects are planned in certain areas.

Prediction and evaluation of likely significant effects

Likely significant social, environmental and economic effects are identified, including those listed in the SEA Directive (biodiversity, population, human health, fauna, flora, soil, water, air, climate factors, material assets, cultural heritage and landscape), as relevant.

This is dealt with for the options appraisals in the matrices within Section 6.

The appraisals of the Preferred Options Core Strategy document will not be undertaken.

The coverage of the SER Objectives is linked to the SEA topics within the SER framework presented in Section 5.2.

Both positive and negative effects are considered, and where practicable, the duration of effects (short, medium or long-term) is addressed.

This is addressed within the appraisal matrices within Section 6.



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APPENDIX A: Performance of the SER Report Criteria required by the SEA Directive Performance of SER Report Likely secondary, cumulative and synergistic effects are identified where practicable.



Inter-relationships between effects are considered where practicable.


Mitigation measures

Measures envisaged to prevent, reduce and offset any significant adverse implementing the plan are indicated.

This is addressed within Section 8.

The Sustainability Appraisal Report

Identifies sources of information, including expert judgement and matters of opinion.

Sources of baseline data are included within the 6 Topic Papers and in Section 9 of the draft SER Report.

Contains a non-technical summary. The NTS is presented at the beginning of the report.

Consultation

The SA is consulted on as an integral part of the plan-making process.

Details of consultation are included in Section 4 of the draft SER Report.

The consultation bodies, other consultees and the public are consulted in ways which give them an early and effective opportunity within appropriate time frames to express their opinions on the draft plan and SEA Report.

Details of consultation are included in Section 4 of the draft SER Report.

Decision-making and information on the decision

The SEA Report and the opinions of those consulted are taken into account in finalising and adopting the plan.

A good record of consultation on the scoping report has so far been kept. A similar record of subsequent SER stages will be kept for the SER final Report.

An explanation is given of how they have been taken into account

A good record of consultation on the scoping report has so far been kept. A similar record of subsequent SER stages will be kept for the SER final Report.

Decision-making and information on the decision


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APPENDIX A: Performance of the SER Report Criteria required by the SEA Directive Performance of SER Report Measures proposed for monitoring are clear, practicable and linked to the indicators and objectives used in the SEA.

The monitoring system will need to be included as a draft framework within this version of the draft SER Report. The contents page identifies where this will be located within the report. The Monitoring Framework may need to be updated and finalized as the Core Strategy is changed and subsequent iterations of the SER are undertaken.

Monitoring is used, where appropriate, during implementation of the plan to make good deficiencies in baseline information in the SEA

The monitoring system will be developed in accordance to Section 8. Nevertheless, since no plan will be implemented, monitoring refers to the different environmental topics when wind power projects are being planned.


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APPENDIX B: Evaluation of Significant Effects

Appendix B1: Energy, Climate and Air Quality

Appendix B2: Cultural Heritage

Appendix B3: Flora, Fauna and Biodiversity

Appendix B4: Soil and Water

Appendix B5: Landscape

Appendix B6: Public Health, Noise and Vibration

Appendix B7: Socio-Economic and Material Assets


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Appendix B1: Energy, Climate and Air Quality - Evaluation of significant effects

SER Objective

Indicator/Receptor

Description of effect

Value and Vulnerability

Cumulative/

secondary/ synergistic interaction

s

Probability (H/M/L/VL)

Duration (construction,

operation, decommissioning)

and frequency

Irreversible/ reversible; temporary/ permanent

Magnitude (H/M/L/VL)

Spatial extent &

trans-boundary

Positive/ Negative


1.1 Reduce the growing dependence on energy

imports within

Bulgaria.

1.1.1 Percentage of wind energy from

gross inland consumption and

benchmark with EU countries

Change Bulgarian

dependency on energy imports.

Value = H

Vulnerability = L

Cumulative impact of all

the wind turbines.

Effects are combined with the

effects of the other

RES

High. Continual effect

throughout operation.

Reversible

Temporary depending

on period of operation

Very low to low – in 2009 wind energy represented

0,1% of gross energy consumption

and in the near future it is expected to reach 2 %

EU targets achieveme

nt and National

effect

Positive

1.2 Support compliance

with the Bulgarian national

targets for % of energy

from RS in the gross

final energy consumption

1.2.1 Contribution to the compliance with 2010 (11% share of energy from RS in the gross inland

electricity consumption) and

2020 (16% share of energy from RS in

the gross final energy

consumption).

Change the % of RES in

the final energy

consumption.

Value = H

Vulnerability = L


the wind turbines.


effects of the other

RES.

High Continual effect


Reversible

Temporary depending


Medium - in 2009

wind energy

represented 0.6%

of the gross inland energy

consumption, but it

is expected to reach 12,7%


nt and National

effect

Positive


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SER Objective

Indicator/Receptor



Cumulative/ secondary/ synergistic interactions


Duration(construction,

operation, decommissioning) and frequency



Spatial extent &

trans-boundary

Positive/ Negative


1.3 Reduce the overall

emissions of greenhouse

gases associated with energy generation

and support compliance

with the Bulgarian

greenhouse gas

emission targets.

1.3.1 Contribution to the compliance with

the 2012 (8% reduction from 1988

levels) and 2020 (20% increase from

the 2005 levels).

Change the Bulgarian

greenhouse emissions patterns.

Value = H

Vulnerability = L

Cumulative impact of all the wind

turbines.

Effects are combined with RES strategy.

The zero

emissions of wind power

developments will be cumulative with

hydro and solar developments.



Reversible

Temporary depending


Very Low – even if all

wind power projects

with preliminary contracts

are implement

ed, the contribution of wind power to

GHG reductions is expected

to be relatively

low.


nt and National

effect

Positive


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SER Objective

Indicator/Receptor




Probability

(H/M/L/VL)





Spatial extent &

trans-boundary

Positive/ Negative


1.4 Reduce the overall

emissions of air quality pollutants associated with energy generation

and support compliance with the air

quality pollutants targets.

1.4.1 Contribution to the compliance with the 2010 and 2015

air emission reduction targets for SO2, NOx, PM and

Hg (set by the National

Environmental Strategy 2009-2018).

Change emissions

of air quality

pollutants.

Value = H

Vulnerability = L


the wind turbines.


effects of the other RES.



Reversible

Temporary depending


Very low – even if all wind power projects with preliminary contracts

are implemented

, the contribution

of wind power to air

pollution reductions is expected to be relatively

low.

EU targets achievement

and National

effect

Positive


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Appendix B2: Cultural Heritage - Evaluation of significant effects

SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative

Cultural Heritage

2.1 Reduce

the risk of potential impact on

the boundaries

of the Bulgarian and World Cultural Heritage

Properties

2.1.1. Avoid direct and minimise visual impact on Bulgarian World and National Cultural Heritage

properties

Physical effects and potential

damage of the

Bulgarian World and National Cultural heritage

Properties.

Value = H

Vulnerability = L

No cumulative/secondary synergistic interactions were

identified.

Low to medium – will

depend on the

identification/classification

of the properties.

Continual effect during construction

and operation period.

Irreversible

Not possible to assess - impacts are likely

to be locally

specific and

additional information

on the location

status and past

impacts needed.

Local/regional land trans-boundary

effects

Zone of visual

influence confined to

the wind park

Negative


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Appendix B3: Flora, Fauna and Biodiversity - Evaluation of significant effects

SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative

Flora, Fauna and Biodiversity

3.1 Reduce

the risk of potential impact on threatened

and migratory birds and

bats

3.1.1 Avoid impacts on migration

bottleneck sites of globally and EU protected bird

species (more than 5000 storks and pelicans or more

than 3000 raptors)

Damage of protected

bird species naturally

living in the wild. Barrier effect and

disturbance to the energy

balance of the birds (by

trying to avoid the

wind farms)

Value = H Vulnerability =

H

Assessed in Section 6.1.3

Medium - depends on the projects dimension

Long term Irreversible

Not possible to

assess can vary from very

low to high

Тrans-boundary

effect

Negative

3.1.2. Avoid impacts on roosting sites of globally and EU protected bird

species


H

3.1.3. Avoid impacts on staging

areas and flying corridors of globally and EU protected

raptors and vultures

Damage of protected

bird species naturally

living in the wild.


H


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SER Objective

Indicator/Receptor





Duration (construction,


and frequency



Spatial extent &

trans-boundary

Positive/ Negative


3.1 Reduce potential impact on threatened


bats

3.1.4. Avoid impacts on staging and feeding areas of globally and EU protected wintering geese, swans and

ducks

Disturbance of natural

habitats. Displacement effect (passive habitat loss); disturbance and collision

risk.


H

Cumulative impact of wind

turbines through increase in the number of the turbines or in

combination with other activities



Not possible to


low to high

National and trans-boundary

effects

Negative

3.1.5. Avoid impacts on

wetlands with waterfowl

concentrations and waterfowl colonies

(regardless of season)


habitats. Damage of congregator

vulnerable bird species

(mortality, disturbance,

barrier effect).


H


breeding and feeding areas of globally and EU

protected raptors and vultures


habitats. Damage of

protected bird species

naturally living in the wild.

Could affect the viability of

population.


H


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SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative




bats

3.1.7. Avoid impacts on areas of

reintroduction of globally and EU protected bird

species

Disturbance

of natural habitats.

Damage of protected bird

species naturally living

in the wild. Could affect

the viability of population.


H Cumulative impact of

wind turbines through

increase in the number

of the turbines or in combination with other activities



Not possible to


low to high


effects

Negative


Important Bird Areas

Damage of

protected bird species


Disturbance of natural habitats.


H

3.1.9. Avoid impacts on areas

around the boundaries of

protected territories, specifically

designated for bird protection


H


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SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative




bats


breeding and feeding areas, and migratory routes for bats.

Disturbance

of natural habitats.

Damage of protected bats

species naturally living

in the wild. Could affect

the viability of population.


H

Cumulative impact of

wind turbines through

increase in the number

of the turbines or in combination with other activities



Not possible to


low to high


effects

Negative

3.1.11. Consider the variations in the behaviour of different bat and

bird species towards wind

turbines.

Damage of

protected bird and bats species


Disturbance of natural habitats.


H


H


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SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative


3.2 Reduce the risk of potential impact on protected

habitat types and

plants

3.2.1 Minimise the impacts on

bottleneck sites for migration of large carnivores outside of NATURA 2000

sites.

Disturbance of plant and

animal species within and outside

the protected areas.

Value = H Vulnerability

= H

Cumulative impact of wind turbines through

increase in the number of the turbines or in



Medium – mostly during construction

phase

Temporary and in

particular cases can

be irreversible

Not possible to


low to high

National and

regional effects

Negative 3.2.2 Minimise the

impacts on threatened plant

species.





= H Value = H

Vulnerability = H





= H


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SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative


3.3 Reduce

the risk of potential impact on Protected territories (under the Bulgarian Protected Territories

Act)

3.3.1 Avoid impacts in protected territories.

Damage of the biological diversity in the eco-systems

and the natural

processes proceeding in

them.


= H

Cumulative impact of wind turbines through





Not possible to


low to high


effects

Negative


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SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative


3.4 Reduce

the risk of potential impact on NATURA 2000 sites

3.4.1 Avoid impacts on NATURA 2000 SPA

sites.

Damage of the biological diversity in the eco-systems

and the natural

processes proceeding in

them.


= H

Cumulative impact of wind turbines

through increase in the number of the

turbines or in combination with other activities


Long term

Irreversible

Not possible to


low to high


effects (for SCI and

SPA)

Negative

3.4.2 Avoid impacts on NATURA 2000 SCI

sites.

3.4.3 Avoid significant deterioration on all

habitats of the species in Annex 1 of the

Habitat Directive in NATURA 2000 sites. Disturbance

of plant and animal species

within and outside the protected

areas.


H Cumulative impact of

wind turbines through increase in the number of the

turbines or in combination with other activities



effects

3.4.4 Avoid significant deterioration of all

habitats of the species included in Annex II of the Habitat Directive

inside NATURA 2000.


H

3.4.5 Avoid disturbance of species under Annex II of the

Habitat Directive inside NATURA 2000 - large

carnivores.


H


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SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative


3.5 Reduce


forests

3.5.1 Minimise the impacts on high

conservation value forests.

Disturbance of

characteristic landscape

and the remarkable

natural spots.


= H Cumulative impact of wind turbines through



Low Medium term Irreversible

Not possible to


low to high

Local Negative

3.5.2 Minimise the impacts on forests

with special designation.


= H

3.5.3 Minimise the impacts on forested

areas.

Value = L Vulnerability

= H


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Appendix B4: Soil and Water - Evaluation of significant effects

SER Objective

Indicator/Receptor









Spatial extent &

trans-boundary

Positive/ Negative

Soil and Water

4.1 Reduce

the risk of potential

contribution to soil

erosion.

4.1.1 Minimise the contribution to soil

erosion.

Potential for disturbance of soil structure

and functions.

Value = L

Vulnerability = L

No secondary or cumulative effects.

Low - according

to Soil experts

Long Term

Reversible

Temporary depending on

period of construction

Medium – around 30 % of the country’s territory has high risk of

erosion

Local effect Negative

4.2 Reduce


mobilization of

anthropogenic contaminants

during construction

.

4.2.1 Minimise the mobilization of anthropogenic contaminants

during construction.

Potential for mobilization of anthropogenic contaminants

during construction.

Value = L

Vulnerability = L

No secondary or cumulative effects.

Very low – unlikely to happen

according to Soil experts

Short term depending on


Reversible



Low – Contamina

ted soils represents less than

10%



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Appendix B4: Soil and Water - Evaluation of significant effects

SER Objective

Indicator/Receptor









Spatial extent &

trans-boundary

Positive/ Negative

Soil and Water

4.3 Protect soil

resources with

significant economic

value

4.3.1 Minimise the area of soil

resources with significant

economic value which land use has been changed as a

result of wind power development

(ha).

Potential for conversion of

fertile agricultural land into lands for

industrial use.

Value = H

Vulnerability = L

No secondary effects.

Cumulative effects with solar power

generation and other

development activities

Medium - depends on the volume

of investments

projects

Long term – throughout

construction, operation and

decommissioning

Irreversible permanent land

use change takes place

Not possible to assess

can be low or high

National effect

Negative

4.4 Reduce


impact on surface

water and groundwater quality

4.4.1 Minimise the impacts on water quality of surface

water bodies.

Disturbance of surface

water resources and

spread the contamination

on surface water bodies.

Value = L

Vulnerability = L


Low - according to water experts

Short term during the period of

construction and short intervals

during the period of operation

Reversible

Temporary Low Local effect

Negative

4.4.2 Minimise the impacts on water

quality of groundwater water

bodies.

Disturbance of

groundwater resources and

spread the contamination

of groundwater

bodies.

Value = L

Vulnerability = L


Low - according to water experts

Short term during the period of

construction and short intervals

during the period of operation

Reversible

Temporary Low Local effect

Negative


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Appendix B5: Landscape - Evaluation of significant effects

SER Objective

Indicator/Receptor







and frequency



Spatial extent &

trans-boundary

Positive/ Negative

Landscape

5.1 Reduce

the risk of potential negative

landscape transforma

tion

5.1 1 Minimise the impact on land use

and land use change.

Disturbance on land use and land use

change.

Value = L

Vulnerability = L

Cumulative effects with other land

uses. Effects are combined

with future construction

projects.

Medium - according to experts

Continual effect throughout

construction and operation.

Reversible


period of operation

Low Local effect Negative

5.1 2 I Minimise the impact on landscape

sensitivity, vulnerability and

resistance of landscape units.

Damage natural

landscape.

Value = L

Vulnerability = L

Medium - according experts


construction and operation.

Reversible


period of operation


5.2 Reduce


visual value of

landscape

5.2.1 Distance of wind power developments to protected zones, protected territories,

tourist areas and recreation areas.

Damage natural

landscape.

Value = H

Vulnerability = H

The implementatio

n of wind turbines can progressively

increase visual impacts on landscapes.



Reversible


period of operation

Low - about 30% of total land area in Bulgaria is protected.


5.2.2 Minimise the loss of aesthetic

values.

Damage natural

landscape.

Value = L

Vulnerability = L

Medium Continual effect


Reversible


period of operation



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Appendix B6: Public health, Noise and Vibration - Evaluation of significant effects

SER Objective

Indicator/Receptor





Duration(construction, operation, decommissioning) and

frequency



Spatial extent &

trans-boundary

Positive/ Negative

Public health, Noise and Vibration 6.1

Reduce the risk of potential impact

from noise caused by

the interaction

of the turbine blades with the

wind

6.1.1 Distance of wind power

developments from settlements.

Increase of noise levels due to wind

power development.

Value = L

Vulnerability = L

Secondary effects on

public health. Low

Continual effect throughout operation.

Reversible


period of operation

Not possible to assess can be low or

high


6.2 Reduce


public health due to shadow

flicker effect

6.2.1 Distance and orientation of wind

power developments in

relation to settlements.

Disturbance of the citizen’s

health.

Value = L

Vulnerability = L

Secondary effects on

public health. Low


Reversible


period of operation

Not possible to assess can be low or

high



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Appendix B7: Socio-Economic and Material Assets - Evaluation of significant effects

SER Objective

Indicator/Receptor









Spatial extent &

trans-boundary

Positive/ Negative

Socio-Economic and Material Assets

7.1 Reduce

the effect on

property values of

developed area and adjacent

properties.

7.1.1 Real estate values in areas affected by wind

power development prior to and after

the implementation of wind projects.

Real estate values vary when wind

power development

s are planned.

Prior implementati

on prices arise, after wind power construction

prices diminish.

Value = L

Vulnerability = L

Effects are combined with

future construction projects.

Medium – will depend on global economic

trends.

Continual effect during

construction and operation period.

Reversible

Temporary

Not possible to assess can vary from

very low to high and impacts

are likely to be locally specific

and a sigh broad of surveys would be need to correctly

assess the impact

Local/ regional effect

confined to the areas

nearby the wind

projects

Not possible to assess can be positive or negative


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SER Objective

Indicator/Receptor






operation, decommissio

ning) and frequency



Spatial extent &

trans-boundary

Positive/ Negative

Socio-Economic and Material Assets

7.2 Attain positive

contribution towards employme

nt and secondary economy.

7.2.1.1 Impact of wind power

development on employment.

Change in employment

during construction

due to creation of unskilled

jobs.

Value = L

Vulnerability = L

Effects are combined with future

construction projects.

Low – will depend on

global economic

trends.


construction period.

Reversible

Temporary

Low – no information

on significant increase of

employment



nearby the wind projects

Positive

7.2.1.2 Impact of wind power

development on regional GDP.

Increase of regional

income due to local

developments.

Value = L

Vulnerability = L

Effects are combined with other regional projects.

Low – will depend on global economic

trends.


operation period.

Reversible

Temporary



GDP




Positive

7.3 Reduce the risk of potential impact on

other sectors

(conventional tourism, hunting,

eco-tourism, etc.)

7.3.1 Coordination of wind power

investment projects with existing

economic regional development plans.

Impact on other

economic sectors due

to wind power

development.

Value = L

Vulnerability = L

Effects are combined with other regional projects.

Very low – will depend on global economic

trends.


operation period.

Reversible

Temporary



GDP




Not possible

to assess can be positive

or negative


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SER Objective

Indicator/Receptor









Spatial extent &

trans-boundary

Positive/ Negative

Socio-Economic and Material Assets 7.4

Reduce the risk of electroma

gnetic interferenc

es with signals

relevant to human

activities.

7.4.1 Electromagnetic

interference levels prior to and after

implementation of wind projects.

Electromagnetic effect from wind

parks.

Value = L

Vulnerability = L


future construction

projects.

Low – according

to wind experts


Reversible

Temporary depending



on significant electromag

netic interferenc

es




Negative

7.5 Contribute

to the developme

nt of power

transmission and road

infrastructure.

7.5.1 Length of power transmission

and road infrastructure

subject to construction,

rehabilitation or modernization

associated with wind-energy

projects.

Raise the development of roads and

others infrastructure

s. Improving country

connectivity.

Value = L

Vulnerability = L


future construction

projects.

Medium


construction, operation and

decommissioning.

May be permanent

or temporary depends on the project

Medium




Positive


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APPENDIX C: Example of a Metadata Form

GIS Metadata by Microreserves-EN

GIS Metadata Name

Data Name Microreserves-EN

Data Provider IB-BAS

Date of Registration Април 28, 2010

Identification Information

Abstract This is a polygon layer of 10x10km UTM squares, covering the territory of Bulagria. The layer contains

information on the areas which are expected to be designated as "microreserve" protected territories.

The future microreserves will occupy small areas (up to 10 ha) but their exact locations are currently

not known. Because of that UTM squares, in which the microreserves are located, are used. The precise

locations of the microreserves will be identified in the comming years.

Purpose This data set has been created as part of a project aiming to identify the exact locations of 47 rare

plant species, which have extremely small populations and which do not fall in any protected territory

(protected under the Protected Territories Act). Some of the future microreserves fall within Nature

2000 sites but not all of them. Most of these plants are included in Annex 3 of the Bulgarian

Biodiversity Act.

A project is currently being undertaken by the Institute of Botany at the Bulgarian Acadamy of Science

to map the precise locations of these rare plans and to set the boundaries of the future microreserves.

As part of the same project will be developed the management plans for the protected microreserves.

The Protected Territories Act is expected to be ammended with the addition of a new protected

territory category - microreserve. There are such microreserves already in Spain.

The microreserves will be with a maximum area of 10 ha and only one microreserve will be designated

for each specie. If a rare plant species is found at a few places, only one of them will be designated as

a microreserve. If two species are found in closely located areas, only one microreserve will be

designated for both of them.

The project has starrted in the begining of 2010 and is expected to end in 2013.

General DescriptionLanguage

BG

General DescriptionSupplementalInformation

None

General AccessConstraints

This dataset is been provided specifically to be used by the project "Strategic Environmental Review(SER) of the development of wind power in Bulgaria". It is a preliminary data set.

Use Constraints The data set can be used only by the SER of wind power development in Bulgaria project.

Data Set Credit None

Data SetEnvironment

Data Set Format ESRIShapefile

Current Reference 01.01.2010

Time Period StartDate

Яну. 1, 2010

Time Period EndDate

Юни 1, 2013

Status Process InWork

Status UpdateFrequency

Annually

Spatial DomainFrame

The territory of Bulgaria.

Entity and Attribute Information

Over Desc Dataset Overview The GIS layer contains infromation about the future microreserves for rare plant

Welcome to GIS METADATA site

Начало Metadata List

Copyright 2010 | GIS Metadata site | J05 Ltd.

GIS Metadata Site | Welcome to GIS METADATA site http://78.90.16.151:8006/metalist/76/

1 от 3 28.4.2010 г. 15:52

Over Desc Entity Attribute Overview

Detailed Desc Ent Type Label Microreserves for rare plants

Detailed Desc Ent Type Type Feature Class

Detailed Desc Ent Type Count 7

Detailed Desc Ent Type Definition

Detailed Desc Ent Type DefinitionSource

Attributes

AttributeLabel

AttributeType

AttributeWidth

AttributePrecision

AttributeDefinition

AttributeDefinitionSource

AttributeValueAccuracy

Attribute ValueAccuracyExplanation

AttributeMeasurementFrequency

id Integer 5 0 serial number 10 km the places wherethe plants arepresent arecircles withdiameter of 1km

the data isexpected tobecome moreaccurate

Objectid Integer 5 0 id of thesquare fromthe UTM gridof Bulgaria

IME Integer 5 0 the numericalpart of thecode of the10km UTMsquare

UTMFullname

String 10 0 the code ofthe 10kmsquare in UTMcoordinatesystem

Shape_Leng Real 20 0

Shape_Area Real 20 0 area of thepolygon in sq.m.

0.0001 m

Data Quality Information

General LogicalConsistency Report

The data set is comprised of 10x10 km squares.

GeneralCompleteness Report

The data has been compiled based on published information about the locations of the rare plants.

By the end of the project undertaken by the Institute of Botany at BAS (2013), which will identify

the boundaries of the microreserves, the data set will be updated and will become much more

precise.

Attribute AccuracyReport

The data set has low accuracy. It provides only a rough approximation of the locations of the future

microreserves. Each 10x10 km of the dataset however will contain a future microreserve.

Positional AccuracyHorizontal Accuracy

Positional AccuracyVertical Accuracy

Process Step None

Process Soft AndVersion

None

Process Date None

Process Time None

Spatial Data Organization

Spatial Reference Information

Welcome to GIS METADATA siteНачало Metadata List



2 от 3 28.4.2010 г. 15:52

Distribution Information

General ResourceDescription

The data set is owned by the Institute of Botany at the Bulgarian Academy of Science.

General Distribution Liability

General Custom OrderProcess

Access to the data can be granted by the Institute of Botany at BAS upon the receipt of an

official request.

General TechnicalPrerequisites

Software which can view *shape files.

Available Time Period Date 2013-06-01

Welcome to GIS METADATA siteНачало Metadata List



3 от 3 28.4.2010 г. 15:52


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Appendix D: Data sets detailed information

Appendix D1: Cultural Heritage

Appendix D2: Flora, Fauna and Biodiversity, except Birds

Appendix D3: Birds

Appendix D4: Soil and Water

Appendix D5: Public Health, Noise and Vibration

Appendix D6: Socio-Economic and Material Assets


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Appendix D1: Cultural Heritage – Detailed information

Legal basis for inclusion this area of constraint

The World Heritage Properties are being designate through a rigorous process which is outlined in detail in the Operational guidelines for the implementation of the World Heritage Convention. The boundaries of the World Heritage Properties are drawn “to ensure the full expression of the outstanding universal value and the integrity and/or authenticity of the property”. Further, “for the purposes of effective protection of the nominated property, a buffer zone is an area surrounding the nominated property which has complementary legal and/or customary restrictions placed on its use and development to give an added layer of protection to the property”. “Although buffer zones are not normally part of the nominated property, any modifications to the buffer zone subsequent to inscription of a property on the World Heritage List should be approved by the World Heritage Committee.” 75

Justification for designating the respective

level of constraint

Assigned as areas with explicit legislative prohibition for wind power development. Based on the requirements outlined in the Operational guidelines for the implementation of the World Heritage Convention, the World Heritage Properties and the buffer zones around them, as shown in the designation documentation of each property, can be considered as places where wind power development is prohibited.

Data sources Map with the location of each Bulgarian Cultural World Heritage Property has been downloaded from the UNESCO website: http://whc.unesco.org/en/statesparties/bg. Using these maps, the boundaries of the buffer zones around the properties were digitized in GIS and a single GIS layer (.shape file) was created.

Data quality During the digitizing process, the boundaries, as shown on the maps in the designation documents, where followed. Considering that the maps in the designation documents should be accurate, the resulting GIS layer is considered to be fairly accurate at land plot level.

Data gaps

Bulgaria has designated seven (7) Cultural World Heritage Properties and two (2) Natural World Heritage Properties (Pirin National Park and Srebarna Nature Reserve). The two Natural World Heritage Properties have not been included here because their boundaries coincide to a big extend with the boundaries of the respective protected territories, designated under the Bulgarian Protected Areas Act and are included with the rest of the protected territories in section 7.3.3. From the seven designated Bulgarian Cultural World Heritage Properties, only six are included in the GIS layer because the map of the Thracian Tomb of Sveshtari is not available on the UNESCO website.

75 All citations are from the Operational guidance for the implementation of the Word heritage Convention, 2008, p. 26-27


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Appendix D2: Flora, Fauna and Biodiversity, except Birds – Detailed information

A. Areas with conservation importance to bats

Legal basis for inclusion of this area of constraint

According to art. 37 of the Biological Diversity Act, all species, included in Annex 3 of the act should be protected throughout the whole territory of Bulgaria. All bat species in Bulgaria are listed in Annex 3. Further, since 1999, Bulgaria is a party to the EUROBATS agreement for the conservation of populations of European bats under the Bonn Convention.


level of constraint

Assigned as areas with low, medium or high sensitivity to wind power development. The identification process of areas with conservation importance to bats in Bulgaria was based upon both published literature data and the unpublished database of the Bat Research and Conservation Center at the National Museum of Natural History in Sofia. Fifteen major literature sources in combination with critical expert judgment were used to outline the size and form of 99 polygons. Five polygons were determined to be with medium sensitivity to wind power development, 59 with high sensitivity and 35 with very high sensitivity. The size, shape and level of sensitivity for each polygon were based on the following parameters: local species diversity, population abundance, migration/dispersal potential, number of underground roosts and quality of the surrounding forests. Each parameter was assigned a few degrees of importance and each degree was given certain number of points. For example, depending on the number of bat individuals in a particular area (all species), the parameter “population abundance” was assessed as having medium importance (number of individuals is less than 500), high importance (between 500 and 1000 individuals), very high importance (1001-5000 individuals) or extremely high importance (over 5001 individuals). Each of these degrees of importance was assigned certain amount of points – medium importance = 1 point, high = 3 points, very high = 5 points and extremely high = 10 points. The same approach was taken for all five parameters. At the end, for each polygon, the points of the five parameters are summed and polygons with a total score 0-9 were assigned medium conservation importance for bats, polygons with score 10-19 – high conservation importance and polygons with score more than 20 – very high conservation importance. The protection of the identified zones will ensure the protection of important bat roosts and habitats and will minimize the impact of wind power development in Bulgaria on the protected bat populations. Detailed explanation on the identification approach is provided in a separate report included in Appendix E of the current report.

Data sources The identification of the areas with conservation importance for bats was conducted by Mr. Boyan Petrov at the Bat Research and Conservation Center at the National Museum of Natural History, specifically for the elaboration of this report.

Data quality The boundaries of the polygons are drawn in Google Earth and in most cases, the physical-geographic elements such as river valleys, forest areas, water bodies, etc, which are important for the breeding, feeding, migration or distribution of bats, were followed.

Data gaps The polygons are drawn based on existing information. The size and shape of each polygon reflect the level of knowledge of the particular region, as of February 1st, 2010. The discovery of new caves and/or large bat colonies should result either in changes to the existing polygons or addition of new polygons.


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B. Annex I habitats in pSCI/SCI NATURA 2000 zones


According to art. 6 of the Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, Bulgaria has to take appropriate measures to prevent the deterioration of the natural habitats in the designated Sites of Community Interest (SCI). In Bulgaria, SCIs are designated under art. 6 of the Bulgarian Biodiversity Act to protect the natural habitats listed in Annex I of the act and the habitats of the species listed in Annex II of the act.


level of constraint

Assigned as areas with high sensitivity to wind power development. According to art. 6 (2) of the Habitat Directive, Bulgaria has to avoid damaging activities that could significantly disturb the species or deteriorate the natural habitat types or habitats of protected species. The construction of wind power turbines, their auxiliary installations, as well as the access roads, is expected to significantly deteriorate the natural habitats in NATURA 2000 zones if constructed on them.

Data sources GIS data on grassland habitats (Annex I habitats) has been provided by Balkani Wildlife Society.

Data quality

This GIS layer had been created by merging two data sets together. The first data set consisted of grassland habitats within pSCI/SCIs NATURA 2000, mapped as part of various grassland mapping projects. The second data set was based on CORINE Landcover and consisted of grassland habitats, territories with dispersed vegetation, and agricultural lands with high portion of natural vegetation (CLC grasslands) – all within pSCI/SCIs NATURA 2000.

Data gaps

Grassland habitats are not the only habitats included in Annex I. However, information in the appropriate format was not available for the other habitat types. A large scale project for mapping of habitats in all pSCI/SCI NATURA 2000 sites in Bulgaria is being prepared and is expected to be completed within the next three years. The results of this upcoming project should be incorporated in future updates of this environmental and social constraints analysis.


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C. Habitats of Annex II species in pSCI/SCI NATURA 2000 zones


According to art. 6 of the Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, Bulgaria has to take appropriate measures to prevent the deterioration of the habitats of the species listed in Annex II of the Directive. In Bulgaria, SCIs are designated under art. 6 of the Bulgarian Biodiversity Act to protect the natural habitats listed in Annex I of the act and the habitats of the species listed in Annex II of the act.


level of constraint

Assigned as areas with high sensitivity to wind power development. According to art. 6 (2) of the Habitat Directive, Bulgaria has to avoid damaging activities that could significantly disturb the species or deteriorate the natural habitat types or habitats of protected species. The construction of wind power turbines, their auxiliary installations, as well as the access roads, is expected to significantly deteriorate the habitats of protected species in NATURA 2000 zones if constructed on them.

Data sources

GIS data set has been provided by Balkani Wildlife Society about the habitats in pSCI/SCI NATURA 2000 zones for the following species: Marble polecat (Vormela peregusna), Romanian hamster (Mesocricetus newtonii), Tortoise (Testudo sp.) and European souslik (Spermophilus citellus), all of which are included in Annex II of the Habitat Directive, as well as in Annex 2 (or 2a) of the Bulgarian Biodiversity Act.

Data quality

This GIS layer had been created by merging four data sets together – one data set for each species. The data set for Marble polecat was based on a model, created by the Bulgarian Academy of Science for the most suitable habitats for the specie, where altitude, habitat size and region were taken into account. The data set used data from CORINE Landcover. The data set for Romanian hamster was created in a similar manner. The data set for Tortoise (two species - Testudo graeca and Testudo hermanni) was based on field data collected in 2005-2006 as part of a Bulgarian-Dutch project for the establishment of NATURA 2000 network. CORINE Landcover data was used and the following parameters were also taken into account: slope, altitude and exposition. The data set for the European souslik was based on actual mapping of known colonies of the specie, conducted by the Biology Department at the Sofia University and CORINE Landcover was used as a base layer. The resulting data set is contained within the boundaries of the pSCI/SCI NATURA 2000 sites.

Data gaps

The five species included in the dataset are just few species from the long species list in Annex II of the Habitat Directive and Annex II of the Bulgarian Biodiversity Act. A large scale project for mapping of habitats protected under the Habitat Directive in all pSCI/SCI NATURA 2000 sites in Bulgaria is being prepared and is expected to be completed within the next three years. The results of this upcoming project should be incorporated in future updates of this environmental and social constraints analysis.


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D. Disturbance avoidance of Annex II species in pSCI/SCINATURA 2000 zones


According to art. 6 of the Directive 92/43/EEC on the Conservation of the natural habitats and of the wild fauna and flora, Bulgaria has to take appropriate measures to avoid disturbance of the species for which the protected areas have been designated. In Bulgaria, SCIs are designated under art. 6 of the Bulgarian Biodiversity Act to protect the species included in Annex II of the act.


level of constraint

Assigned as areas with high sensitivity to wind power development. According to art. 6 (2) of the Habitat Directive, Bulgaria has to avoid damaging activities that could significantly disturb the species or deteriorate the natural habitat types or habitats of protected species. The construction and operation of wind power turbines, their auxiliary installations, as well as the access roads, is expected to significantly disturb the protected species. The Grey wolf (Canis lupus) and Brown bear (Ursus arctus) are species listed as requiring priority protection of their habitats because they are threatened of extinction – they are included in Annex II and IV of the Habitat Directive and Annex II of the Bulgarian Biodiversity Act.

Data sources GIS data set with areas within the pSCI/SCI NATURA 2000 zones where disturbance should be avoided for Canis lupus and Ursus arctus has been provided by Balkani Wildlife Society.

Data quality

This GIS layer had been created by merging two data sets – one for Canis lupus and one for Ursus arctus. The data set for Ursus arctus contains habitats which are suitable for bear dens, using the methodology outlined in the official action plan for the protection of Ursus arctus and CORINE Landcover 2000. From all potentially suitable areas for bear dens, only the most suitable ones are included. The data set for Canis lupus had been prepared in a similar way.

Data gaps

There are no known data gaps in the data set for Canis lupus and Ursus arctus. Future field studies may lead to the need to update the size and shape of the areas. Even though there are other species in Annex II of the Biodiversity Act for which disturbance in NATURA 2000 should be prevented, because of the large areas which bears and wolf require for their normal functioning, it is considered that the areas for these two species sufficiently cover the rest of the species in the pSCI/SCI NATURA zones.


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E. Avoidance of bottleneck sites of Annex II species outside pSCI/SCI NATURA 2000


Brown bear (Ursus arctus) is included in Annex II and IV, as well as in Annex III to art. 37 of the Bulgarian Biodiversity Act. As such, this specie has to be protected throughout the territory of Europe and Bulgaria – both inside and outside the NATURA 2000 sites.


level of constraint

Assigned as areas with medium sensitivity to wind power development. This data set represents the bear bottleneck areas located between NATURA 2000 network sites. These areas are important for the unimpeded movement from one protected zone to another. The construction and operation of wind power turbines in these bottleneck sites can pose significant disturbance to the bears and prevent them from using then, thus posing an overall negative impact on the bear populations.

Data sources GIS data set with bottleneck areas for Brown bear (Ursus arctus) located outside of the pSCI/SCI NATURA 2000 zones has been provided by Balkani Wildlife Society.

Data quality The data set for Ursus arctus contains habitats which are suitable for bear dens, using the methodology outlined in the official action plan for the protection of Ursus arctus and CORINE Landcover. From all potentially suitable areas for bear dens, only the most suitable ones are included.

Data gaps There are no known data gaps in the data set for Ursus arctus. However, the layer may need to be expanded if spatial information becomes available about other species which have bottleneck areas outside the pSCI/SCI NATURA 2000 network.


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F. Proposed plant microreserves


The Bulgarian Protected Areas Act (PAA) specifies six types of protected territories: reserves, maintained reserves, nature parks, national parks, natural monuments and protected sites. There are 47 rare plant species in Bulgaria which have very small populations and which do not fall within any of the currently designated protected territories. To protect the populations of these rare plant species, the Ministry of Environment and Water is planning to amend the Protected Territories Act to include a seventh protected territory category – microreserves. For each of the 47 rare plant species one microreseve will be designated with a maximum area of 10 ha. The designation of these areas is expected to be completed within the next 5 years.


level of constraint

Assigned as areas with low sensitivity to wind power development. Currently, the available information about the locations of the populations of these 47 plant species is limited to 10x10 km UTM squares where these species have been observed. In January 2010, the Institute of Botany at the Bulgarian Academy of Science (BAS) started a project aiming to determine the precise boundaries of these future microreserves. This project is expected to end in the middle of 2013.

Medium sensitivity level has been assigned for the 10x10 km UTM squares within which microreserves are expected to be designated because there is a possibility that a rare plant species population is located anywhere in the square but further studies are needed in order to determine the precise location of the population.

If wind power development is planned within such UTM square before the official designation of these microreserves, it is recommended that the Institute of Botany is contacted and a request is submitted for the most recent information on the location of the rare plant population in order to assess properly the impact of the wind power development on this proposed microreserve.

Data sources The data was provided by the Institute of Botany at the BAS.

Data quality The data set is very low precision (10x10 UTM squares) and as soon as the project of the Institute of Botany at BAS is completed, more updated data should be used.

Data gaps There are no data gaps identified in this data set.


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G. Important plant areas

Legal basis for inclusion of this

area of constraint

Important Plant Areas (IPAs) are natural or semi-natural sites exhibiting exceptional botanical richness and/or supporting an outstanding assemblage of rare, threatened and/or endemic plant species and/or vegetation of high botanical value. The identification of IPAs is based on the following three broad criteria: A) the site holds significant populations of species of global or regional concern; B) the site has exceptionally rich flora in a regional context in relation to its biogeography zone; C) the site is an outstanding example of a habitat type of global or regional importance. A site is identified as IPA if it fulfills one or more of these criteria. The identification of IPAs forms an integral part of the Convention on Biological Diversity (CBD) Global Strategy for Plant Conservation, which was first endorsed by governments all over the world in 2002. The creation of a network of IPAs helps to implement Target 5 of the Global Strategy for Plant Conservation, which aims to protect and conserve at least 50% of the most important areas for plants, as well as Target 5 of the European Strategy for Plant Conservation, which is the regional response to the CBD global strategy for plant conservation. Further, IPAs help to implement articles 6, 7 and 8 of the CBD on biodiversity strategies and in-situ conservation, and networks of IPA experts and volunteers help to implement articles 12 and 13 on national and international co-operation. IPAs inform the process for selecting Special Areas of Conservation (SAC) for the Natura 2000 network required by the EU Habitats and Species Directive, Areas of Special Conservation Interest (ASCI) for the Emerald Network proposed by the Bern Convention, as well as international wetland sites of importance through the Ramsar Convention.

Justification for designating the respective level

of constraint

Assigned as areas with low sensitivity to wind power development. IPAs are not legal site designations but are a tool for identifying and highlighting the best sites for plants and fungi which can be used to focus conservation actions and funding. The identification of IPAs aims to inform and provide support to the existing international, regional and national conservation programs and legislation.

The currently available data set about the locations of the IPAs in Bulgaria contains only the central coordinates of the areas, without specifying their actual sizes. This data set should be used only as a general guidance on the presence and location of IPAs at a particular territory. If a wind power project or another major development is considered in a close proximity to a point from this data set, further information should to be requested from the Institute of Botany at BAS on the actual boundaries of the respective IPA, its species diversity, species conservation status, etc. and this information should be taken into consideration in the EIA process.

Data sources The data set was provided by the Institute of Botany at the Bulgarian Academy of Science and had been prepared as part of a Plantlife International project.

Data quality The GIS layer contains the central coordinates of the Important Plant Areas in Bulgaria. The points are not representative of the actual size of the areas and they are with 5 km precision.


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Data gaps The data set contains 125 points and which coincides with the number of designated Important Plant Areas in Bulgaria.

Appendix D2: Flora, Fauna and Biodiversity, except Birds – Detailed information H. Protected territories


Under the Bulgarian Protected Areas Act, six types of protected territories are designated in Bulgaria: strict nature reserves, managed nature reserves, nature parks, national parks, natural monuments and protected sites. Various levels of restrictions are set in the act for each protected territory type.


level of constraint

Strict nature reserves, managed nature reserves, national parks, natural monuments and protected sites are assigned as areas with explicit legislative prohibition for wind power development, while natural parks as areas with high sensitivity to wind power development.

• Strict Nature Reserves – according to art. 17 (1), all activities shall be prohibited in strict nature reserves, except some activities which are directly related to the protection of the reserves;

• National Parks – according to art. 21, any construction, with the exception of hikers' shelters and chalets, water catchments for drinking purposes, treatment facilities, park management and visitor service buildings and facilities, underground communications, repair of existing buildings and roads, and sports and other facilities, shall be prohibited in the national parks.

• Natural Monuments – according to art. 24, any activities that may disturb the natural state of natural monuments or impair the aesthetic value thereof shall be prohibited in natural monuments.

• Managed Nature Reserves – according to art. 27 (1), any activities shall be prohibited in managed nature reserves, except some activities which are directly related to the protection of these territories;

• Nature Parks – according to art. 31, all activities and construction, which are not permitted in the park designation orders , park management plans and the spatial and technical plans and projects, as well as all activities which are specifically prohibited in the parks designation orders and the management plans, shall be prohibited in nature parks.

• Protected Sites – according to art. 34, any activities contrary to the requirements for conservation of the specific features subject to protection shall be prohibited in protected sites.

Data sources The data set for protected territories was provided by the Ministry of Environment and Water (MoEW).

Data quality The information provided by MoEW consisted of three separate GIS shape files (three separate data sets). One data set is called “parks” and contains the polygons of nature parks and national parks; another data set, called “reserves”, contains the polygons of the reserves and managed reserves; and a third data set called “protected territories” contains protected sites and natural monuments. The files were used as provided. It should be noted that the information in the data sets is partially mixed up. The “reserves” data set, for


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example, contains polygons of protected sites, and the file “protected territories” contains polygons of reserves. Since it was not certain whether this data presentation was done purposefully or not, the data was not changed and was used as provided. This potential duplication of a few of the protected territories currently is not leading to inaccurate results because the protected territory types which are mixed are all assigned the same level of sensitivity. However, if further analyses are performed, such as quantification what percentage of the territory of the country a particular environmental constraint occupies, then, it is crucial that all data sets are corrected.

Data gaps

The names and number of polygons in the “reserves” and “parks” datasets were checked against the list of protected territories displayed on the Environmental Executive Agency (EAA) website. It was found that no reserves, maintained reserves, national parks and natural parks were missing in the datasets. However, only 745 natural monuments and protected sites are included in the respective dataset, while according to the EAA website the number of protected territories in these two categories should be 851.


I. Sites of Community Interest (SCI) from NATURA 2000 network


The pSCI/SCI areas are designated to provide protection for certain natural habitats included in Annex I of the Habitat Directive and habitats of species included in Annex II of the Habitat Directive.


level of constraint

Assigned as areas with low sensitivity to wind power development. The pSCI/SCI areas are designated to provide protection for certain natural habitats included in Annex I of the Habitat Directive and habitats of species included in Annex II of the Habitat Directive. At present, there is no sufficient spatial data about the exact locations of the habitats for which the pSCI/SCI sites have been designated within these sites. Therefore, currently, without a field survey, it is hard to be sure that at a certain location within pSCI or SCI, a protected habitat or a habitat of a protected species is present.

A large scale project for mapping of habitats in all pSCI/SCI NATURA 2000 sites in Bulgaria is being prepared and is expected to be completed within the next three years. The results of this upcoming project should be incorporated in future updates of this environmental and social constraints analysis and they may determine a different sensitivity level for pSCI/SCIs.

Data sources The data set with the boundaries of the NATURA 2000 pSPIs/SCIs was provided by the Ministry of Environment and Water.

Data quality The data set represents the boundaries of the NATURA 2000 pSPIs/SCIs as they were proposed in 2007.

Data gaps The data set contains 228 polygons which correspond to the number of pSCI, hence, there are no identified data gaps in the data set.


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J. Biodiversity important forests (Categories HCVF1, HCVF3 and HCVF4)


The High Conservation Value Resource Network (HCVRN) is an international voluntary association of individuals, organisations and institutions who share a broad vision for the definition, identification and management of high conservation value forests (HCVF) and other ecosystems within the matrix of conservation and sustainable land use. According to the HCVRN, there are six types of high conservation value (HCV) areas:

• HCV1: Areas containing globally, regionally or nationally significant concentrations of biodiversity values (e.g. endemism, endangered species, refugia). This HCV is subdivided into: HCV1.1 – protected areas, HCV1.2 – threatened and endangered species, HCV1.3 – endemic species and HCV1.4 – critical temporal use.

• HCV2: Globally, regionally or nationally significant large landscape-level areas where viable populations of most if not all naturally occurring species exist in natural patterns of distribution and abundance.

• HCV3: Areas that are in or contain rare, threatened or endangered ecosystems.

• HCV4: Areas that provide basic ecosystem services in critical situations (e.g. watershed protection, erosion control).

• HCV5: Areas fundamental to meeting basic needs of local communities (e.g. subsistence, health).

• HCV6: Areas critical to local communities’ traditional cultural identity (areas of cultural, ecological, economic or religious significance identified in cooperation with such local communities).

The data set of biodiversity important forests, provided by the Bulgarian Society for the Protection of Birds is based on categories HCVF1 (1.1, 1.2 and 1.3), HCVF3 and HCVF4. The legislative support for these areas is provided below:

• HCVF1.1: The Bulgarian Protected Areas Act sets the framework for the protection of the areas designated as protected territories.

• HCVF1.2 and HCVF1.3: The plant, animal and fungi species which are threatened, endangered or endemic are listed in the IUCN Red List, the Bulgarian Red Book - Volume I and II, and the Atlas of endemic, endangered and rare species in Bulgaria.

• HCVF3: Rare, threatened or endangered forest ecosystems are usually protected under the Protected Areas Act (as protected territories) or under the Biodiversity Act (as NATURA 2000 sites).

• HCVF4: According to art. 53, art. 25 and art. 32 of Ordinance 3 for the conditions and order of investigation, designing, approval and operation of the sanitary protection zones around the water sources and the potable water supply facilities… (SG issue 88/2000) the forests in sanitary water protection zone I have to be recovered and maintained, while the forests in sanitary


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protection zones II and III are managed in accordance with the special forestry projects.


level of constraint

Assigned as areas with medium sensitivity to wind power development. Bulgaria has an obligation to achieve 16% share of energy from RS in its gross final energy consumption by 2020. However, Bulgaria also has an obligation to stop the loss of biodiversity by 2010, as well as to combat climate change. Construction activities in forests which have been identified by High Conservation Value Resource Network (HCVRN) as important for biodiversity should be approached with special care.

Data sources The data set for biodiversity important forests was provided by the Bulgarian Society for the Protection of Birds (BSPB).

Data quality

The data set provided by the BSPB contains categories HCVF1 (1.1, 1.2 and 1.3), HCVF3 and HCVF4. The layer which is generated from the provided data set, uses the following criteria for inclusion:

• Little or no sign of human influence;

• Average age of stand more than 100 years, where 100 is at least 20 years more than the commercial maturity;

• Endangered vegetation types;

• Rare or endangered forest dependent species are present;

• Limited access areas.

These criteria have been agreed upon by three forest experts, representatives of three different organizations. Limiting the biodiversity important forests only to those, which satisfy the above criteria, is done in order to focus the attention to the forests with the highest biodiversity value.

This data is the result of an international project conducted between Bulgaria and Romania and it was financed by the Danish Foundation Aage V. Jensens. A book has been published with the results of the study.

Data gaps No data gaps have been identified in the provided data set.


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K. Non-fragmented large forest landscapes (Category HCVF2)


The data set for non-fragmented forest landscapes corresponds to forests from category HCVF2, according to the categorization of the High Conservation Value Resource Network: Globally, regionally or nationally significant large landscape-level areas where viable populations of most if not all naturally occurring species exist in natural patterns of distribution and abundance.

The identification of these forest landscapes has been done in accordance with the national HCVF Toolkit - Identification, management and monitoring of forests with high conservation value in Bulgaria. There is no particular piece of legislation in Bulgaria which deals with this HCVF category.


level of constraint

Assigned as areas with low sensitivity to wind power development. The forests which contain viable populations of most or all local species should have large areas, to be relatively undisturbed by human activities and should have low fragmentation (% of non-forested areas). Forest territories with regional importance are those which within the region are unique in terms of their naturalness, fragmentation and support of the optimal viable populations of all naturally occurring species. Forest territories with national importance are those which are unique within the country in terms of their naturalness, fragmentation and support of the optimal viable populations of all naturally occurring species. The forests which are designated as being HCVF2 have to fulfill the criteria – naturalness, fragmentation and minimal size of the viable occurrence of the populations of the naturally occurring species.

Forests which fulfill the quantitative parameters of all three criteria are designated as non-fragmented large forest landscapes:

• Naturalness – the forest should have been formed by plant species with natural or mixed origin, where for deciduous species (oak and beech), sprout forests can be included as well. For the lower plain-hilly and hilly-mountainous belt of oak forest (between 0 and 600-800m altitude) the naturalness should be at least 70%, for the medium mountainous belt of the beech and coniferous forests (between 600-800 and 1 800-2 200m) – at least 80-90 %, and for the upper mountainous belt, including sub-alpine spruce and white fir (between 1800 and 2 500m) – at least 90%.

• Fragmentation – percentage of the anthropogenic landscapes within the boundaries of the designated territory and their spatial location. For the lower plain-hilly and hilly-mountainous belt of oak forest the fragmentation should be no more than 15 %, for the medium mountainous belt of the beech and coniferous forests – no more than 5 %, and for the upper mountainous belt, including sub-alpine spruce and white fir – no more than 3 %.

• Size – according to the vegetation type, their geographic distribution and the required territory for normal functioning of the populations of all naturally occurring species. For the lower plain-hilly and hilly-mountainous belt of oak forest the minimum size should be 10 000 ha, for the medium mountainous belt of the beech and coniferous forests – 25 000 ha, and for the upper mountainous belt, including sub-alpine spruce and white fir – 5 000 ha.


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Where possible, further anthropogenic fragmentation of these forest landscapes should be avoided.

Data sources This data set is provided by the World Wildlife Fund (WWF) Bulgaria.

Data quality The data set consists of 38 040 polygons which correspond to the smallest forest units (sub-department).

Data gaps There are no known gaps in the data set.


L. Forests with special designations

Legal basis for inclusion of this area of

constraint

According to art. 4 (2) of the Bulgarian Forest Act, the protective and recreational forests perform water protection, fire protection, ameliorative, recreational and other functions and are divided into the following categories:

• Water protection – water supply zones, watersheds of water bodies and water currents and regions around individual springs;

• Anti erosion – eroded forest lands; lands at steep and rocky terrains; the zone of the upper forest boundary; pine shrubs; the strips along the Black Sea, the Danube river and the large rivers; forest areas not suitable for trees, covered with bush vegetation; flooded forest lands and forests, created as part of technical projects for erosion control;

• Meliorative – protective forest belts, forests for the protection of engineering installations and forests around centers of industrial pollution;

• Recreational – resort forests and sites, caves, forest parks and green zones outside urbanized territories;

• Other – seed-producing plantations and gardens; forest nurseries; geographic crops; dendrariums; forests around individual or group cultural heritage and protection zones; research and development forests and forests for educational purposes;…; up to 200m around tourist huts and monasteries; buffer zones of reserves; intensive game breeding stations.

Justification for designating the

respective level of constraint

Assigned as areas with medium sensitivity to wind power development.

Even though there are no explicit legislative restrictions for the conduct of construction activities in these forest types, in practice, significant impacts on these forest types may lead to erosion problems, water supply problems, etc. Thus, the potentially negative effects of construction activities should be carefully assessed.

Data sources General data about the forests in Bulgaria was expected from the Executive Forest Agency. However, since information was not provided until the end of this Final Report, these areas were not included in the final spatial constraints analysis.

Data quality It was expected that the information from the Executive Forest Agency would be provided in .zem format. In order to use this data set together with the other data sets in the GIS database, major data processing would have to be undertaken. It is anticipated, for future project


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related developments that the conversion of the .zem files into .shape files will take at least four weeks.

Data gaps The completeness of the dataset should be evaluated when the data set is provided.


M. Forested areas


According to art. 1 of the Bulgarian Forest Act, the objective of the act is to preserve the Bulgarian forests as a national treasure – a main environment-forming factor, through their reproduction and sustainable development, as well as through multi-purpose use in the interest of the owners and the society.


level of constraint

Assigned as areas with low sensitivity to wind power development. The general forested areas are considered in this category – regardless of their naturalness, level of fragmentation, size and special functions. While Bulgaria has an obligation to achieve share of energy from RS in its gross final energy consumption by 2020, it also has an obligation to combat climate change and reverse the trend of biodiversity loss. Considering that forested areas are generally considered as contributing to the preservation of biodiversity and they are also a major carbon sink, where possible, the construction of wind power installations should avoid significant disturbance to permanently forested areas.

Data sources General data about the forests in Bulgaria was expected from the Executive Forest Agency. However, since information was not provided until the end of this Final Report, these areas were not included in the final spatial constraints analysis.

Data quality

It was expected that the information from the Executive Forest Agency (EFA) would be provided in .zem format. In order to use this data set together with the other data sets in the GIS database, major data processing wouldl have to be undertaken. It is anticipated, for future project related developments that the conversion of the .zem files into .shape files will take at least four weeks. The goal is to extract from the large database of the EFA the areas which are permanently forested.



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Appendix D3: Birds – Detailed information

A. Published sources of information

For the purpose of this project all publications about bird occurrence and distribution in Bulgaria were consulted. The most important publication are: Atlas of Breeding Birds in Bulgaria; Globally Threatened Species in Bulgaria. National Action Plan for their Conservation - Part 1; Mid-winter Count of Waterfowl in Bulgaria for the period 1997-2001; Important Bird Areas in Bulgaria and NATURA 2000; Raptor Watch; and The Birds of the Danube Plain.

• Atlas of Breeding Birds in Bulgaria. The book was published in 2007 and is the first breeding atlas of birds published in Bulgaria. It gives information about distribution, numbers, and historical changes in the populations’ since1859, as well as the preferred breeding habitats of 297 species of birds, breeding presently or in the past in the country. The present breeding status of birds is defined on a base of 10-years period of field studies – 1995-2005. The data are gathered by 475 ornithologists and birdwatchers. The bird distribution is presented on a base of standard Universe Transverse Mercator units – UTM squares 10x10 km. The preferred habitats of species are classified, using Classification of Palearctic Habitats. For the purpose of the SER, an electronic georeferenced copy of the atlas was used, in particular for the following species that are known as vulnerable to wind farms: Honney Buzzard, Black Kite, White-tailed Eagle, Short-toed Eagle, Marsh Harrier, Montagu’s Harrier, Levant Sparrowhawk, Long-legged Buzzard, Lesser Spotted Eagle, Golden Eagle, Booted Eagle, Peregrine Falcon, Red-footed Falcon and Orsey. For each species, the distribution data is combined with the preferred habitats for the specie, as well as the altitude at which the specie occurs. Based on all this information, for each of the above mentioned species, a map layer has been prepared that shows the most suitable habitat distributions. For the preparation of the map layer, used are only those UTM squares that hold all suitable habitats for the given species. Thus, UTM squares that include only one or part of the suitable habitats for the species are not included, nevertheless that the species is found to breed there according to the Breeding Bird Atlas.

• Globally threatened species in Bulgaria. National Action Plans for their conservation - Part 1. The book was published in 2002 and includes the national action plans elaborated for nine globally threatened species: Pygmy Cormorant (Phalacrocorax pygmeus), Red-breasted Goose (Branta ruficollis), Ferroginous Duck (Aythya nyroca), White-headed Duck (Oxyura leucocephala), Black Vulture (Aegypius monachus), Imperial Eagle (Aquila heliaca), Lesser Kestrel (Falco naumanni), Corncrake (Crex crex) and Slender-billed Curlew (Numenius tenuirostris). The national action plans are based on the European action plans for these nice species. Even though these action plans are not officially adobted according to the Bulgarian Biodiversity Act, which came into force after the book was published, they give concrete information about the species distribution, their conservation status in the country, as well as the threats and the priority actions that have to be taken on national level to prevent further decline of these species. The information about the Corncrake, the Pygmy Cormorant, the Red-breasted Goose, the Ferruginous Duck, the White-headed Duck and the Slender-billed Curlew was particularly used for the purpose of the Strategic Environmental Review.

• The Birds of the Danube Plain. The book was published in 2005 and provides relatively precise information about breeding species that are subject of Strategic Environmental Rivew in quite large part of the country – the Danube plain. It gives also the locations of the breeding colonies of herons, egrets and cormorants in the Danube plain.


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• Mid-winter Count of Waterfowl in Bulgaria for the period 1997-2001. The book was published in 2001 and provides detail information about the numbers of the waterfowl in 206 wetlands all over Bulgaria, including the coastal sea waters of Black Sea, for the period 1997-2001. It also describes the data collection methodology used during the mid-winter count in the period 1997-2008. The same methodology is used for the identification of wetlands vulnerable to wind farms.

• Fauna of Bulgaria. Vol.20. The book was published in 1990 and provides relatively detailed information about the distribution and ecology of the bird species from the orders of Gaviiformes, Podicipediformes, Procellariiformes, Pelecaniformes, Ciconiiformes, Falconiformes, Galiiformes, Gruiformes, Columbiformes and Strigiformes in Bulgaria. For the purpose of the Strategic Environmental Review, the published information about the migratory routes of the White Stork (Ciconia ciconia) along the Black Sea coast is used. This information is based on radar migration surveys carried out in 1982 and 1983. These surveys do not give information about the total number of passed birds, but they provide the most representative available data about the width of the migration route of the White Stork along the Bulgarian Black Sea Coast between the Batova River valley (near Albena Resort) and the state border with Turkey. For the purpose of the study, the radars of the civil airports of Varna and Burgas have been used. The flocks of white storks were detected in the region of Batova River valley and Albena Resort - they were detected on the field, as well by a mobile team, in order to identify the species composition of the flock. After that, they were followed by the radars until they left the country. Each of the detected flocks form its own trajectory. One hundred and twenty separate flocks are followed using this methodology. Because of the screen effect of the Frangensko Plateau, it was not technically possible to detect the flocks of migratory white storks above Dobrudzha and their trajectory to be followed above this region as well. However, from published map it is obvious that all the detected flocks passed through the Dobrudzha region.

• Raptor Watch. The book was published in 2000 and provides an overview of the known facts about the migration of raptors around the world, including Bulgaria. There are specific hot-spots of raptor migration described in the book. For each migration hot-spot, described are the location, the observed raptor species, the approximate number of migrating individuals if such data were available, and the relevant references. Seven of the published hot-spots in Bulgaria lie on the territory of the identified intensive migration corridor of Via Pontica.

• Important Bird Areas in Bulgaria and NATURA 2000. The book was published in 2007 and describes the Important Bird Areas in the country – their exact location, boundaries, species for which each site is designated (numbers during each season of occurrence of the species), threats to species and proposed conservation measures. The book includes information about the protection status of all species, occurring in Bulgaria, the national and European populations of the breeding birds (according to “Atlas of the Breeding Birds in Bulgaria” and “Birds in Europe: Population estimates, trends and conservation status”), the national and European populations of wintering birds, as well as the known migratory flyway populations of the soaring birds along the Bulgarian Black Sea Coast.


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B. Unpublished sources of information

The unpublished information which has been used for this Project includes:

• The National Bank for Ornithological Information (NBOI) is maintained by the Bulgarian Society for the Protection of Birds and is for the territory of Bulagria. The NBOI holds more than four million bird records during breeding, migration and winter season and has been collected over a period of about 30 years. The information is collected mainly through targeted field studies, conducted by ornithology experts or trained birdwatchers from BSPB, the Bulgarian Academy of Science, the Sofia University, as well as other institutions and organizations. The database includes data collected by ornithologists and birdwatchers that are collected during their own observations and provided voluntary to BSPB to be used for bird conservation purposes. This also includes international birdwatcher groups that regularly visit Bulgaria to practice bird watching. The data stored in the NBOI is validated by bird experts before it is entered into the database for further use. At a minimum, each bird record includes the species name, number of individuals observed, date, location, observer name, project/monitoring scheme/methods used for the data gathering.

• Field studies carried out by different organizations or ornithologoists under different projects. Most of this data is not published but was made available for the purpose of the Project.

o Data provided by ornithology experts at the Institute of Zoology of the Bulgarian Academy of Science – Petar Shurulinkov and Nikolay Karaivanov. Mr. Shurulinkov, PhD, has collected a significant amount of data about breeding areas, feeding areas, migrations routes, etc. during numerous field studies, related to mapping of the breeding bird fauna, identification of potential SPAs and other studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale. Mr. Karaivanov has conducted a numerous migration bird observations over the last few years, most of which have been related to wind power development projects.

o Green Balkans Federation has provided information on breeding and staging areas of raptors, as well as locations of reintroduction sites for threatened species. The information on breeding areas is based on field studies, where GPS coordinated has been taken of the exact nest locations. The information on staging areas (for Imperial Eagle and Black Vulture) is based on radio telemetry observations. Locations of reintroduction sites of Griffon Vulture is available because of the participation of Green Balkans in various conservation projects targeting the conservation of this species.


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C. Migration routes

Data sources

Published and unpublished data was used for determining sensitive areas along the migration routes. The data is based on targeted studies on migration of soaring birds along the Black Sea coast, conducted in the process of identification of bottleneck sites to be inclusion in NATURA 2000, data from regular monitoring of the migration in the Burgas lakes region and targeted studies of migration for the purposes of wind farm development in conducted in the Dobrudzha region. The migration along the Via Pontica migration route is studied by BSPB at 28 observation points for the period 2003 – 2009. At each of the observation points at least one full autumn migration period is studied (80 days from 10 August to 30 October). Both spring and autumn migration were studied at several of the observation points. At Balchik, Balgarevo and Hadzhi Dimitar observation points the autumn migration was studied during two consecutive years. The migration in the area of “Poda” protected area has been observed every year, both in autumn and spring, in the period 2003-2009. The methodology includes full day observation, every day during the migration period, using optics – binoculars and telescopes. This method is used for migration studies also at Bosphorus (Turkey) and Gibraltar. For each observation recorded are the bird species, the number of individuals, the height and the direction of flight, as well as their specific behaviour. Wherever possible, the observations of the Saker Falcons are documented with pictures. In addition, data about migration in the Dobrudzha region has also been provided by an ornithologist from the Institute of Zoology at the Bulgarian Academy of Science, Nikolai Karaivanov. Mr. Karaivanov has provided the Project team with a map of the intensive migration route of soaring birds in Dobrudzha region. This map has been elaborated by the author on a base of the results of visual migration observations which he has performed in relation to wind farm developments at 13 observation points in the region of Dobrudzha. Further data about bird migration was provided by another ornithologist at the Institute of Zoology at the Bulgarian Academy of Science, Petar Shurulinkov, PhD. Mr. Shurulinkov has conducted numerous migration observations, each 1 to 3 weeks long, in the period 1999-2009 in the region north, north-east, east and southeast of the town of Sliven, as well as observations of the spring migration in 2008 in the municipalities of Sredets and Karnobat. The data from these observations showed that at all these locations are migration bottleneck sites where the criteria for 5000 storks is satisfied and in most places, the criteria for 3000 migrating raptors is also satisfied.

Data quality

The polygons representing the intensive migratory routes have been created based on the above mentioned information. The boundaries of the polygons have been roughly drawn and at some places adjacent polygons either slightly overlap or slightly diverge.

Data gaps

Except for the Eastren part of Via Pontica migration route, the migration of birds through Bulgaria is not sufficiently studied or not studied at all. The western part of Via Pontica migration route and the migration routes along Danube River, Iskar River, Maritsa River, as well as the Via Aristotelis migration route (Struma and Mesta rivers) are not sufficiently studied. Having in mind that Bulgaria is located on major bird migration routes, large scale study on migration across the whole country should be carried out, including radar surveys, in order to identify and map all migration corridors.


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D. Roosting areas

Data sources

The data about the regular roosting sites for white storks was collected in 2004 by BSPB through surveys with questionnaires. The questionnaires were distributed to the mayors of all villages in the districts of Dobrich, Varna and Burgas. The questionnaires included questions about presence of areas in the around given settlement where big flocks of white storks regularly stop during migration period, as well as if these areas are used in autumn or spring. This method of data collation is confirmed as reliable because of the following reasons: the white stork is very well known and easily recognizable bird species, it is easy to identify and it does not avoid people. People that live in the settlements along the bird migratory route remember if in the surroundings of the settlements storks regularly concentrate, because this event happens every year and because usually it is a case of roosting of numerous flocks. Quantitative data were not collected, because it is known that the local people usually do not count birds and that the estimations on the number of birds on the land is too subjective and imprecise, especially when done by people that are not specially trained.

Data quality

The roosting points entered into GIS represent the approximate location of the roosting areas, while the territory covered by the roosting flocks of storks cover much larger territory.

Data gaps

The roosting areas of raptors along the Via Pontica migration route, where raptors are concentrated, are not known. The regular roosting sites of White Stork are not precisely mapped yet and also not all regular roosts have been identified. These data gaps have to be filled through future studies. Further, even the known roosting areas are with unknown size. Future studies are needed to determine their approximate size and enter a buffer zone of 2 to 5 km around the identified central point. Areas closer to the sea coast or areas with strong winds should have larger buffers (5 km) because birds can easily be “swept” to long distances until they find suitable currents.


E. Imperial Eagle – staging areas and flying corridors

Data sources

Data from the radio telemetry study, carried out by Green Balkans Federation during the period 2007-2009 on the territory of Sakar Mountain and Derventski Heights, was provided. Four young birds were equipped with TW-3 radio transmitters. The data was collected through the standard method of radio tracking, carried out for a two-week period each year. The data was first entered in a field notebook, and then processed as database and GIS. Data related to post-breeding and staging areas of Imperial Eagle were also collected through satellite tracking field studies of young birds. The satellite studies have been carried out by BSPB since 2007 and at the time of the preparation of this report, the studies still continue. In total of 8 young imperial eagles are equipped with GPS-Argos satellite transmitters (1 in 2008 and 7 in 2009). The birds are from three nests in Sakar Mountain, one in Wastern Standzha and one along Tundzha River. The results of the studies in 2008-2009 showed the movements


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of the birds after the breeding seasons, as well as the staging areas where the young birds prefer to stay. The study is carried out under the following projects:

• BG 2005/017-453.01.02.02. „Strandzha-Sakar – the Kingdom of Eagles”, financed by the PHARE Cross-border cooperation “Bulgaria-Greece” of the European Union. The project is executed by the Union for restoration and development (Haskovo, Bulgaria), Byukarishtran (Turkey) and BSPB.

• LIFE 07 NAT/BG/ 000068 „Conservation of Imperial Eagle and Saker Falcon in Natura 2000 sites in Bulgaria” financed through the Life+ fund of the European Union (http://www.saveraptors.org/en/page.php?cat=3&subcat=6). The project is executed by BSPB, in partnership with the BirdLife partners in UK and Hungary, the “Central Balkan” National Park Directorate and the Wild Flora and Fauna Fund.

Data quality

The polygons representing the staging areas of Imperial Eagle and the movement corridors have been created based on the above mentioned information. Points which are highly dispersed from the others are not included in the polygons.

Data gaps The staging areas and flying corridors of Imperial Eagle should continue to be studied in order to obtain a more complete picture of the areas important for this highly threatened and highly vulnerable to wind power development species.


F. Black Vulture – staging areas and flying corridors

Data sources

Data about the staging areas and flying corridors of Black Vulture has been provided by Green Balkans Federation. The known staging areas are identified through a radio telemetry study (biangulation and triangulation), conducted in the period 2005-2008 of individuals from a Greek population. The data has been first entered in a field notebook, then transferred into a database and GIS.

Data quality

The area is located in the Eastern Rhodopes Mountain and represents a single polygon drawn around the points recorded through the telemetry. Points which are highly dispersed from the others are not included in the polygon.

Data gaps Further studies are needed to identify all staging areas and flying corridors of this highly threatened and highly vulnerable to wind power development species.


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G. Saker Falcon – staging and flying corridor

Data sources

Data related to the post-breeding and staging areas have been collected through field studies - satellite tracking of young birds, as well as migration studies related to wind farm development. The data from the satellite tracking of the Saker Falcon had been provided to BSPB by MME/BirdLife Hungary (http://www.sakerlife.mme.hu/en/gmap). The study is carried out in the framework of a project for conservation of the Saker Falcon in Hungary and Slovak Republic – “Conservation of Saker (Falco cherrug) in the Carpathian basin LIFE06 NAT/HU/000096” financed through the Life+ fund of the European Union. For the period 2007-2009, five Hungarian saker falcons, equipped with satellite transmitters, passed the territory of Bulgaria (more than 100 GPS signals have been recorded on Bulgarian territory). BSPB experts keep active communication with the Hungarian experts and double-check the areas were the birds passed or staged. They also analyse the threats and the habitat quality on spot. At the time when this data was provided for the purposes of SER, these satellite tracking studies continue. The data about the migration corridors of the Saker Falcon was collected during standard migration surveys of migration (autumn and spring) of the soaring birds along the Black Sea Coast and along the Danube for the period 2003-2009 in a total of 33 observation points (5 of them along the Danube). The migration studies took place every day during the whole daylight period 10 August – 30 October in autumn migration and 15 March – 15 May in spring migration. Standard methodology of field study is used. This method is used for migration studies also at Bosphorus (Turkey) and Gibraltar. For each observation recorded are the bird species, the number of individuals, the height and the direction of flight, as well as their specific behaviour. Wherever possible, the observations of the Saker Falcons are documented with pictures.

Data quality

The data set contains two types of polygons – one for the staging areas and one for the flying corridors. Most of the polygons of flying corridors cross the polygons of the staging areas.

Data gaps Further studies are needed to identify all staging areas and flying corridors of this highly threatened and highly vulnerable to wind power development species.


H. Red-breasted Goose and other wintering geese

Data sources

Data of the known feeding areas of wintering geese, including Red-breasted Goose, identified between 1996 and 2009 are stored in the NBOI of BSPB. They are collected by: private observations, during the mid-winter counts (January, 1997-2008); targeted monitoring of Red-breasted Goose (twice per month from November to March, 2002-2009); a special study on feeding areas of geese in Coastal Dobrudzha, carried out in the period 1998-2000 under the framework of the Bulgarian-Swiss Biodiversity Conservation Programme; as well as targeted study on Lesser-White-fronted Goose carried out by Norwegian Ornithological Society. Besides the last two studies, additional data on feeding areas of geese is collected on


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irregular base thus even in Dobrudzha mapping of feeding areas of geese are not completed. All known feeding areas are mapped in GIS with the exact borders.

Data quality

The polygons have been drawn rather precisely, following land plot boundaries at most of the cases actual at the moment of drawing the polygons.

Data gaps Regular feeding areas of wintering geese are identified only along Coastal Dobrudzha and certain IBAs. The regular feeding areas of wintering geese in Dobrudzha, along the Danube, in the Burgas lakes region, as well as around the major wetlands in the Thracian Plain, still have to be identified and mapped. The same applies to the feeding areas of swans, which have not been studied at all.


I. Dalmatin Pelican – wintering areas

Data sources

The data set was provided by Petar Shurulinkov, PhD, ornithologist at the Institute of Zoology at the BAS and the data has been collected by Mr. Shurulinkov and Ms. Gergina Daskalova from the BSPB as part of a study conducted every year during the winters of the period 2004-2010. The study has determined that every winter up to 550 Dalmatian Pelicans winter in Ovcharitsa dam, located in SE Bulgaria and its surroundings. All of these birds or part of them move daily to the smaller lakes in the vicinity of Ovcharitsa dam (Prohorovo, Byal kladenets, Matsa, Mezda, Radnevo, Bolyarsko, Boyadzik, Roza and others).

Data quality

The polygons have been drawn precisely including areas of occurrence.

Data gaps The species is well studied. However it is possible new important wintering locations of the species to be found.


J. Waterfowl congregations (wetlands)

Data sources

Regular mid-winter counts of waterfowl in Bulgaria have been carried out since 1977. Between 1967 and 1977 studies were also conducted but they were only scattered. For the purposes of the SER, data is used from the 12-year period 1997-2008, because the majority of wetlands in Bulgaria were counted in this period. All data is stored in the NBOI of BSPB. During the period 1997-2008, more than 130 ornithology experts and birdwatchers from the Bulgarian Society for the Protection of Birds, BAS, Green Balkans Federation, Nature Park directorats, Regional Inspectorates of Environment and Water, State forestry departments, State game stations, coastal police, etc. Have participated in the mid-winter


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counts. The data has been collected through the full count method, where geese are counted early in the morning at roosting sites, cormorants are counted at sunset at roosting sites and other waterfowl are counted at wetlands during the day. Bigger wetlands or wetland complexes have been observed from more than one observation point and by parallel teams, in order to avoid double counting of birds. On a national scale, the bird counting in all wetlands in the country is carried out within 3-4 days. In addition to this information, data gathered by BSPB through regular monitoring of wetlands was also used. Such data was used for the Burgas wetlands (monthly monitoring during last ten years) and the lakes of Shabla and Durankulak (monitoring twice per month from November to March each year for the last eight years).

Data quality

This data set contains 65 polygons of wetlands (lakes, dams, marshes, rivers, etc.), which are important for migrating and wintering waterfowl. Around these wetlands 2 km buffer zones are set.

Data gaps Many of wetlands are not specially studied during migration period when they might be more important than during the mid-winter period.


K. Waterfowl colonies

Data sources

Even though many of the birds nesting in colonies live at wetlands important for migrating and wintering birds, there is still a considerable number of bird colonies, which live at wetlands, which do not have any importance for migrating and wintering birds. Thus, a separate GIS layer was created for waterfowl colonies.

Data about breeding waterfowl and waterfowl colonies was provided by the BSPB from its NBOI where it had been collected during the following projects: elaboration of management plans (Srebarna, Shabla, Durankulak, Poda, Atanasovsko Lake, Vaya Lake, Varna-Beloslav Lake, Belenski Islands Complex – 1996-2005); identification of wetlands of international importance; elaboration of GIS database of designated and potential Ramsar sites in Bulgaria (2003); gap filling field studies during the process of identification of Natura 2000 sites (2005); and IBA monitoring (1998-2008).

The data set from the NBOI of BSPB has been further supplemented with data provided by Peter Shurulinkov from the Institute of Zoology at BAS. This data set is composed of GPS coordinates of the central locations of bird colonies of herons (A. Ralloides), ibises (P. Falcinellus), cormorants (Ph. Carbo), spoonbill (P. Leucorodia), etc. Only colonies which are within 2 km from the boundaries of SPA NATURA 2000 sites have been included in the data set.

Data quality

Currently, the data sets provided by BSPB and the Institute of Zoology are presented as separate GIS layers. In the BSPB data set, 2 km buffer zones are set around the boundaries of the wetlands where the colonies live. In the data set of the Institute of Zoology, 2 km buffers are set around the central locations of the colonies. Both layers represent areas where wind power development should be avoided.

Data gaps The two sets do not cover all waterfowl colonies in Bulgaria and further studies are needed to complete the information.


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L. Imperial Eagle breeding areas

Data sources

Information about the breeding areas of Imperial Eagle was provided by BSPB. During the period 1997-1998 targeted field studies were carried out in Bulgaria to identify the breeding locations of the Imperial Eagle. This project was financed by the Ministry of Environment and Water. After the end of the project, the efforts to identify all nests of the species contained. All indentified nests are guarded since 10 year to now during the breeding season - from the start of the breeding season until the young birds leave the nests and their surrounding areas. A dossier is maintained for each of the nest, the exact nest locations are marked with GPS and entered in GIS. Each new nest is included in the monitoring system.

Data quality

The GIS layer was created by setting 15-km buffers around the known nests, localized in GIS, of Imperial Eagle. When a few nests were located in a close proximity a common polygon was created.

Data gaps

The species is well studied. When new nests are identified the layer should be updated.


M. Egyptian Vulture breeding areas

Data sources

Information about the breeding areas of Egyptian Vulture was provided by BSPB. Egyptian Vulture nests exclusively in rocky areas. It is typical for the species that one pair has several nests, which changes periodically through the years. The species usually flies long distances in the search of food. Studies to identify the nests of the species have started in the 1960s but in the period 1995-2005 most known nest were mapped and in 2003-2009, all nests were localized with a GPS and entered into GIS. A dossier is maintained for each of nest, which includes various information, including information on the periods when the nest has been occupied. After 2005, all nests are monitored annually.

Data quality

The GIS layer was created by setting 15-km buffers around the known nests, localized in GIS, of Egyptian Vulture. Three nest categories were identified: 1) nests occupied after 2000; 2) nests occupied between 1990 and 2000 but not after that, and 3) nests occupied before 1990 and not after that. When a few nests of the same category were located in a close proximity a common polygon was created.

Data gaps

The species is well studied. It is possible old abandoned nests to be re-occupied and new locations to be found but it is unlikely they to be out of the already known areas of distribution of the species.


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N. Saker Falcon breeding areas

Data sources

Information about the breeding areas of Saker Falcon was provided by BSPB. This information is stored in the NBOI of BSPB and has been collected by various sources of published information, as well as through field studies. The species is subject to studies in Bulgaria since the end of XIX century. Because it breeds on cliffs, all nests are known and were published with relatively precise locations in the second half of XX century. During the period 2006-2009, the known historical nests of the species were visited and their exact coordinated were taken with GPS. A dossier is maintained about each nest - its occupation, breeding success, as well as the peresecution cases (harvestin of eggs or young birds by poachers, etc.). All nests are monitored annually.

Data quality

In general, the GIS layer was created by applying a 10 km buffer around the known nests, localized in GIS, of Saker Falcon. However, because of the frequent destruction of nest of Saker Falcon, driving the population decrease, the information about the exact locations of the nests is not publically available. To avoid the possibility of easy identification of the nests from the generated maps, the polygons have been created in such a way, so that the polygons include the main nesting and feeding areas.

Data gaps

Studies on the recent localities of the Saker Falcon continue, as well as attracting new breeding birds through set of artificial nest boxes in the known breeding and staging areas. When new breeding localities are identified the layer should be updated.


O. Red-footed Falcon breeding areas

Data sources

Information about the breeding areas of Red-footed Falcon was provided by BSPB. The information is collected through a project for identification of recent breeding localities of Red-footed Falcon, carried out by BSPB. The nest was localized by BSPB field workers from Bourgas region.

Data quality

The data set contains a single polygon – a 4 km buffer around the single known nest in the Bourgas lake area.

Data gaps

Studies need to be continued to indentify more nests of this globally threatened species and the layer should be completed.


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P. Griffon Vulture breeding areas

Data sources

Information about the breeding areas of Griffon Vulture was provided by BSPB. Until the 1950s, Griffon Vulture was widely spread in the whole country – everywhere where suitable habitats existed. This abundance was due to the massive cattle breeding and the huge number of domestic animals. The only remaining colony of Griffon Vulture in Bulgaria (Eastern Rhodopes) is well known from decades. In the 1980s, artificial feeding stations started to be built. Currently, there are three artificial feeding stations for vultures in the Eastern Rhodopes, as well one more in Kotlenska Mountain, close to one of the former breeding places. The coordinated of the colony, the artificial feeding stations and the regular roosting sites, all located in Eastern Rhodopes, have been taken with GPS and entered into GIS. These areas subject to regular monitoring since 1988 and the data is stored in the NBOI of BSPB.

Data quality

The GIS data set for Griffon Vulture consists of a single polygon which was created by merging the 50 km buffers of the identified breeding, artificial feeding and roosting areas.

Data gaps

The species is well studied. Due to implementation of targeted conservation measures as artificial feeding and reintroduction of griffon vultures it is expected that species return to breed at other former breeding localities. Some success is observed in Kresna Gorge in 2010 and this process needs to be monitored.


Q. Black Stork breeding areas

Data sources

Information about the breeding areas of Black Stork was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs and verification of published data. Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Black Stork and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale. The species nests in forests or on cliffs and very much avoid human presence.

Data quality

The GIS layer was created by setting 2 km buffers around the known nests, localized in GIS, of Black Stork (data from BSPB) and by including the polygons, created based on the data provided by Mr. Shurulinkov.

Data gaps Relative small number of the nests of Black Stork is currently known and further studies need to be conducted to identify the rest. There are known nest, mainly on rocks, that are not mapped with GIS and are not included in present study. These nests should be mapped with GIS. The nests


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located in forest should be further found and mapped.


R. Honney Buzzard breeding areas

Data sources

Information about the breeding areas of Honney Buzzard was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs and verification of published data. The present exact locality is found as result of detailed mapping study of Bessaparski Hills SPA. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Honney Buzzard and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer was created by setting 5 km buffers around the known nest of Honney Buzzard (data from BSPB) and by including the polygons, created based on the data provided by Mr. Shurulinkov.

Data gaps The exact breeding localities of Honney Buzzard within the standard 10 km-squares, where the species is confirmed to breed, are not known, thus further studies need to be conducted to identify nests.


S. Black Kite breeding areas

Data sources

Information about the breeding areas of Black Kite was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of Sakar IBA and verification of published data. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Black Kite and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer was created by setting 5 km buffers around the known nests, localized in GIS, of Black Kite (data from BSPB) and by including the polygons based on the data provided by Mr. Shurulinkov.


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Data gaps The exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known in most of the cases, thus further studies need to be conducted to identify nests.


T. White-tailed Eagle breeding areas

Data sources

Information about the breeding areas of White-tailed Eagle was provided by both BSPB and Green Balkans. Data for the locations of nests have been collected during the regular mid-winter counts of waterfowl carried out by BSPB, as well as through targeted field studies for identification of the nests of the species along the Danube River in 2005, financed by “Persina” Nature Park Directorate, also conducted by BSPB. The nests of the White-tailed Eagle along the Black Sea Coast have been identified during the regular monitoring of coastal wetlands, carried by BSPB. The coordinates of all nests have been taken by GPS and entered in GIS. It is typical for this species that one pair has several nests, which the pair changes periodically. A dossier is maintained for each nest of the White-tailed Eagles along the Danube. The nests of the White-tailed Eagle along Tundzha River are localized during field studies along the river, carried out by Green Balkans federation. Both nests are marked with GPS and entered into GIS.

Data quality The GIS layer was created by setting 10 km buffers around the known nests, localized in GIS, of White-tailed Eagle. When a few nests were located in a close proximity a common polygon was created.

Data gaps The species is well studied. As it is a subject of regular monitoring new nests could be identified and the layer should be updated.


U. Short-toed Eagle breeding areas

Data sources

Information about the breeding areas of Short-toed Eagles was provided by Petar Shurulinkov from the Institute of Zoology at BAS. The data does not provide exact nesting locations but instead provides areas occupied by the Short-toes Eagle and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer is based on the information provided by Mr. Shurulinkov.

Data The exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known in most of the


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gaps cases, thus further studies need to be conducted to identify nests.


V. Marsh Harrier breeding areas

Data sources

Information about the breeding areas of Marsh Harrier was provided by Petar Shurulinkov from the Institute of Zoology at BAS. The data does not provide exact nesting locations but instead provides areas occupied by the Marsh Harrier and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer is based on the information provided by Mr. Shurulinkov.

Data gaps

The exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known in most of the cases, thus further studies need to be conducted to identify nests. The breeding locations are situated in wetlands or marshes overgrown with reed beds.


W. Mantagu’s Harrier breeding areas

Data sources

Information about the breeding areas of Mantagu’s Harrier was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs and verification of published data. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Mantagu’s Harrier and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer was created by setting 3 km buffers around the known breeding colonies of Mantagu’s Harrier (data from BSPB) and by including the polygons based on the data provided by Mr. Shurulinkov.

Data gaps

The exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known in most of the cases, thus further studies need to be conducted to identify nests.


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X. Levant Sparrowhawk breeding areas

Data sources

Information about the breeding areas of Levant Sparrowhawk was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs and verification of published data. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Levant Sparrowhawk and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer was created by setting 2 km buffers around the known nests, localized in GIS, of Levant Sparrowhawk (data from BSPB) and by including the polygons based on the data provided by Mr. Shurulinkov.

Data gaps

The exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known in most of the cases, thus further studies need to be conducted to identify nests.


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Y. Long-legged Buzzard breeding areas

Data sources

Information about the breeding areas of Long-legged Buzzard was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs; detailed monitoring of certain SPAs as Sakar, Lomovete, Bessaparski Hills; and verification of published data. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Long-legged Buzzard and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality The GIS layer was created by setting 1 km buffers around the known nests, localized in GIS, of Long-legged Buzzard (data from BSPB) and by including the polygons based on the data provided by Mr. Shurulinkov.

Data gaps Many of the exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known, thus further studies need to be conducted to identify nests.


Z. Lesser Spotted Eagle breeding areas

Data sources

Information about the breeding areas of Lesser Spotted Eagle was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs and verification of published data. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Lesser Spotted Eagle and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer was created by setting 5 km buffers around the known nests, localized in GIS, of Lesser Spotted Eagle (data from BSPB) and by including the polygons based on the data provided by Mr. Shurulinkov.

Data gaps Most of the exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known, thus further studies need to be conducted to identify nests.


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AA. Golden Eagle breeding areas

Data sources

Because the Golden Eagle always nests on rocky cliffs, relatively precise locations of its nests in Bulgaria could be found in different publications dating from decades ago. During the last twenty years part of the nests were permanently abandoned. During the field studies related to mapping of the bird fauna in Bulgaria, most of the nests of the Golden Eagle were mapped with GPS. In 2008-2009, BSPB carried out an inventory of the known Golden Eagle nests, where majority of them were entered into GIS. A dossier is maintained for each of the nests. A dossier includes information on the published references describeing the location, the year the nest was found, the occupation during the inventory, etc. Two nests in Southern Bulgaria have been localized by Green Balkans with s GPS. Further breeding areas have also been provided by P. Shurulinkov from the Institute of Zoology at BAS.

Data quality

The GIS layer was created by setting 6 km buffers around the known nests, localized in GIS, of Golden Eagle. When a few nests were located in a close proximity a common polygon was created. The polygons provided by Mr. Shurulinkov were also included in the layer. Some of the polygons created through buffering of known nests overlap with polygons provided by Mr. Shurulinkov.

Data gaps Few insufficiently studied breeding areas of Golden Eagle need to be further studied and nest - mapped.


BB. Booted Eagle breeding areas

Data sources

Information about the breeding areas of Booted Eagle was provided by Petar Shurulinkov from the Institute of Zoology at BAS. The data does not provide exact nesting locations but instead provides areas occupied by the Booted Eagle and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality The GIS layer is based on the information provided by Mr. Shurulinkov.

Data gaps

The exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not known, thus further studies need to be conducted to identify nests.


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CC. Peregrine Falcon breeding areas

Data sources

Information about the breeding areas of Peregrine Falcon was provided by BSPB and has been collected through field studies for mapping of the breeding bird fauna, identification of the SPA NATURA 2000 areas, monitoring of IBAs and verification of published data.

Data quality

The GIS layer was created by setting 5 km buffers around the known nests, localized in GIS, of Peregrine Falcon.

Data gaps

Many of the exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not mapped in GIS, thus further studies need to be conducted to map nests.


DD. Capercallie breeding areas

Data sources

The leaks of Capercallie were mapped using a standard methodology – on spot visits early in the morning, when birds are active. Additional data was collected during the day following specific trails left by the birds. The data were collected under by the Bulgarian Biodiversity Foundation under Term of Reference by State Forestry Agency “Elaboration of Action Plan for Conservation and Sustainable use of Capercallie and its habitats in Rhodopes Mountain”, as well as under the project “Sustainable management of Capercallie population and its habitats in the Municipality of Devin and Western Rhodopes Mountain towards multifunctional forest use and sustainable hunting”.

Data quality

The GIS layer represents the areas around the known leaks of Capercallie in the region of Western Rhodopes. These areas have been created by overlaying the mapped leaks according to the forest structure plans and modeling based on field mapping of the leaks, which was conducted by Bulgarian Biodiversity Foundation, BSPB and the State Forest Service in the region of Western Rhodopes.

Data gaps

The leaks of Capercalie out of Western Rhodopes mountain – Rila, Pirin and western Balckan are not mapped in details or at least the data were not available for the purpose of this project. These also should be mapped in details and added to the layer.


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EE. Eagle Owl breeding areas

Data sources

Information about the breeding areas of Eagle Owl was provided by BSPB and by Petar Shurulinkov from the Institute of Zoology at BAS. The BSPB data has been collected through field studies for: mapping of the breeding bird fauna; identification of the SPA NATURA 2000 areas; monitoring of IBAs and verification of published data. The data from Mr. Shurulinkov does not provide exact nesting locations but instead provides areas occupied by the Eagle Owl and other bird species vulnerable to wind farms. This data has been collected through numerous field studies for mapping of the breeding bird fauna and identification of the SPA NATURA 2000 areas, as well as other targeted studies. All observations are well recorded and the breeding certainty is assessed according to Yetman scale.

Data quality

The GIS layer was created by setting 6 km buffers around the known nests, localised in GIS, of Eagle Owl (data from BSPB) and by including the polygons based on the data provided by Mr. Shurulinkov. The boundaries of the polygons do not follow the boundaries of land plots and sometimes adjacent polygons either slightly overlap or slightly diverge.

Data gaps

Many of the exact breeding localities of the species within the standard 10 km-squares, where the species is confirmed to breed, are not mapped in GIS, thus further studies need to be conducted to map nests.


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FF. Summary of proposed buffer zones around breeding areas (16 Buffer Zones) for bird species vulnerable to wind turbines

Species Proposed buffer zones Justification of proposed buffer zones

Species threatened globally

Egyptian Vulture (Neophron percnopterus) 15 km around nests and roosts Carette et al. 2009; Atienza, J.C at all. 2008; etc.

Imperial Eagle (Aquila heliaca) 15 km around nests Atienza, J.C at all. 2008

Saker Falcon (Falco cherrug) 10 km around nests Cramp, S., K. E. L. Simmons. 1980.; precautionary principle; etc.

Red-footed Falcon (Falco vespertinus) 4 km around breeding colonies Expert discussions; precautionary principle

Lesser kestrel (Falco naumanni) Overlaps with IBAs identified for the species Expert discussions; precautionary principle

Corncrake (Crex crex) 2 km around the breeding areas

Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg. 2003.; etc.

Dalmatian Pelican (Pelecanus crispus) 2 km around wetland where it breeds Various impact studies and UK Guidance in wind farm design

Ferruginous Duck (Aythya nyroca) 2 km around wetland where it breeds Various impact studies and UK Guidance in wind farm design

Species threatened at EU level

Griffon Vulture (Gyps fulvus) 50 km around breeding colonies and roosts

20 km around core areas of reintroduction of the species

Atienza, J.C at all. 2008, etc.

White-tiled Eagle (Haliaeetus albicilla)

10 km around nests

Atienza, J.C at all. 2008; Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg. 2003; expert discussion and adaptation of the buffer according to the specifics of the local population

Golden Eagle (Aquila chrysaetos) 6 km around nests

Atienza, J.C at all. 2008; Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg. 2003; expert discussion and adaptation of the buffer according to the specifics of the local population


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FF. Summary of proposed buffer zones around breeding areas (16 Buffer Zones) for bird species vulnerable to wind turbines

Species Proposed buffer zones Justification of proposed buffer zones

Short-toed Eagle (Circaetus gallicus) 6 km around nests

Cramp, S., K. E. L. Simmons. 1980.; Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg. 2003; Atienza, J.C at all. 2008

Booted Eagle (Hieraaetus pennatus) 6 km around nests

Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg. 2003; Atienza, J.C at all. 2008

Eagle Owl (Bubo bubo) 6 km around nests

Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg. 2003; Atienza, J.C at all. 2008

Black Stork (Ciconia nigra) 2 km around nests Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg

Lesser Spotted Eagle (Aquila pomarina) 5 km around nests Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg

Black Kite (Milvus migrans) 5 km around nests Atienza, J.C at all. 2008

Honney Buzzard (Pernis apivorus) 5 km around nests Atienza, J.C at all. 2008

Montagu’s Harrier (Circus pygargus) 3 km around preferable areas of the breeding colonies

Atienza, J.C at all. 2008; Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg

Peregrine Falcon (Falco peregrinus) 5 km around nests Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg

Marsh Harrier (Circus aeruginosus) 2 km around wetland where it breeds Various impact studies and UK Guidance in wind farm design

Levant Sparrowhawk (Accipiter brevipes) 2 km around nests Atienza, J.C at all. 2008

Long-legged Buzzard (Buteo rufinus) 1 km around nests Atienza, J.C at all. 2008

Capercallie (Tetrao urogallus) 2 km around leaks

Ministerium für Umwelt, Gesundheit und Verbraucherschutz des Landes Barandenburg.

Ruddy Shelduck (Tadorna ferruginea) 1 km around the breeding site Expert discussions

Breeding colonies of herons, egrets, cormorants and other colonial water birds

2 km around the breeding colony Expert discussions


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GG. Areas of reintroduction of globally threatened or highly vulnerable to wind turbines EU level threatened species Areas of reintroduction of Griffon Vulture

Data sources

Data about the locations of sites where young griffon vultures have just been released or are about to be released has been provided by Green Balkans Federation, Fund for Wild Flora and Fauna and Birds of Prey Protection Society for five sites of reintroduction – one in the Vrachanska Mountain, one at the Kresna Gorge, one at the Central Balkan Mountain and two around the town of Sliven.

Data quality

The data has been provided as coordinates of the reintroduction sites, around which buffer zones of 20 km were set.

Data gaps

There are no known data gaps. If new sites of reintroduction are planned in the future, this data set has to be updated.

Areas specifically designated for bird protection.


HH. Areas specifically designated for bird protection - Important Bird Areas

Data sources

The GIS file for the IBAs was provided by the BSPB.

Data quality

The data set has been created through a rigorous process and officially approved. The polygons follow the boundaries of individual land plots.

Data gaps

The data set for IBAs is provided by the Bulgarian Society for the Protection of Birds and there are no known data gaps in it.


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II. Areas specifically designated for bird protection - SPAs NATURA 2000 areas

Data sources

Two data sets have been provided by the Ministry of Environment and Water – a data set with the 114 proposed SPA NATURA 2000 areas in 2007 and a data set with the 90 officially approved SPA NATURA 2000 areas in 2009. Also, data about the Bulgarian relief was used from the website of the ASTER – Global Digital Elevation Map, available at: http://asterweb.jpl.nasa.gov/gdem.asp (see below for more details).

Data quality Both data sets have been created through a very rigorous process and officially approved. The polygons follow the boundaries of individual land plots. The maps have been generated with the use of the 90 approved SPA areas (data set from 2009) and the 24 remaining to be approved SPAs (data set from 2007).

It should be noted that since the data sets were provided by MOEW in March 2010 but they are current as of September 2009. Because of that it is possible that boundaries of the five SPAs, which designation orders were published by June 14th, 2010 – Melnishki piramidi, Durankulasjko ezero, Shablenski Ezeren Kompleks, Dervenski vazvishenia and Rupite – may not be absolutely identical to the boundaries published in the State Gasette.

The designation orders of 14 SPAs, which contain prohibition for wind power development, are undergoing approval and are expected to soon be published in the State Gazette. The proposed designation order of the Zapaden Balkan SPA contains a prohibition for wind power development above 800m. In order to split the territory of the Zapaden Balkan SPA, data from ASTER – Global Digital Elevation Map was used. The data quality of this relief data is 1 arc sec.

Data gaps No gaps. The layers should be updated with the update of IBA list and SPA list respectively.


JJ. Protected territories, designated for bird protection

Data sources

Three data sets have been provided by the Ministry of Environmental and Water for protected territories – a data set with all strict nature reserves and managed reserves, a data set with all national parks and nature parks and a data set with all protected sites and natural monuments.

Data quality From the data sets provided by the Ministry of Environment and Water, identified were these protected territories, which have been designated for bird protection. A buffer of 1.5 km has been set around these territories.

Data gaps From the 101 identified territories, designated for bird protection, 20 were missing from the data sets, provided by MoEW. The MoEW should create a complete GIS data set which contains all designated protected territories.


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KK. Bird species and birds related areas - Summary table

Identified areas of constraint

Species – English name

Species – Latin name

Level of endangerment

(IUCN)

Vulnerability of species to

wind turbines

Proposed size of buffer zone

Spatial data availability /

representation Data sources

Level of constraint


Migration bottleneck areas

Raptors, Black Stork, White

stork, White Pelican, Dalmatian Pelican, Common

Crane

Coconia nigra, Coconia coconia,

Pelecanus onocrotalus, Pelecanus

crispus, Grus grus

Globally threatened /

EU level protection -

Annex 1

High Corridor defined based on criteria

Available - separate GIS

layer

BSPB; Institute of Zoology at

BAS; publications

Red / Orange / Yellow

Passerines Passeriformes

Globally threatened /

EU level protection -

Annex 1

Not defined Not defined Not available N/A Orange Yellow

Roosting sites

White stork, White Pelican, Dalmatian

Pelican and Raptors

Coconia coconia, Pelecanus

onocrotalus, Pelecanus crispus

Globally threatened / EU level protection,

Annex 1

High At least 2 km from the known roosting

sites

Available – separate GIS

layer

BSPB; publications

Red

Staging areas / Feeding areas / Wintering areas

Imperial Eagle Aquila heliaca Globally

threatened - Vulnerable

Very high

Polygons based on satellite and radio

telemetry observations


layer

BSPB; Green Balkans

Red / Orange

Black Vulture Aegypius monachus

Globally threatened -

Near threatened

High Polygons based on

radio telemetry observations


layer Green Balkans Red

Saker Falcon Falco cherrug Globally High Areas where Available – BSPB Red /


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threatened - Endangered

(not studied in particular;

precautionary principle

should apply)

species has been observed via

satellite telemetry

separate GIS layer

Orange

Red-breasted Goose

Branta ruficollis

Globally thretened -

Endangered

Very high (not studied in

particular; precautionary

principle should apply)

10 km around wetlands (or 10 km

inland from the coastline) where

the species roosts; known regular

feeding areas for geese

Available – separate GIS layer, as well

as part of “wetlands” GIS

layer

BSPB; publications

Red / Orange

Dalmatian Pelican Pelecanus crispus Globally


High (not studied in



At least 2 km around wetlands

where the species roosts/congregates

Available – separate GIS layer, as well

as part of “wetlands” GIS

layer


BAS; publications

Red

Slender-billed Curlew

Numenius tenuirostris

Globally thretened - Critically

endangered

High (not studied in



All known localities occurrence of the

species – all in IBAs

Available – as part of

“wetlands” GIS layer

BSPB; publications

Red

Lesser White-fronted Goose

Anser erythropus

Globally threatened - Vulnerable

Very high (not studied in



At least 10 km around wetlands (or 10 km inland

from the coastline) where the species

roosts; known regular feeding



BSPB; publications

Red


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areas for geese

White-headed Duck

Oxyura leucocephala

Globally threatened - Endangered

High





BSPB; publications

Red

Marbled Teal Marmaronetta angustirostris


High





BSPB; publications

Red

Ferruginous Duck Aythya nyroca


Near threatened

High





BSPB; publications

Red

Black-winged Pratincole

Glareola nordmanni


Near threatened

High



Not available N/A Red

Sociable Lapwing

Vanellus gregarious


Critically endangered

High


where the species roosts



BSPB; publications

Red

Great Snipe Gallinago media


Near threatened

High





BSPB; publications

Red

Black-tailed Godwint

Limosa limosa


Near threatened

High





BSPB; publications

Red

Eurasian Curlew Numenius arquata Globally threatened -

High At least 2 km around wetlands



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Near threatened


Aquatic warbler Acrocephalus

paludicola


Unknown

2 km around wetlands where the

species roosts/congregates


Known wintering areas of geese

Red-breasted Goose, Lesser White-fronted

Goose

Branta ruficollis, Anser erythropus

Global and EU level of protection

High 10 km around

wetlands


later

BSBP; publications

Red


Wetlands with high waterfowl concentration

Red-breasted Goose, Dalmatian Pelican, Slender-

billed Curlew, Lesser White-fronted Goose, White-headed Duck, Marbled

Teal, Ferruginous Duck, Sociable Lapwing, Great

Snipe, Black-tailed Godwint

Branta ruficollis, Pelecanus

crispus, Numenius tenuirostris,

Anser erythropus, Oxyura

leucocephala, Marmaronetta angustirostris, Aythya nyroca,

Vanellus gregarious,

Gallinago media, Limosa limosa


Medium to High

2 km around wetlands


later

BSBP; publications

Red / Orange / Yellow

Waterfowl colonies

Herons, Egrets, Ibis, Soonbill,

Terns and Cormorants

A. Ralloides, Ardeidae, P.

Falcinellus, P. Leucorodia,

Sternidae, Ph. Carbo


High 2 km around

wetlands where the colony is situated

Available – two separate GIS layers


BAS; publications

Red


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Breeding areas - know nests

Globally threatened

species

Imperial Eagle Aquila heliaca Globally


Very high but not certain

15 km Available –

separate GIS layer

BSPB; publications

Red

Egyptial Vulture Neophron

percnopterus

Globally threatened - Endangered

Very high 15 km Available –

separate GIS layer

BSPB; publications

Red

Saker Falcon Falco cherrug Globally

threatened - Endangered

High (precautionary

principle)

Predefined zone around known

localities; in principal 10 km


layer BSPB Red

Red footed Falcon Branta ruficollis


Near threatened

High (precautionary

principle) 4 km


layer BSPB Red

Black Vulture Aegypius monachus


Near threatened

High 50 km Not available N/A Red

Lesser Kestrel

Falco naumanni Globally


High (precautionary

principle) IBAs Not available N/A Red

Dalmatian Pelican

Pelecanus crispus Globally


High (precautionary

principle)


where the species breeds


Ferruginous Duck Aythya nyroca


Near threatened

High


where the species breeds



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Corncrake

Crex crex


Near threatened

High 2 km around areas with calling males


European Roller Coracias garrulous


Near threatened

Unknown Not defined Not available N/A Red

Semi-collared Flycatche

Ficedula semitorquata

Globally thretened -

Near threatened

Unknown Not defined Not available N/A Red

EU level threatened

species

Griffon Vulture Gyps fulvus EU level

protection, Annex 1

Very high

50 km around colonies or

feeding/roosting grounds


layer

BSPB; publications

Red

Black Stork Ciconia nigra EU level

protection, Annex 1

High 2 km Available –

separate GIS layer


BAS; publications

Orange

Honney Buzzard Pernis apivorus EU level

protection, Annex 1


separate GIS layer


BAS; publications

Orange

Black Kite Milvus migrans EU level

protection, Annex 1


separate GIS layer


BAS; publications

Orange

White-tailed Eagle Haliaeetus

albicilla EU level

protection;

Very high; only 12

couples left in 10 km


layer

BSPB; Green Balkans;

Red


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Bulgaria publications

Short-toed Eagle Circaetus gallicus EU level

protection, Annex 1


separate GIS layer

Institute of Zoology at BAS

Orange

Marsh Harrier Circus

aeruginosus

EU level protection, Annex 1


separate GIS layer


Orange

Montagu’s Harrier Circus pygargus EU level

protection, Annex 1

High 3 km around the breeding area


layer

BSPB + Institute of Zoology at

BAS (P. Shurulinkov) +

publications

Orange

Levant Sparrowhawk

Accipiter brevipes EU level

protection, Annex 1


separate GIS layer


BAS; publications

Orange

Long-legged Buzzard

Buteo rufinus EU level

protection, Annex 1


separate GIS layer


BAS; publications

Orange

Lesser Spotted Eagle

Aquila pomarina EU level

protection, Annex 1


separate GIS layer


BAS; publications

Orange

Golden Eagle Aquila chrysaetos

EU level

protection, Annex 1

Very high 6 km Available –

separate GIS layer


BAS; publications

Red

Booted Eagle Hieraaetus pennatus

EU level protection,

High 6 km Available – separate GIS


Orange


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Annex 1 layer

Peregrine Falcon Falco peregrinus EU level

protection, Annex 1

Medium 5 km Available –

separate GIS layer

BSPB; publications

Orange

Capercallie Tetrao urogallus EU level

protection, Annex 1

High 2 km around lakes Available –

separate GIS layer

BSPB; publications

Orange

Eagle Owl Bubo bubo EU level

protection, Annex 1


separate GIS layer


BAS; publications

Orange

Osprey

Pandion haliaetus

EU level protection; less than 10 couples

in Bulgaria

High 6 km Not available N/A Red

Breeding areas – suitable habitats, where species have been observed

Globally threatened

species

Corncrake Crex crex


Near threatened

High Locations based on

National Action plan for Crex crex


layer

BSPB; publications

Orange

Red-footed Falcon Falco vesperinus


Near threatened

High (precautionary

principle) N/A


layer BSPB; Breeding

Bird Atlas Orange

EU level threatened

species

Honney Buzzard Pernis apivorus EU level

protection, Annex 1

High N/A Available –

separate GIS layer

BSPB; Breeding Bird Atlas

Yellow

Black Kite Milvus migrans EU level

protection, Annex 1


separate GIS layer


Yellow


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White-tailed Eagle Haliaeetus

albicilla EU level

protection

Very high, only 12

couples in Bulgaria

N/A Available –

separate GIS layer


Orange

Short-toed Eagle Circaetus gallicus EU level

protection, Annex 1


separate GIS layer


Yellow

Marsh Harrier Circus

aeruginosus



separate GIS layer


Yellow

Montagu’s Harrier Circus pygargus EU level

protection, Annex 1


separate GIS layer


Yellow

Levant Sparrowhawk

Accipiter brevipes EU level

protection, Annex 1


separate GIS layer


Yellow

Long-legged Buzzard

Buteo rufinus EU level

protection, Annex 1


separate GIS layer


Yellow

Lesser Spotted Eagle

Aquila pomarina EU level

protection, Annex 1


separate GIS layer


Yellow

Golden Eagle Aquila Chrysaetos EU level

protection, Annex 1

Very High N/A Available –

separate GIS layer


Orange

Booted Eagle Hieraaetus pennatus



separate GIS layer


Yellow


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Osprey Pandion haliaetus EU level

protection, Annex 1

High, less than 10 couples in Bulgaria

N/A Available –

separate GIS layer


Orange

Peregrine Falcon Falco peregrinus EU level

protection, Annex 1


separate GIS layer


Yellow

Areas of reintroduction of globally or EU level threatened species

Released on 1 year

Griffon Vulture Gyps fulvus EU level

protection, Annex 1

Very high 20 km around the point of release


layer

Green Balkans Federation;

Birds of Prey Protection

Society, Fund for Wild Flora

and Fauna

Orange

Released within 5 years

N/A N/A Global or EU level protection Very high

20 km around the point of release

N/A N/A Yellow


IBA Various species N/A Global or EU

level protection High Not defined Available –

separate GIS layer

BSPB Red

SPA Various species N/A Global or EU level protection High Not defined


layer MoEW

Black / Red with

Black stripes/

Red

Proetcted territory

Various species N/A Global or EU level protection

Medium to high 1.5 km


layer MoEW Orange


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Appendix D4: Soils and Water – Detailed information

A. Contaminated areas

Legal basis for inclusion of this

area of constraint

As part of the Bulgarian environmental legislation, there is a Regulation on the inventarization and investigations of areas with contaminated soils, required reclamation measures, as well as the maintenance of the implemented reclamation activities. According to art. 2 (2) of this regulation, a register has to be maintained with the information from the inventarization, investigations and the conduct of impact measures and this register has to be maintained by the Environmental Executive Agency (EEA) (art. 5).

Such register of the contaminated zones in Bulgaria has not been developed yet. Currently, the EEA is preparing a methodology for this inventory.

Justification for designating the

respective level of constraint

Assigned as areas with low sensitivity to wind power development. In order to minimize the impacts on wildlife, wind power development should be encouraged in areas with significant anthropogenic alternation, including areas contaminated by industrial activities. Assigning contaminated areas with medium level of sensitivity is done not to deter wind power investors from these territories but more to inform them on the preexisting soil conditions, which should be taken into account during the conduct of the construction activities.

Data sources Data on areas contaminated by industrial activities was requested from the Cartography and Cadastre Agency. However, the agency replied unofficially that such data is not present within the cadastral database.

Data quality Not applicable.

Data gaps Not applicable.


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B. Agricultural land – Category I, II, II and IV


In March 2010, the Ministry of Agriculture and Food submitted a proposal to the Bulgarian Council of Ministers for changes of the Agricultural Lands Protection Act. In art. 23 (2) of the proposed amended act, a prohibition is included for the construction or enlargement of facilities for the production of electrical energy from RES on agricultural lands from first to forth category and on irrigated lands.


level of constraint

Assigned as areas with low sensitivity to wind power development. According to the newest amendments to the Agricultural Lands Protection Act, agricultural lands category 1st to 4th are expected to become prohibited for wind power development soon. The amendments to the act were approved in April 2010 by the Council of Ministers and now have to be voted in the Parliament. As shown in Section 6.1.4, the potential impact of wind power on soils with high economic value is assessed as being partial negative and because of that a low level of sensitivity has been assigned to agricultural lands category 1st to 4th. However, given the potential that the referred areas may become unavailable for wind power development if the amendments to the act are approved by the Bulgarian parliament, these areas have been assigned a special intermediate level, only applicable for this particular case - low sensitivity level (yellow) with black overlaying stripes.

Data sources Spatial information on the categorization of the agricultural lands has been requested from the Ministry of Agriculture and Food (MAF). The information has already been prepared by MAF but MAF was waiting to sign an agreement with the Ministry of Economy, Energy and Tourism for this data transfer. However, since information was not provided until the end of this Final Report, these areas were not included in the final spatial constraints analysis.

Data quality It was expected that the information from MAF would be provided in .zem format. In order to use this data set together with the other data sets in the GIS database, major data processing will have to be undertaken. It is anticipated, for future project related developments that the conversion of the .zem files into .shape files and the extraction of agricultural lands from 1st to 4th category will take at least four weeks.



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C. Sanitary water protection zones


The land use of sanitary water protection zones is regulated under Ordinance 3/16.10.2000 for the conditions and order of investigation, designing, approval and operation of the sanitary-protective zones around the water sources and the potable water supply facilities and around the mineral water sources, used for healing, preventive, potable and hygiene needs. According to art. 8 (2) in sanitary water protection zone I are allowed only activities related to the water source and/or operation of the water facilities. According to Annex 1 of the ordinance, in sanitary protection zones II around surface water sources, the construction of aboveground and underground facilities is restricted, with the exception of reconstruction and modernization of the main water supply facilities, while there are no such restrictions for zone III. According to Annex 2, in sanitary protection zones II around underground water sources, all activities which damage the integrity of the watertight layer above the underground water body are prohibited, which in zones III of the same water bodies these activities are restricted.


level of constraint

These areas are assigned with the following levels of sensitivity:

• Sanitary protection zones I around both underground and surface water sources - areas with explicit legislative prohibition for wind power development;

• Sanitary protection zones II around surface water sources – areas with high sensitivity to wind power development;

• Sanitary protection zones II around underground water sources – areas with high sensitivity to wind power development;

• Sanitary protection zones III around surface water source – areas with low sensitivity to wind power development;

• Sanitary protection zones III around underground water sources – areas with medium sensitivity to wind power development.

Data sources Data was provided by the four Basin Directorates – Pleven, Blagoevgrad, Varna and Plovdiv. Data only for sanitary protection zones I was requested but Basin Directorate Blagoevgrad provided also data on sanitary protection zones II and III for both underground and surface water sources.

Data quality

The data sets provided by the Pleven, Blagoevgrad and Plovdiv Basin Directorates were in .shape format and could be used directly in the GIS database. The data provided by Basin Directorate Varna was highly fragmented (provided as individual plans for sanitary protection zones) and major data processing is required before it could be used. Considering the time and budget constraints of this project, the data provided by Basin Directorate Varna was not used.

Data gaps The completeness of the provided data sets is hard to assess just by reviewing the .shape files. However, it has been indicated by


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the Basin Directorates that not all drinking water sources in Bulgaria, sanitary water protection zones have been determined for. The boundaries of many sanitary protection zones are still in the process of being determined. Therefore, as new data becomes available, it should be included in these data sets. The update of the GIS constraint database should also include data about sanitary protection zones II and III from all Basin Directorates.

Appendix D5: Public Heath, Noise and Vibration – Detailed information A. Buffer zone around settlements boundaries


According to art. 141 from the Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy, wind power turbines should be at least 500 meters away from the territory of the closest settlement.


level of constraint

Assigned as areas with explicit legislative prohibition for wind power development. Wind power development is forbidden in the buffer zone of 500 m from the boundaries of all settlements in Bulgaria. Class 1 from the CORINE Landcover database contains all major elements of the artificial surfaces: continuous urban fabric, discontinuous urban fabric, industrial or commercial units, road and railroad networks and associated land, port areas, airports, mineral extraction sites, dump sites, construction sites, green urban areas, sport and leisure facilities. From these categories only continous urban fabric and discountinuous urban fabric were selected, as they are believed to represent the actual settlement areas. A buffer zone of 500m was created around each polygon of a settlement.

Data sources Data set with the boundaries of the settlements in Bulgaria was derived from the the CORINE Landcover Class 1 data set that has been downloaded from the website of the Ministry of Regional Development and Public Works.

Data quality The smallest objects which appear on the map from the CORINE Landcover project is 25 ha. Therefore, only settlements which are larger than 25 ha are included in this data set.

Further, the boundaries of the settlements, as defined in CORINE Landcover are a good approximation of the actual (legal) boundaries. More accurate information should be sought (again) from the Cadastre Agency and the Ministry of Agriculture and Food.

Data gaps Settlements smaller than 25 ha are not included in this map.


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Appendix D6: Socio- Economic and Material Assets – Detailed information

A. Buffer zone around settlements boundaries


According to art. 141 from the Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy, wind power turbines should be at least 500 meters away from the territory of the closest settlement. Different legislative acts considering the operation of ports, airports, railroads, etc. pose various restrictions for the construction of industrial installations, including wind power turbines, in close proximity to these built structures.


level of constraint

Assigned as areas with explicit prohibition for wind power development. Class 1 from the CORINE Landcover database contains all major elements of the artificial surfaces: continuous urban fabric, discontinuous urban fabric, industrial or commercial units, road and railroad networks and associated land, port areas, airports, mineral extraction sites, dump sites, construction sites, green urban areas, sport and leisure facilities. All these site types have different restrictions for construction of industrial installations, including wind power turbines, in their close proximity – around some of them wind power development may be prohibited while around others it may be restricted in one way or another.

Therefore, the continous urban fabric and discountinuous urban fabric categories from Class 1 CORINE Landcover, which represents the actual settlements, are defined as having explicit prohibition for wind power development, while the other categories are defined as having no or unknown sensitivity..

Data sources The CORINE Landcover Class 1 data set has been downloaded from the website of the Ministry of Regional Development and Public Works.

Data quality The smallest objects which appear on the map from the CORINE Landcover project is 25 ha. Therefore, only settlements which are larger than 25 ha are included in this data set.

Further, the boundaries of the settlements, as defined in CORINE Landcover are a good approximation of the actual (legal) boundaries. More accurate information should be sought (again) from the Cadastre Agency and the Ministry of Agriculture and Food.

Data gaps Settlements smaller than 25 ha are not included in this map. It should be noted that this map does not include the electrical transmission lines, underground and aboveground pipelines, and other “thin” linear objects, which however require buffer zones. The maps also don’t include buffer zones around the included facilities, such as airports, railroads, etc.


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APPENDIX E: Identification of indicative GIS polygons with importance for conservation of bats (Mammalia: Chiroptera) in Bulgaria


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IDENTIFICATION OF INDICATIVE GIS POLYGONS WITH IMPORTANCE FOR

CONSERVATION OF BATS (MAMMALIA: CHIROPTERA) IN BULGARIA

Boyan Petrov

Bat Research and Conservation Center at the National Museum of Natural History

http://nmnhs.com/display_en.php?id=bat-research-and-conservation-centre

Bulgaria has a uniquely high diversity of bats. Of the 35 species present within continental Europe, 33 species are known to inhabit Bulgaria. Among the reasons for this high diversity are the country’s transitional geographic location, its mosaic of habitats which start at sea level and reach an altitude of over 2 900 m, the continued existence of wild nature in many parts of the country, extensive farming activities in the mountains and semi-mountainous regions, the presence of over 5,900 caves and the high diversity and abundance of insects. The greatest bat diversity can be found in the belt between 100 and 400 m altitude, where relatively small areas are inhabited by 17-20 species. All bat species in Bulgaria are strictly protected under the Bulgarian legislation (Biodiversity Act) and the EUROBATS Agreement. Bats are a priority animal group in terms of study and conservation.

Harnessing the renewable energy of the country’s wind resources is a relatively new activity in Bulgaria. The development of wind power is quickly gaining popularity although the experience in planning, construction and operation of wind power plants in Bulgaria is very limited.

While guidelines for the development of wind power have been prepared in some European countries, there are no examples of the identification of the most important sites for bats at a national scale with the view of minimizing the impact of wind power development on bat populations.

PRIMARY PURPOSES OF THIS REPORT:

To provide basic knowledge in the form of a Geographic Information System (GIS) map and a descriptive table to different units of the Ministry of Environment and Water in their preliminary assessment for the importance of the areas proposed for wind farm projects with regard to bats.

To raise awareness amongst developers and planners by pointing where the most critical conflict zones for the conservation of bats are located throughout Bulgaria.

The need to consider possible impacts on bats as part of the development control process and to adapt policy and practices in terms of properly locating wind turbines is vital to ensure that bats are not faced with an unnecessary threat to their survival.


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Wind power plants may cause negative impacts on bat populations, as well as on their prey and habitats, such as:

Direct risks Indirect risks

Direct strike with the rotor blades

Damage, disturbance or destruction of

roosts

Disorientation of bats in flight through

emission of ultrasound noise

Changes in the characteristics of

the habitat - Damage, disturbance or

destruction of foraging habitats and

commuting corridors

Clash with the power-transmission network Fragmentation of habitat

Turbulence spin while in flight Barrier effect

Noise “pollution” Cumulative death effect

Altogether 20 European bat species were found to suffer collision fatalities, and 21 bat species are considered to be potentially affected (RODRIGUES et al. 2008 in Table 1). Table 1: Bats’ behaviour in relation to wind farms based on the knowledge and experience

Bulgarian/Latin name English name High flight

(> 40 m)

Low flight

Known collision

Risk of

collision 1. олям подковонос Rhinolophus ferrumequinum

Greater horseshoe bat X

2. алък подковонос Rhinolophus hipposideros

Lesser horseshoe bat X

3. жен подковонос Rhinolophus euryale

Mediterranean horseshoe bat

X

4. одковонос на Мехели Rhinolophus mehelyi

Mehely's horseshoe bat ?

5. редиземноморски подковонос Rhinolophus blasii

Blasius's horseshoe bat

6. олям нощник Myotis myotis

Greater mouse-eared bat X X X X

7. строух нощник Myotis blythii

Lesser mouse-eared bat X X X


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(> 40 m)

Low flight

Known collision

Risk of

collision 8. ехщайнов нощник Myotis bechsteinii

Bechstein's bat

9. рицветен нощник Myotis emarginatus

Geoffroy's bat X X

10. ългопръст нощник Myotis capaccinii

Long-fingered bat X

11. ирокоух прилеп Barbastella barbastellus

Western barbastelle X

12. ещерен дългокрил Miniopterus schreibersii

Schreiber's long-fingered bat

X X X X

13. атереров нощник Myotis nattereri

Natterer's bat X

14. устакат нощник Myotis mystacinus

Whiskered bat X

15. латист нощник Myotis aurascens

Steppe whiskered bat X

16. ощник на Брандт Myotis brandtii

Brandt's bat X X X X

17. лкатоев нощник Myotis alcathoe

Alcathoe whiskered bat X

18. оден нощник Myotis daubentonii

Daubenton's bat X X X X

19. зерен нощник Myotis dasycneme

Pond bat X X X X

20. афяв дългоух прилеп Plecotus auritus

Brown long-eared bat X X X X

21. ив дългоух прилеп Plecotus austriacus

Grey long-eared bat X X X X

22. ъждив вечерник Nyctalus noctula

Noctule X X X

23. олям вечерник Nyctalus lasiopterus

Giant noctule X X X


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(> 40 m)

Low flight

Known collision

Risk of

collision 24. алък вечерник Nyctalus leisleri

Lesser noctule X X X

25. афяво прилепче Pipistrellus pipistrellus

Common pipistrelle X X X X

26. алко кафяво прилепче Pipistrellus pygmaeus

Pygmy/soprano pipistrelle

X X X X

27. атузиево прилепче Pipistrellus nathusii

Nathusius' pipistrelle X X X X

28. редиземноморско прилепче Pipistrellus kuhlii

Kuhl's pipistrelle X X X X

29. авиево прилепче Hypsugo savii

Savi's pipistrelle bat X X

30. олунощен прилеп Eptesicus serotinus

Serotine X X X

31. еверен прилеп Eptesicus nilssonii

Northern bat X X X

32. вуцветен прилеп Vespertilio murinus

Particoloured bat X X X

33. улдогов прилеп Tadarida teniotis

European free-tailed bat X X X

Methodology The identification of areas with importance to bats in Bulgaria was based upon both published literature data and the unpublished database of the Bat Research and Conservation Center at the National Museum of Natural History in Sofia. Fifteen major literature sources in combination with critical expert judgment were used to outline the size and form of the polygons. Population abundance data was taken into account only from assessments carried after 1998.

Local species diversity (1), population abundance (2), migration/dispersal potential (3), number of underground roosts (4) and quality of the surrounding forests (5) were selected as key parameters, which describe the importance and size of each of the selected areas (Table 2).


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Greatest area coverage was given to polygons around regionally, nationally and internationally important bat roosts as defined by IVANOVA (2005a,b). The presence of habitats likely to be utilised by bats such as nearby forests, wetland and hedgerow networks, and habitat features such as known individual trees, water bodies or water courses were taken into account. Special consideration was given to known narrow bat migration routes and concentrated feeding, breeding and roosting areas. Very open habitats (e.g. in Dobrudzha) were considered with precaution because they are normally less important for roosting of large bat colonies, but may form commuting or migratory corridors. Known roosts without recent confirmation of presence of large bat colonies were no included and assessed.

Table 2: Criteria for the relative importance of BAT GIS polygons in Bulgaria.

PARAMETER DESCRIPTION POINTS REFERENCES

1. Species diversity

1. Low- 2-5 species 2. Medium- 6-10 species 3. High- 11 and more species

Overall number of species known for a given area

Each species is 1 point

Published and new data on bats from DB of BRCC/NMNH

2. Population abundance

1. Low- < 500 ind. 2. Medium- 500-1000 ind. 3. High – 1001-5000 ind. 4. Very High - >5001 ind.

Indicative number of all bat individuals for a given area regardless of the species

1 – 1 point 2 – 3 points 3 – 5 points 4 – 10 points

Published and new data on bats from DB of BRCC/NMNH, expert judgement


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PARAMETER DESCRIPTION POINTS REFERENCES

3. Migration & Dispersal corridor

1. Local 2. National 3. International

Presence of linear landscape elements with or without roosts with importance for local dispersal and foraging movements. Proved or potential connections between bat roosts in the country and beyond the national borders

1 – 1 point 2 – 3 points 3 – 5 points

Published and new migratory/dispersal data on bats from DB of BRCC/NMNH, expert judgement

4. Forests

1. Good 2. Excellent

Presence of deciduous or mixed forests with hollow trees and loose bark

1 – 1 point 2 – 3 points

Expert judgement based on in-situ field observations

5. Caves & galleries

1. Low- <10 caves 2. Medium- 11-20 caves 3. High- over 21 caves

Number of underground roosts (caves, galleries, bunkers, etc.) within the scope of the polygon

1 – 1 point 2 – 3 points 3 – 5 points

Index of caves in Bulgaria - Bulgarian Federation of Speleology

The relative importance of each polygon was determined by summing the points assigned to each criteria parameter. Three relative categories were defined - MEDIUM importance, HIGH importance, VERY HIGH importance (Table 3). Table 3: Scale of the relative importance of BAT GIS polygons.

SCALE OF IMPORTANCE

POINTS POLYGON

COLOR DESCRIPTION

Low 0 - 9 Yellow Construction possible after careful analysis, proper avoidance, mitigation and compensatory measures.

Medium 10 - 19 Orange Construction not recommended. Great risk of collisions, especially during migration

High ≥ 20 Red No-go area, complete ban. Great species diversity and abundance.

RESULTS


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Ninety nine polygons were identified and described (see Bat_polygons_description_2010.xls; Table 4). Data summary is presented in Table 4. Total species diversity was accessed for each polygon. A list of bat species, which are abundant and common in these areas is presented as a potential source for the expected collision estimates.

Only in 5 polygons (5 %) construction of wind power plants is considered to cause low impact on bats (polygon files- 019_Panega, 039_Vetovo, 046_Ruino, 048_Onogur and 088_Chirpan_Bunar). In 59 polygons (60%) construction of wind turbines is not recommended (medium impact). Investment proposals can be granted in these areas only after careful pre-construction Environmental Impact Assessment. Risk of bat collisions remains high in these polygons especially during migration and dispersal periods. High impact on bats was assessed in 35 areas (35%). The risk of wind turbines construction is evaluated as UNACCEPTABLE since it affects bats and their habitats at a population level.

Table 4: Importance of BAT GIS polygons (N=99).

IMPORTANCE POINTS SCORE NUMBER OF POLYGONS

Low 0-9 5

Medium 10-12 20 13-15 20 16-19 19

High 20-22 11 23-29 15 ≥30 9

TOTAL 99

MITIGATION AND COMPENSATION MEASURES

Reduce impacts with appropriate turbine layout

The pre-permitting studies must be sufficiently detailed in order to determine the normal movement patterns of the resident and migratory species, which will inform the micrositing decisions in the turbine configuration process. Turbine alignments that separate roosts and feeding sites pose a permanent collision threat. As part of the wind project development process a map should be developed and among other things it must show the places with the highest concentration of foraging and migrating bats so that these places are not used for wind power development. Traditional bird and bat migration corridors in Bulgaria follow the Black Sea coast, Strouma River valley, Danube, valley of Maritsa River, Iskar River Gorge, etc. At local scale, each well defined mountain pass (or saddle) definitely constitutes a


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bottleneck migration place. Careful siting of new wind turbines contributes substantially to reduce the fatality risk.

Reduce habitat for prey near turbines

Areas around turbines and along roads that have been disturbed by construction and operations activities may provide habitat for prey species such as insects, small mammals and weedy vegetation. Increases in prey availability may in turn attract bats, insectivorous birds and raptors, thus putting them at increased risk of collision. Biologists should be aware of these potential impacts when reviewing the site design and recommend construction and management practices to minimize the activities that might attract prey and predators to the wind turbine site.

Avoid lighting that attracts insects, birds and bats

It is still poorly understood how birds and bats respond to lighting but it is known that steady burning lights attract insects and thus increase the potential for large-scale fatality events. Flashing lights with the minimum “on” period should be used on turbines without breaking the safety and security needs. White lights with sensors and switches that keep the lights off when they are not required should also be used. These lights should be directed in a way which minimizes the illumination of areas outside of the facility.

Minimize power line impacts

To prevent avian collisions and electrocutions, place all connecting power lines associated with wind power development underground, unless burial of the lines would result in greater impacts to biological resources.

Decommission non-operational turbines

Remove wind turbines when they are no longer operational so they cannot present a collision hazard to bird and bats. As part of permitting applications, developers should submit a decommissioning and reclamation plan. The plan should discuss in reasonable detail how the wind turbines and associated structures will be dismantled and removed. Decommissioning a project typically involves removal of turbine foundations (to one meter below ground level) and removal of access roads, unnecessary fencing, and ancillary structures. The decommissioning plan should also include documentation showing financial capability to carry out the decommissioning and restoration requirements. Plans for decommissioning can also be addressed as an obligation of the property owner as part of the lease arrangement with the wind developer.

Compensation


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Regardless of the form of the compensatory mitigation, Regional Inspectorates of Environment and Water should establish a balance between the level of impact and the amount of mitigation. Unlike habitat impacts, in which 1ha habitat loss can be compensated with an appropriate number of hectares of habitat protected or restored, bird and bat collisions with wind turbines do not suggest an obvious compensation ratio.

The following potential compensation options are known to protect and enhance bird and bat populations as part of the compensatory program:

Offsite conservation and protection of essential habitat

Nesting and breeding areas

Foraging habitats

Roosting or wintering areas

Migratory rest areas

Habitat corridors and linkages

Offsite conservation and habitat restoration

Restored habitat function

Increased carrying capacity

Offsite habitat enhancement

Predator control program(s)

Exotic/invasive species removal


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GUIDELINES FOR FURTHER RESEARCH ON BATS AND WIND FARM PROJECTS IN BULGARIA

Knowledge and expert capacity for accessing the impact of wind turbines particularly on bats in Bulgaria are very limited at present. There are only few field surveys carried on bats prior to construction of wind turbines and none during the operation of the newly built wind farms. No studies are carried by means of radar or thermal imaging methods.

The following priorities should be set out:

Develop and test models for habitat use and dispersal and foraging ranges of bats in large

colonies.

Post-construction impact surveys in three test areas - agricultural land, mountain top and forest ridge.

Accumulation of new field data on bat species composition and distribution in open agricultural areas (e.g. Dobrodzha, Thracian Plain) and over mountain passes in Stara planina Mts, Rhodopes Mt., Slavyanka Mt. and Osogovo Mt.

Identifying major bat migration routes / corridors in Bulgaria.

Identifying importance of each known transient roost and discovery of new ones.

Introduction of new research methods (e.g. radar and thermal imaging techniques).


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REFERENCES USED FOR POLYGON MAPPING AND SIZING BENDA, P., T. IVANOVA, I. HORÁČEK, VL. HANÁK, J. ČERVENÝ, J. GAISLER, A. GUÉORGUIEVA, BP, VL. VOHRALÍK. 2003. Bats (Mammalia: Chiroptera) of the Eastern Mediterranean. Part 3. Review of bat distribution in Bulgaria.- Acta Soc. Zool. Bohem., 67: 245–357.

BORISSOV I. 2010. Research on bats (Mammalia: Chiroptera) in the valley of Roussenski Lom River system. Underground roosts and their importance for the local bat community.- unpublished M.Sci thesis, University of Sofia, Faculty of Biology, 65 p. (in Bulgarian).

BORISSOV I. 2006. Research on bats of Uzana Resort Area, Balgarka Nature Park.- unpublished project report, Directorate of Balgarka Nature Park, 14 p. (in Bulgarian).

DIETZ C.2007. Aspects of ecomorphology in the five European horseshoe bats (Chiroptera:Rhinolophidae) in the area of sympatry.- unpublished PhD thesis, Faculty of Biology, University of Tuebingen, 237 p.

HUBANCHEVA A. 2009. Bats (Мammalia: Chiroptera) of the Osogovska planina mountain-results from a survey carried in 2008.- In: 120 years of academic education in biology- 45 years Faculty of Biology “XI Anniversary Scientific Conference Biotechnol. & Biotechnol.” Eq. 23/2009/special edition/on-line, 72-76 p.

INDEX OF CAVES IN BULGARIA- Bulgarian Federation of Speleology

http://www.speleo-bg.com/ and http://www.hinko.org

IVANOVA T. 2005a. Important bat underground habitats (IBUH) in Bulgaria.- Acta Zoologica Bulgarica, 57 (2): 197-206.

IVANOVA, Т. 2005b. Conception for the conservation of bats and their habitats in Bulgaria within NATURA 2000 network.- unpublished report, Preparation of the Bulgarian Natura 2000 network of protected zones, http://www.natura2000bg.org/ (in Bulgarian).

IVANOVA T., A. GUEORGUIEVA. 2005. Bats (Mammalia: Chiroptera) of the Eastern Rhodopes (Bulgaria and Greece) – species diversity, zoogeography and faunal patterns. - In: Beron P. & Popov A. (eds). Biodiversity of Bulgaria. 2. Biodiversity of Eastern Rhodopes (Bulgaria and Greece). Pensoft & Nat. Mus. Natur. Hist., Sofia, 907-927.

PANDOURSKI I., V. POPOV 2009. Monitoring study on bats (Mammalia, Chiroptera) in Eastern Rhodopes, Bulgaria.- In: Conference “Explоration and protection of karst and caves”, 50th years Student Speleological Club “Akademic”- Sofia, 24.10.2008., 148-156. (in Bulgarian, English summary).

PETROV B. 2001. Bats (Mammalia: Chiroptera) in Kresna Gorge, SW Bulgaria.- In: Beron P. (ed.) Biodiversity of Kresna Gorge, National Museum of Natural History, Institute of Zoology, 325-330. (in Bulgarian, English summary).


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PETROV B. 2005. Bats (Chiroptera) of Ponor Mountain.- In: “Conservation of globally important biodiversity in the grasslands of the Ponor Mountains through support for the traditional local economy”, GEF, Bulgarian Society for the Protection of Birds, 10 pp., 2 Annexes. (in Bulgarian).

PETROV B. 2007. Bats (Mammalia: Chiroptera) of Maglenik Ridge, Eastern Rhodopes, Bulgaria.- project report, UNDP Rhodope Project, National Museum of Natural History, 8 pp., 2 Annexes (in Bulgarian).

PETROV B., G. STOYANOV, B. GUEORGUIEV, CH. DELTSHEV, P. STOEV, Z. HUBENOV, K. DONCHEV, B. ZLATKOV, S. ZIDAROVA, D. CHOBANOV, T. LYUBOMIROV. 2007. Fauna ot Nature Park ”Vrachanski Balkan".- In: Management Plan of Nature Park "Vrachanski Balkan", Agrolesproject, 122 p, + 4 Annexes (in Bulgarian).

PETROV B., O. V. HELVERSEN. [2010]. Bats (Mammalia: Chiroptera) of the Western Rhodopes Mountain (Bulgaria & Greece).- In: Beron P. (ed.). Biodiversity of Bulgaria. 4. Biodiversity of Western Rhodopes (Bulgaria and Greece). Pensoft & Nat. Mus. Natur. Hist., Sofia.

POPOV V., PANDURSKI I., PANDURSKA-WHITCHER R. & BESHKOV V., 2005. Small mammals (Insectivora, Chiroptera, Lagomorpha, Rodenia) in the area of Strandzha Mountain, South-Eastern Bulgaria. In: N. Chipev (ed.) „Challenges of Establishment and Management of a Trans-Border Biosphere Reserve Between Bulgaria and Turkey in Strandzha Mountain", UNESCO-BAS Workshop, Bourgas, 10-13 November 2005, 87-104.

GENERAL REFERENCES ON BATS AND WIND TURBINES

Assessing Impacts of Wind-Energy Development on Nocturnally Active Birds and Bats: A Guidance Document http://www.wind-watch.org/documents/wp-content/uploads/wild-71-08-45.pdf Bat Fatalities at Wind Turbines: Investigating the Causes and Consequences http://www.fort.usgs.gov/BatsWindmills/ Bats and wind turbines- advice from an expert http://www.awea.org/faq/sagrillo/ms_bats_0302.html Bats and Wind Turbines. Pre-siting and pre-construction survey protocols (Revised May 2008) http://www.srd.gov.ab.ca/fishwildlife/guidelinesresearch/pdf/inventoryguide/Bats_and_wind_survey_protocol_May_2008.pdf


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Bats – methodology for environmental impact assessment and appropriate assessment. A manual for developers, environmental experts and planning authorities. Petrov B. 2008. National Museum of Natural History-BAS, 88 p. http://nmnhs.com/display_en.php?id=bat-research-and-conservation-centre Bulgaria- a national report on the implementation of The Agreement on the Conservation of Populations of Bats in Europe (2004-2009). http://www.eurobats.org/documents/national_reports.htm] California Guidelines for Reducing Impacts to Birds and Bats from Wind Energy Development http://www.energy.ca.gov/windguidelines/index.html Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses.- http://www.bu.edu/cecb/reprints/2007/Kunz.Bats%20&%20Wind.07.pdf Environmental Assessment Studies on wind turbines and bat populations - a step towards best practice guidelines http://www.bach-freilandforschung.de/download/Harbusch_Bach_2005.pdf Guidelines for consideration of bats in wind farm projects. Rodrigues, L., L. Bach, M.-J. Dubourg-Savage, J. Goodwin & C. Harbusch, 2008: EUROBATS Publication Series No. 3 (English version). UNEP/EUROBATS Secretariat, Bonn, Germany, 51 pp. http://www.eurobats.org/publications/publication%20series/pubseries_no3_english.pdf Wind Turbine Guidelines Advisory Committee Technical Workshop and FACA Meeting February 26-28, 2008 http://www.fws.gov/habitatconservation/windpower/Meeting_Feb_26_28_2008/Technical_Workshop_and_FACA_Mtg1.html Wind turbine interactions with birds and bats: a summary of research results and remaining questions http://www.nationalwind.org/publications/wildlife/wildlife_factsheet.pdf Migration of bats past a remote island offers clues toward the problem of bat fatalities at wind turbines http://www.fws.gov/sfbayrefuges/Farallon/cryan&brown_2007_biocon.pdf Patterns of Bat Fatalities at Wind Energy Facilities in North America (2008) http://www.batsandwind.org/pdf/arnett2008patbatfatal.pdf


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Relationships between Bats and Wind Turbines in Pennsylvania and West Virginia: An Assessment of Fatality Search Protocols, Patterns of Fatality, and Behavioral Interactions with Wind Turbines http://www.batcon.org/wind/BWEC2004finalreport.pdf Variation in bat and bird fatalities at wind energy facilities: assessing the effects of rotor size and tower height. http://www.bio.ucalgary.ca/contact/faculty/pdf/Barclay07Tur.pdf


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Hypotheses for bat fatalities at wind energy facilities

1. Linear corridor hypothesis. Wind energy facilities constructed along forested ridgetops create clearings with linear landscapes that are attractive to bats.

2. Roost attraction hypothesis. Wind turbines attract bats because they are perceived as

potential roosts.

3. Landscape attraction hypothesis. Bats feed on insects that are attracted to the altered landscapes that commonly surround wind turbines.

4. Low wind velocity hypothesis. Fatalities of feeding and migrating bats are highest

during periods of low wind velocity.

5. Acoustic attraction hypothesis. Bats are attracted to audible and/or ultrasonic sound produced by wind turbines.

6. Visual attraction hypothesis. Nocturnal insects are visually attracted to wind turbines.

7. Echolocation failure hypothesis. Bats cannot acoustically detect moving turbine blades

or miscalculate rotor velocity.

8. Electromagnetic field disorientation hypothesis. Wind turbines produce complex electromagnetic fields, causing bats to become disoriented.

9. Decompression hypothesis. Rapid pressure changes cause internal injuries and/or

disorient bats while foraging or migrating in proximity to wind turbines.

10. Thermal inversion hypothesis. Thermal inversions create dense fog in cool valleys, concentrating both bats and insects on ridgetops.

Source: Ecological impacts of wind energy development on bats: questions, research needs,

and hypotheses http://www.bu.edu/cecb/reprints/2007/Kunz.Bats%20&%20Wind.07.pdf

Note: Information presented in this report is based on available data until 1st February 2010.

Sofia, 22nd February 2010


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APPENDIX F: Main directions for investigating the behavior of birds and bats, as a risk indicator at operational wind farms and future wind projects


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Main directions for investigating the behavior of birds and bats, as a risk indicator at operational wind farms and future wind

projects Prepared by: Associate professor V. Delov, PhD

Approach:

I. It is important to compare data before and after the construction of the wind farm II. Calculating the number of killed and injured individuals of each species per turbine per year in

order to obtain results comparable with other studies.

III. Selection of observation points, in a way that allows to determine the distance between the animal and the turbine for all flight types and movement types.

IV. Elaboration of methods for usage of objective register systems – photo-traps, cameras, sensors, sound recording and analyzing devices.

Tasks and methods

• The behavior is assessed at a distance of maximum 250 m from the wind farm • Description of the behavior in risk situations – when the animal passes in less then 5

m from the turbine. • Taking into account the season variability and the dependency on the construction of

certain turbines. • The height of the flight of native and migrating birds and the frequency of passaging

through the area, the flight direction, the flight type. • Deriving specific coefficients related to the frequency of passage and the number of

killed birds for a certain wind farm. • Specific flight behavior within the wind farm/ project proposal - it is described ad.

libitum. • Analysis of the behavior during collision with the turbine - direct and retrospective • Types of species-specific bird reactions related to the turbine – analysis of the specific

behavior consequences. • Minimum distance between the animal and the turbine. • Investigation of the correlation between the flight height and frequency, and the

meteorology variables. • Counting of the birds sleeping and resting within the wind farm/ project proposal.

Description of the place and pose for sleep and rest. • Determining the ratio between the killed animals from the native and migrating birds

and bats. • Detailed observation and description of the behavior of the soaring birds using the

method of ad. Libitum. • Investigation of the wind generator as a potential refuge for birds and bats. • Collection of food under the generators.


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• Disorientation caused by different reasons.

Studying of the process of familiarization with wind turbines of the native birds and bats of high conservation importance. The following has to be taken into account:

1. Initial reaction of the investigated animals towards the construction activities and towards the constructed turbines.

2. Change of this reaction in time and through the process of familiarization. 3. Determination of spieces-specific and individual critical period of time after which the

familiarization could cause dulling of the fear reaction and collision with the turbine. 4. Development of the individual behavior models. 5. Description of the specie-specific strategy towards the wind farms. 6. Conclusion regarding the ability of the specie for development of optimal strategy

regarding the wind generators.

Experiments Experimental investigation of different coloring types of the wind generators in order to achieve repellent effect and testing others repellent systems. Classification I recommend that each observation is related to one of the following categories of functional behavior classification:

1. Individual behavior: Type of movements, feeding, protective reactions, sleep, rest, comfortable behavior,

migration day and night activity, play, searching of refuges 2. Social behaviour: Moving in group, perceiving the propeller as a flock and attraction to it, territorial behavior,

aggressive behavior between the animals, импортанце of the hierarchy structure. 3. Reproductive behavior: courting, copulation, building of nests, incubation, feeding, protection and training of the

youngs. 4. Behavior of the young birds 5. Teaching – description of all the gain reactions Choice of appropriate statistical methods for analyses of the data and methods for modeling. Note: Regarding bats, the applicability of the above mentioned main directions has to be determined.


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APPENDIX G: Minutes of SER consultation meetings

Appendix G1: SER technical consultation workshop: Sofia – May 25th, 2010 – 1 pm

Appendix G2: SER technical consultation workshop: Momchilgrad – May 27th, 2010 – 10 am

Appendix G3: SER public consultation meeting with the general public: Momchilgrad – May 27th, 2010 – 6 pm

Appendix G4: SER technical consultation workshop: Burga – May 28th, 2010 – 2 pm

Appendix G5: SER public consultation meeting with the general public: Burgas – May 28th, 2010 – 6 pm


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Appendix G1: SER technical consultation workshop: May 25th, 2010. Sofia

Press Center of Ministry of Economy, Energy and Тоurism

Meeting participants

# Name Position Organization

1 Peter Wouters Director Environ Iberia

2 Manuel Clar Director PM&E

3 Joana Soares Environmental Consultant Environ Iberia

4 Svetla Traycheva Management of Environmental Assessment Dept. POVVIK AD

5 Diana Dimitrova Environmental Consultant POVVIK AD

6 Apostol Dyankov Head of Sustainable Development Dept. POVVIK AD

7 Elena Ivanova Environmental Consultant POVVIK AD

8 Boyan Petrov Zoologist National Museum of Natural History, BAS

9 Irina Nikolova Mateeva Ornithologist POVVIK AD

10 Yulia Krasteva Ecologist NEC EAD

11 Valentin Ilievski Head of Department NEC EAD

12 Andrey Voynov Expert DSK Bank

13 Gyunnur Djoumalieva Head of Department MEET

14 Stanka Daskalova State Expert MEET

15 Valeri Rujin Head of Department NEC

16 Dimitar Donchev Project Manager Geopower OOD

17 Nikolay Karaivanov Ornithologist Zoology Institute-BAS

18 Dimitar Hristov Manager Geo Power

19 Gergana Pavlova Business Development AES Wind Power Development, B l i20 Ivo Nishanov Automation Engineer ESO EAD

21 Venelin Barosov Head Expert SCEWR

22 Stoyan Petkov Energy Transmission Engineer ESO EAD

23 Kalina Kalinova Legal Consultant Еnertrag Balkan EOOD

24 Deniza Nogarova Manager Еnertrag Balkan EOOD

25 Valentin Doichinov Project Manager Global Wind Power Bulgaria

26 Daniel Kralev PPM Division Manager CEZ Bulgaria AD

27 Zhivko Bogdanov “Forest” Program Coordinator WWF България


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# Name rise to aOrganization Organization

28 Maria Minova State Expert MEET

29 Milena Tsoleva State Expert MEET

30 Stoycho Stoychev Director, Nature Protection BSPB

31 Alexandrina Yaprakova Head Expert Nature Protection Service MoEW

32 Pavel Milanov Associate Office of the M. Kazak, Member f th EP

33 Petar Petrov Head of Department „Solar Energy Projects” ProEcoEnergia OOD

34 Dora Tomova Head of Alternative Fuels Sector ProEcoEnergia OOD

35 Tanya Trenkova Environmental Consultant GeoMarine-Center

36 Katrin Suroleiska RES Project Consultant New Europe Corporate Advisory OOD

37 Violeta Simeonova Head Expert “Business Development” Enel Green Power EAD

38 Valentin Vasilev Manager „Wind Sis” OOD

39 Renata Tsankova Director, Strategic Planning Nika partners

40 Nikolay Nikolov New markets, Head Expert Energy Efficiency Agency

41 Muren Guler Business Development Freelancer, Construction Carbon T di42 Denitsa Nencheva Legal Adviser Enel Green Power Bulgaria

43 Denis Lapshov Project Manager Valorem

44 Peter Ivanov Senior Scientific Associate, PhD National Institute for Meteorology and Hydrology, BAS

45 Maria Raycheva Head of Department Environment and Energy

Effi i

MEET

46 Alexandrina Dimitrova Head of RES Department MEET

47 Sebastian Noethlichs Manager, acting manager, Chair of the energy commission

N-vision Energy, German-Bulgarian Chamber of Commerce

48 Albena Tsankova Manager N-vision energy

49 Svetla Bratanova Head of Divison at the CLGE CLGE-BAS

50 Radoslav Mikov Sr. Associate DLA Piper, Bulgaria

51 Raina Georgieva Senior Еnvironmental А t Е t

MoEW, “EIA and SEA” Dept.

52 Rositsa Dimova State „NATURA 2000” Еxpert MoEW

53 Ivan Kroussachki Manager „Brest Energy” OOD

54 Ivan Hinovski Chairman Bulgarian Energy Forum

55 Stilian Burhanlarski Manager Eolica Bulgaria EAD

56 Todoro Lubenov GIS Expert


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57 Jacqueline Metodieva Head of EIA and EA Dept, Preventive Activities Directorate MoEW

58 Bilyana Petrova Local Wind Expert to the Consortium

Association of the Producers Ecological Energy

59 Zornitsa Pavlova Secretary Association of the Producers of Ecological Energy

60 Nesho Chipev, PhD Head of „Applied Ecology” team CLGE-BAS

61 Dobromir Dobrinov Expert Natura 2000 Green Balkans

62 Metin Ibryamov Legal Advisor APEE CH4

63 Petar N. Petrov Manager Enfinity

64 Yuliana Yankova Environmental Protection Director CEIB

65 Denitsa Petrova Coordinator NGO “Za Zemyata”

66 Dimitar Haralambiev Manager BEVEDE OOD

67 Aksinia Triova Expert MEET

68 Vassil Petev Member of BFA, Partner in 3V Management AD BFA, 3V Management AD

69 Valentin Simeonov Executive Director European Center for Environmental Economy

70 Kostadinka Todorova Director, Energy Efficiency and Environmental Protection

MEET

71 Milen Marinov Project Manager Winslow Group

Meeting Minutes

Diana Dimitrova (Environmental Consultant, POVVIK AD): Presented the content, objectives and status of the “Strategic Environmental Review of the wind power development in Bulgaria” project. The presentation included obtained results, conclusions and main project limitations.

After the presentation questions were raised in between the participants and consultants.

Kostadinka Todorova (Director, Energy Efficiency and Environmental Protection Directorate, Ministry of Economy, Energy and Tourism (MEET)):

• Opened the discussion by expressing her satisfaction of the completed work. She believes that the work has been done with competency and expertise and has even exceeded the scope of the tasks in the project Terms of Reference.

• Encouraged the representatives of the Ministry of Environment and Water (MoEW) to provide their unofficial opinion on the project.

• Wonders whether the proposed centralization of the Environmental Impact Assessment (EIA) decision making would not completely stop the development of green energy.


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Jacquelina Metodieva (Head of EIA/EA Department, Preventive Activities Directorate, MoEW):

• Confirmed that MoEW will submit an opinion within the official consultation process (June 8th).

• Stated that at the beginning of the project there were some problems with the methodology – the project was called a SEA but there was no wind development plan… Expressed an opinion that the SER report continues to have too many references to the SEA directive, which is unnecessary.

• Thinks that the recommendations for changes in the EIA procedure are not well explained and the report lacks a detailed analysis of the implementation of the present EIA procedure, which makes the recommendations for changes in the EIA procedure not serious enough.

• Hopes that the recommendation for centralization of the EIA decisions on projects falling within the red area is an appreciation of the good work that MoEW and her department does. However, she does not know of any plans at the central level for changes in the Environmental Protection Law and the EIA and EA regulations.

• Approves the fact that these sensitivity maps have been created. Nevertheless, MoEW were hoping to see maps in which the environmental constraints are overlaid with the wind potential.

Nesho Chipev, PhD (Head of Applied Ecology Group, Central Laboratory of General Ecology (CLGE), Bulgarian Academy of Science (BAS)):

• Stated that a lot of work has been done – work that is useful and well done.

• Asked whether information from monitoring studies from existing wind farms has been incorporated in the report.

• Thinks that the terms “constraints” and “sensitivity” have to be further defined and not mixed up.

Diana Dimitrova: Responded to Mr. Chipev that some data from bird monitoring, done with regard to planned wind projects, have been used. However, not all such data has been used because this information has been collected as part of the EIA process, paid by the investors and are the property of the investors.

Peter Wouters (Director, Environ Iberia):

• Responded to Mr. Chipev that the terms “sensitivity” and “constraints” are common terms used in the environmental field. If the terms are not clear in the draft report they will be better explained in the final report.

• Responded to Ms. Metodieva that the recommendations for a more centralized approach to environmental permitting is related with the expectation that this would result in a more uniform approach to the issue, and that this would be limited to the most sensitive areas.

Dobromir Dobrinov (NATURA 2000 expert, Green Balkans):

• Thinks that the current acknowledgements should be changed because the opinions of the environmental NGOs have not been fully taken into account. During the numerous consultations with the external environmental experts, cited in the acknowledgements, the levels of constraints decided for various layers with data were different (more stringent) than the levels of constraints presented in the report. The areas that were initially proposed to be


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black (i.e. wind power development forbidden) should have remained black. Because of that, the environmental NGOs who have provided the data do not stand behind this report.

• Asked why this change in the suggested levels of constraint has occurs.

• Thinks that the current maps are not helping much to resolve the current problems with wind power because they are not providing more clear guidance than there was before the project. Even before this project it was clear that wind power could not be built in areas where it is explicitly forbidden in the legislation and that at all other places wind projects should undergo EIA.

Peter Wouters (response to Mr. Dobrinov):

• Stated that the Consortiums is well aware and has emphasized in the report that Bulgaria is a country with very rich biodiversity. However, this project does not have the aim to do an EIA of the country, but rather to develop a methodology to ensure the sustainable development of wind power. The EIA is the essential tool to be used for the assessment of whether wind power development is possible in a certain area. The maps that have been produced give an indication on the degree of detail that the EIA should have.

• Reminded that the current version of the database is not its final version and that the database should continue to be improved and enlarged.

Zornitza Pavlova (Secretary, Association of the Producers of Ecological Energy (APEE)):

• Emphasized that APEE is a balanced organization which aims to promote a sustainable energy. None of the APEE members have built on lands within Natura 2000.

• Thinks that the current combined map shows that wind power cannot be developed in Bulgaria and that there are some very limited opportunities for wind power development but they are at places which are not suitable because there is not enough wind there.

• Expressed an opinion that the impacts from the wind power development should not be compared to no development but to the development of other conventional energy sources.

• Asked whether there is a specification of the term “current wind power technology”.

Peter Wouters (response to Mr. Pavlova):

• Stated that the Consortium is convinced that wind power is necessary and should be developed and disagreed that the current map implies that wind power cannot be developed in Bulgaria.

• It has not been the goal of this study to compare energy from RES with energy from conventional energy sources.

• The technical parameters of wind power will be reviewed in much more detail in additional documents.

Irina Mateeva (Expert on ornithology to the Consortium): Added that AES is one of APEE’s members and AES has a project located on a territory proposed for Natura 2000 zone. Even though the territory where the AES wind farm is located has not been designated as Natura 2000 yet, according to EU legislation, this territory is subject to strict protection. Two infringement procedures have been initiated against Bulgaria because of this territory (Kaliakra), including because of the AES project. Therefore, this information should be kept in mind when APEE makes statements regarding the projects of its members.


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Zornitza Pavlova: Currently, this combined map cannot be included in the RES plan because it does not include wind potential.

Peter Wouters: Stated that how the results of this study will be used is beyond the control of the Consortium.

Kostadinka Todorova: Stated that she also did not get the idea that it is OK to build wind turbines everywhere outside the black zones.

Irina Mateeva:

• Inserted that the wind technology which has been taken into account in this report is the currently prevalent one – with rotor and blades.

• Added that the mortality from wind power developments should not be compared to mortality from other anthropogenic factors because it is additional to them, not a substitute to them.

Stoycho Stoychev (Director Environmental Protection, Bulgarian Society for the Protection of Birtds (BSPB)):

• Reminded that BSPB is a balanced organization which has taken part in the EIAs of many wind projects.

• Stated that BSPB has provided a lot of data for this project but BSPB does not agree with the maps because they do not express sufficiently the level of constraints (in his opinion the maps are not stringent enough).

• Stated that the conflicts between the stakeholders, experts, scientific community should be discussed using the maps as a discussion base.

• Emphasized his belief that EIA at a National level will not work.

• Suggested to include an extra color – dark red, for NATURA 2000 areas.

Kostadinka Todorova:

Asked the following questions:

• Is there any proof for destroyed habitats as a result of wind power development in Bulgaria?

• What is the number of killed birds in Bulgaria as a result of wind power development?

• Is Bulgaria suitable for offshore wind power development?

• Why it is not stated in the report that these maps relate only to the current wind technology?

• Has the Consortium done calculations regarding the theoretical wind capacity which can be installed in Bulgaria, considering the environmental constraints?

Peter Wouters: Encouraged Mr. Stoychev to submit a written statement where the suggestions for changes in the colors are clearly stated.

Manuel Clar (Director, pm&E): Explained that areas sensitivities can be changed in accordance to new developments and in the event that new information becomes available.

Sebastian Noethlichs (Manager, N-Vision; Chair, Energy commission of German Chamber of Commerce in Bulgaria):


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• Stated that the German investors are very worried by this report that the report is too one-sided (in favour of environmentalist views).

• Further added that the report has 7 objectives (groups of environmental components) but that most of the data is supporting the objectives related to birds and bats.

• Wanted an explanation why the total score of biodiversity is -64, while the assessment of the economic benefits is only +1.

• Indicates that the type of technology is important for the impact. The height of turbines is increasing and this needs to be taken into account when assessing the impacts, as most birds fly at low altitude.

• Thinks that a particular study which has been used in the explanation of impacts on birds is too outdated – from 1992.

• Disagrees with the recommendation about fences (leaving an open space near the ground so that small animals can pass through) because fences are used only for substations to prevent electrocution of people and animals.

Diana Dimitrova (response to Mr. Noethlichs):

• Explained that the large number of data used for spatial analysis which refer to biodiversity can be explained with two factors – the availability of such data and the assessment for significant negative impacts (as described in Section 6 of the report). Attempts were made to obtain spatial data for all identified environmental and social components but the efforts in data acquisition were proportionate to the assessed level of impact.

• Clarified that scoring was done for the assessment of the impacts only in order to be able to compare the impacts on the different environmental components – as scale. The scores are not meant to be taken as absolute numbers and should not be summed up within each category of components.

• Pointed that the report includes a statement that the maps refer only to the current wind technology. Added that the assessment of the impacts has taken into account the height of the currently used wind turbines (2-3 MW) and that international wind experts (Spanish wind experts) have participated as team members in the preparation of this environmental report.

• Rejected the claim that outdated sources are used throughout the report, pointing that Mr. Noethlichs has chosen to cite only the oldest publication. Added that the report is based on numerous publications, many of which are from the last few years.

Joana Soares (Consultant, ENVIRON):

• Addressed the issue of wind farm fencing, mentioned in the report, by clarifying that she agrees with Mr. Noethlichs that many wind farms do not have fences. However, some wind farms do have them, due to several reasons, such as property issues, boundaries, security, etc. So, the recommendation is relevant for the current situation.

• Added that the environmental team includes both international (Spanish) and local (Bulgarian) wind experts.

Kostadinka Todorova:

• Urged the audience to use the time left more wisely by avoiding any more questions about the competencies of the consultants, because the competency of the consultants have been well


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proven. Emphasized that even if someone disagrees with the conclusion of the reports, it should be clear to everyone that the consultants have done a great amount of good work.

Maria Mihaleva (Attorney at law): Asked the following questions:

• Why data about agricultural land 1-4 category has been attempted to be collected?

• Is the Consortium familiar with the recommendations made by the MOEW to RIEWs regarding wind power development?

• Why does the report suggest a full inventarization of flora and habitats as part of the EIAs?

Diana Dimitrova:

• Responded to Ms. Mihaleva that a spatial layer with agricultural lands 1-4 category would have been included in the maps, if available, because of the proposed change in the Law for protection of agricultural lands which envisions that all RES projects on these lands should be prohibited. If such ban was not impending, the Consortium would have assessed these areas as having low sensitivity.

• Confirmed that the Consortium is well familiar with the recommendations from MOEW to RIEWs, issued earlier in the year.

Manuel Clair:

• Addressed the third question of Ms. Mihaleva by explaining that inventories are a useful tool to understand which flora and fauna exist in a certain area. Currently, all EIA need to have a fauna and flora inventory in order to be accepted.

Petar Ivanov (Head of department at National Institute of Meteorology and Hydrology at BAS):

• Stated that since the current maps do not take into account the wind resource, they are not useful at all.

• Suggested that fact that money has been spent on foreign consultants does not oblige Bulgaria to use the results of their study and believes that the quality of the study is questionable because local experts were not used.

Diana Dimitrova:

• Clarified that the Consortium has attempted to obtain wind data but such was not made available. The full spatial analysis of wind power, as stated in the report, should include information on environmental constraints and wind power potential. The environmental report has explored only the first half of the whole because there has been no information on the other half. Nevertheless, this by no means diminishes what has been achieved by the report. Simply in the future, the wind potential has to be added to the created maps with environmental constrains. The Institute of Metrology and Hydrology is more that encouraged to create a map of the wind potential which can be used to complete this analysis.

• Disagrees with the claim that local experts have not been used because this does not correspond to the truth. Besides the local consulting company which has been hired as part of this project team, some of the best experts on bats and birds have already been made part of the team. In addition to that, more than 40 local experts in various fields have been consulted through numerous meetings and their input has been taken into consideration.


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Katrin Suroleyska (Associate, New Europe Corporate Advisory):

• Inquired whether there are similar maps made for other European countries.

• Asked how the uncertainties of some of the data have been reflected in the report.

• Thinks that the current maps cannot be used because, as pointed by the consultants, some data is missing.

• Suggested that the fact that the maps are not usable is confirmed by the fact that NGOs do not stand behind them.

• Asked how the database will be developed in the future.

Peter Wouters:

• Expressed his belief that the approach of the map is suitable as it provides an overall indication of the environmental sensitivity of the country for wind power development and therefore can be used to guide the policy for wind power development. There are similar environmental inventories in other countries, such as Sctoland, England, France, Spain, etc.

• The goal of these maps are not to prohibit wind power development but to steer that development towards more suitable areas.

Nesho Chipev:

• Shared that at the beginning of the project he was very skeptical about the creation of these maps. However, now when the maps are a reality, he believes that they are well done and that the consultants have accomplished a lot of good work.

• Believes that the tension in the room is related to the fact that the terms “sensitivity” and “constraints” have been used interchangeably in the report, while they mean different things and have different implications. Indicates that the important factor is risk.

• Thinks that the biodiversity factor has been excessively highlighted and that if similar maps are prepared for other RES the whole country will probably look black.

• Suggested to the consultants to create criteria which can help investors to determine the level of risk.

Peter Wouters: Stated that the maps indicated the overall sensitivity. Site specific EIAs will provide information on risks.

Kostadinka Todorova: Thinks that in its current state, the map is not quite applicable to the RES plan. Indicated that there is no data on wind potential and therefore no calculations can be made of available wind power taking into account the environmental constraints.

Violeta Simeonova (Expert on Business Development, Enel Green Power): Inquired about how these maps can be accessed. Many investors would like to locate their projects in relation with the identified environmental constraints.

Diana Dimitrova: Answered Ms. Simeonova that as part of this project the maps will be available only within the report – as they currently are. It is up to the MOEW and/or MEET to create an online GIS system where these maps can be accessed.

Gergana Pavlova (Business Development, AES):


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• Stated that AES did not know that there is an infringement procedure against the AES wind park.

• Inquired whether the seasonality of the environmental components has been taken into account.

Diana Dimitrova: Answered Ms. Pavlova that the seasonality has been taken into account.

Sebastian Noethlichs:

• Asked whether ENVIRON has conducted projects of similar scope and complexity before, and whether they are comparable to the project in Bulgaria;

• Asked how and by whom the dataset will be updated.

Joana Soares: Explained that ENVIRON is a multinational company, which has been working for the last 3 decades in all environmental fields and has performed projects with similar complexity in various parts of the world.

Diana Dimitrova: Updating the dataset is in the hands of the MEET / MoEW.

Dobromir Dobrinov: Recommended the Consortium to include only the partial maps and not the aggregate maps in the report in order not to present a too negative picture to investors.

End of the Meeting


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Appendix G2: SER Technical Consultation Workshop:

Momchilgrad – May 27th, 2010 – 10:00 am







5 Irina Mateeva Ornithologist POVVIK AD

6 Sabina Syulyukchieva Head of Department

„Eurointegration, regional development and PR”

Kardzhali District Administration

7 Iva Uzunova Junior Expert „Ecology, Water and European programs” Kardzhali District Administration

8 Sevdalin Ognyanov Deputy Mayor Momchilgrad Municipality

9 Halil Sali Halil Senior Expert „EPP” Momchilgrad Municipality

10 Shengul Mestan Junior Expert „Waste Management” Momchilgrad Municipality

Meeting Minutes

Diana Dimitrova (Environmental Consultant, POVVIK AD): Presented the content, objectives and status of the “Strategic Environmental Review of the wind power development in Bulgaria” project. The presentation included obtained results, conclusions and main project limitations.

After the presentation questions were raised in between the participants and consultants.

Diana Dimitrova: Аsked the participants whether there is an interest in the region in the questions raised during the presentation regarding wind energy.

Sabina Syukyulchieva (Head of Eurointegration, Regional Development and PR Department, Kardzali District Administration): Explained that in her opinion there is some interest in using wind energy for domestic purposes.

Diana Dimitrova: Asked the participants whether they have information about big investment projects in the region.

Sabina Syukyulchieva: Answered that she does not have any information about big investment projects.

Diana Dimitrova: Inquired about the type of projects which the Eurointegration, Regional Development and PR Department at the Kardzali District Administration usually deal with.


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Sabina Syukyulchieva: Answered that very few projects are overseen by the district administration. Those that are, are mainly in the tourism sector. The district administration mainly has coordinative and representative function of the national government and state policy.

Joana Soares (Consultant, ENVIRON Iberia): Asked about the opinion of the local community regarding wind energy.

Sabina Syukyulchieva:

• Answered that in her opinion the attitude of the local people is mostly positive, because there are quite a few polluting industries in the area, and wind energy is perceived as clean energy. However, after hearing this presentation, she realizes that information about the adverse effects, associated with wind energy is insufficient. Stated that she has learned many new things from this presentation and that she does not much experience with actual wind projects until now. With regard to other RES, there are some micro hydropower generation projects.

• Asked if consultants could do something about already approved permits, which can be repealed on the basis of the new maps?

Diana Dimitrova: Answered to Ms. Syukyulchieva that it is up to MoEW to make decisions on pending or already issued permits.

Manuel Clar (Director, pm&E): Added that if existing wind parks have to be decommissioned, some compensation scheme for the investors have to be established.

Sabina Syukyulchieva: Asked why there аre Spanish consultants participating in this project?

Manuel Clar: Explained that the project financing has been provided by the Spanish government and also, Spain has a lot of experience in that area. Further, the project team has also used the good European practices.

Sabina Syukyulchieva:

• Thinks that the Ministry has to disclose more information about the project. The Kardzali District Administration is currently preparing a district development strategy and is in the data gathering stage. All data regarding the environment will be useful.

• Stated that will visit the project website to obtain the latest version of the report, as well as the guidance documents. These documents may be uploaded on the District administration website, so that they are shared with the local public.

End of the Meeting


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Appendix G3: SER General Consultation Workshop:

Momchilgrad – May 27th, 2010 – 6:00 m








6 Sanie Myumyun Student - volunteer BSPB

Meeting Minutes

Diana Dimitrova (Environmental consultant, POVVIK AD): Made a presentation about the content, objectives and status of the “Strategic Environmental Review of the wind power development in Bulgaria” project. The presentation included obtained results, conclusions and main project limitations.

No questions were raised.

End of the Meeting


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Appendix G4: SER Technical Consultation Workshop:

Burgas – May 28th, 2010 – 2:00 pm








6 Bilyana Petrova Local Wind Expert to the

Consortium REA EU

7 Asen Atanasov Manager Bulmark

8 Angel Angelov Chairman Bulmark

9 Katya Karausheva Teacher PGEE K. Fotinov

10 Zhenya Dimitrova Head Expert „Electric Construction

Directorate Burgas Municipality

11 Dimitar Sotirov Senior Inspector EKOOS Burgas Municipality

12 Marineta Nikolova Head of Environmental

Management Department Burgas Municipality

13 Stilyana Mihaylova Head of International Projects

Department Burgas Municipality

14 Nikolina Ilieva Ecologist VANG EOOD

15 Veselin Sharlopov Manager VANG EOOD

16 Stanimir Tsanov Expert RIEW Burgas

17 Veselina Doseva Expert RIEW Burgas

18 Hristoslav Pavlov Manager WPD Bulgaria

19 Zornitsa Pavlova Secretary Association of the producers of the

ecological energy

20 Martin Ibryamov Legal Advisor Association of the Producers of

ecological energy

21 Hristo Dimitrov Sotirov Construction Manager Multi Had, OOD


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Meeting Minutes

Diana Dimitrova (Environmental consultant, POVVIK AD): made a presentation about the content, objectives and status of the “Strategic Environmental Review of the wind power development in Bulgaria” project. The presentation included obtained results, conclusions and main project limitations.

Histoslav Pavlov (Manager, WPD Bulgaria):

• Asked for the reason for not including representatives of the wind business in this project. Thinks that companies such as AES have a lot of experience in the field.

• Shared his concern that the maps, in their current scale representation, will be used as a decision tool, especially when there is no wind potential data.

• Wonders why it is so that about 95% of the spatial data is about flora, fauna and biodiversity.

Diana Dimitrova (response to Mr. Pavlov):

• Explained that representatives of business organizations have been consulted at different stages of the projects. Most of the business representatives however are not experts on environmental topics but rather experts on technical and business issues related to wind power development. Because of that, the representatives of the business are not included in the acknowledgement section of the environmental report. The opinions and recommendations of the business representatives will be taken into consideration in the technical guidance documents which will be ready in June.

• Stated that the Consortium knows that there are three key components to finding the most suitable locations to wind power development – 1) the wind potential data, 2) the environmental and social constraints and 3) the technical feasibility to connect the project to the grid. The Consortium has attempted to find spatial information on all three aspects. However, spatial data was available only about the environmental and social constraints. Further, the goal of this environmental report is to focus on the impacts of wind power on the environmental and social aspects. Therefore, even though the maps included in the report contain information only on environmental and social constraints to wind power development, the Consortium is convinced that they will be still very useful to the wind business, the authorities and the public in general.

Histoslav Pavlov:

• Expressed his concern that the maps will be used by the MOEW not in the best way.

• Asked whether the Consortium plans to include in the final report that the maps cannot be used to ban on wind power development.

Manuel Clar (Director, pm&E) (response to Mr. Pavlov):

• Explained that the goal of the maps is not to forbid development but rather to show where the places with high sensitivity are. Emphasized that the maps are not a finished product and that the information needs to be updated and expanded.

• Expressed his disagreement that the maps are not useful. These maps are a tool, which the various institutions have not had before.

Irina Mateeva (Ornithology consultant to POVVIK AD):


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• In relation to the questions of Mr. Pavlov, stated that the project has used published data from satellite observations of bird species, which are quite accurate. Also, information from multi-year bird counting has been utilized. This is real and mostly published data.

• Emphasized that the data, collected as part of this project, was present at various institutions and organizations and was not publicly available and this report provides public access to this abundant information.

• Reminded that these maps are relevant only for the current wind technology and the maps will probably look very different if the wind technology changes significantly.

• Added that the Bulgarian Biodiversity Act lists many legal requirements for the protection of the biodiversity in the country and the maps are based on these requirements.

Histoslav Pavlov:

• Stated that no one is questioning the presence of bird migration in Bulgaria but that the current nation-wide study cannot provide information for all locations.

• Fears that the maps will be used directly, without taking into account all limitations expressed in the report and further, that the maps will be used to forbid wind power development in large parts of the country.

Veselina Doseva (Expert, RIEW Burgas): Expressed her opinion that the report is useful because it combines in a single place a lot of information about the environmental components.

Diana Dimitrova: Inquired whether there are any wind projects at RIEW Burgas which are undergoing EIA.

Veselina Doseva:

• Answered that there are a few ongoing EIA procedures for wind farms but as far as she knows no EIA decisions have been issued yet.

• Stated that in her opinion the noise associated with wind power development is a serious issue, which has not been considered in great detail in the SER report.

Katya Karausheva (Teacher, PGEE K Fotinov): Wondered how the size of the red areas on the map presented in the SER report compares to the size of the red zones in similar maps of Greece and Romania. This question is related to the fact that the Via Pontica bird migratory route passes through Romania and Greece as well.

Irina Mateeva: Explained that in order to be able to make such comparison, there should be such maps for Romania and Greece, which is not the case. In general, the environmental sensitivity towards wind power development in the Danube delta in Romania is very high.

Stilyana Mihaylova (Head of International Projects Department, Burgas Municipality):

• Asked why it is recommended that wind power installations above 100kW should undergo EIA.

• Asked how the distinction was made between red and black zones.

• Shared her experience with a similar project which was focused on the Burgas region only. This project combined some measurements of the wind potential in the region with information on the environmental constraints. Although statements were made in the report of


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the Burgas project that its results and maps are indicative, the report was later used as an absolute point of reference. She thinks that it is likely that the results of the SER report will also be used in a similar way.

Manuel Clar: Stated that the current project has been initiated by the EBRD and MEET as a response to a couple of infringement procedures which have been started against Bulgaria. All recommendations included in the SER report are targeting to solve the issues resulting in infringement procedures. The recommendations of the SER report are tightly linked with the assessment of the cumulative effects in all future wind power projects.

Diana Dimitrova: Added that the threshold of 100kW is based on a few factors – 1) international experience – there are countries in which all wind power projects above 100kW undergo EIA; 2) anticipated legislation changes – it is expected that the new RES law will contain a clear distinction between wind turbines for domestic electricity production, for local industrial production and for commercial electricity production, where 100kW is used as a threshold between the first and second category; and 3) size of wind turbines - 100kW wind turbines are considered large enough to have considerable impacts on biodiversity.

Katya Karausheva: Wonders how the recommendations made in the report will be used by the ministries.

Diana Dimitrova: Answered that this is entirely up to the MEET and MOEW how they will use the results of the SER report.

Katya Karausheva: Shared her fear that if all recommendations included in the report are directly applied to all wind projects, this would cause problems. For example, if the recommendation for turbine shut down systems becomes mandatory for all wind turbines – this will not be technically feasible because many systems will defect.

Diana Dimitrova: Agrees with Ms. Karausheva and adds that using emergency shut-down systems at all wind parks will not only be technically challenging for the individual wind farms but will also pose serious problems for the electrical system operator.

Bilyana Petrova (Local Wind Expert to the Consortium, REA EU):

• Explained that the shut down systems are designed in a way, so that not all wind turbines in a wind park are shut down at the same time – single turbines or groups of turbines are shut down at intervals of time. The new turbines are not so negatively impacted by the use of shut down systems. However, second-hand wind turbines are much more likely to have problem with the shut down systems.

• Clarified that the decision to use new wind turbines or second-hand ones is a matter of economics. Unfortunately, some quite old turbines have been installed in Bulgaria and Bulgaria is starting to look like a museum for wind turbines. However, all large projects are using new turbines.

Hristo Sotirov (Construction Manager, Multi Had OOD):

• Inquired whether the maps can be provided in larger scale.

• Wonders whether it is possible to separate the bird flying/migration corridors by the height of the flight of each bird species.


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• Shared his concern that regardless of the disclaimers made in the report about the maps and how it should be used, these maps will be used by experts in RIEWs to ban outright all projects located in red areas.

Diana Dimitrova (response to Mr. Sotirov):

• Explained that as part of this project the maps will not be presented in a different scale. It is hoped that that MEET or MOEW will take ownership of the maps and make it possible for all stakeholders to access the information contained in them in an appropriate manner.

• Expressed hope that this report and the maps in it will be used by RIEWs and MOEW to make more informed decisions. This project has attempted to collect all available information on the environmental and social constraints – information which previously was stored at different institutions and organizations and was never combined and analyzed in a common framework.

Irina Mateeva: Informed that there another, more detailed project dealing with the environmental constraints for wind power is planned by MOEW. This new project will investigate in more detail the bird migrations and other environmental limitations in relation to wind power development. It is expected that this upcoming project will provide answers to some questions (such as differentiating the height of bird flight) which the current project was not able to because of time and budget constraints.

End of the Meeting


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Appendix G5: SER General Consultation Workshop:

Burgas – May 28th, 2010 – 6:00 pm








6 Nikofor Shterev Мanager Shterev OOD

7 Valentina Angelova Regional Coordinator BSPB

8 Stilyana Mihaylova Head of International Projects

Department Burgas Municipality

Meeting Minutes

Diana Dimitrova (consultant at POVVIK AD): made a presentation about the content, objectives and status of the “Strategic Environmental Review of the wind power development in Bulgaria” project. The presentation included obtained results, conclusions and main project limitations.

Stilyana Mihaylova (Head of International Projects Department, Burgas Municipality):

• Expressed her opinion that the MEET has to issue a guidance document which will better regulate the development of wind power in Bulgaria.

• Agrees that if a single institution, MOEW, makes decisions on the most important wind projects, the approach will be more uniform.

• Shared her experience that there is usually lack of information at the RIEWs. Often investors interested in wind power development go to the RIEW to obtain information about environmental constraints before they purchase a land plot but the RIEW does not provide them with any information.

• Thinks that in current permitting process many different institutions issue various permits and every institution is interested only in its own permit without paying much attention to the content and quality of the other permits. This creates inefficiencies and often important issues are missed.

• Expressed her interest in more information about opportunities for off-shore wind power development in Bulgaria.

• Hopes that this report will be taken into consideration by MEET and MOEW.

End of the Meeting


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APPENDIX H – Clarification notes on the statements received during SER consultation process

Appendix H1: Clarification notes on the comments received by Mr. Kenneth Levkovitz on the SER Environmental Report

Appendix H2: Clarification notes on the statement received by N-Vision on the SER Environmental Report

Appendix H3: Clarification notes on the statement received by the Coalition "For the Nature in Bulgaria" on the SER Environmental Report

Appendix H4: Clarification Notes on the statement received by the Bulgarian Society for the Protection of Birds on the SER Environmental Report

Appendix H5: Clarification Notes on the statement received by the Bulgarian Ministry of Environment and Water on the SER Environmental Report

Appendix H6: Clarification Notes on the statement received by the Association of the Producers of Ecological Energy on the SER Environmental Report


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Appendix H1: Clarification notes on the comments received by Mr. Kenneth Levkovitz on the SER Environmental Report

Clarification Notes to the comments received by

Mr. Kenneth Levkovitz

On behalf of:

New Europe Corporate Advisory, Ltd.

on the SER Report of the Development of Wind Power in Bulgaria

Prepared by:

ENVIRON Iberia, pm&E, POVVIK AD

Date: June 2010


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Table of Contents Introduction 3

Clarification Notes 3

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Clarification notes on the comments received by Mr. Kenneth Levkovitz on the SER Environmental Report

Version: May 2010-05-21

Introduction The Consortium thanks Mr. Kenneth Levkovitz for the comments provided on the SER Report. The Consortium understands that Mr. Kenneth Levkovitz is an important stakeholder for this project and therefore his participation in the public consultation process is much appreciated.

Please refer to the paragraphs below for our clarification notes on the outlined comments in the public consultation statement received.

Clarification Notes

New Europe Corporate Advisory, Ltd.General Comments

The map of Bulgaria in Figure 11 speaks volumes: one can develop wind power in a very limited set of valleys where in fact there is no wind resource. Everywhere that has a remotely adequate wind resource is going to require an EIA of the highest stringency.

Consortium Clarification Note 1

It is the Consortium’s opinion that investors should study case-by-case the areas subject to wind power development and ensure that wind power development is technically, economically and environmentally viable. The objective of this project is not to define or prohibit development areas. The map cannot be used without taking into account the content of the report. Furthermore, the map is meant as a policy development tool, it is not the product of nation-wide Environmental Impact Assessment. The sensitivity classification is provisional and indicative and should be confirmed by the Authorities with the input of relevant stakeholders. The map cannot be used to take final decisions on specific wind power projects before conducting a proper EIA assessment. Your result that the vast majority of the territory of Bulgaria constitutes an area of high or medium environmental sensitivity I would say is highly debatable, but you have given 3 working days to prepare for a public comment session on a highly technical 302 page report. This is a mission impossible that does not do justice to Bulgaria’s commitment to the Aarhus Convention on stakeholder consultation in environmental policy-making.


The Consortium was committed to receive input from all stakeholders and the general public on the scope and content of the SER report from November 30th, 2009 to February 8th, 2010, having only 90 days to perform the analysis of the comments, data and information provided. Therefore, it was Consortium’s belief that 30 days of public consultations for the discussion of the draft SER report is an optimal timeframe which allows compliance with project timelines and

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at the same time is still within the lines of international best practices. Additionally, due to project time constraints, consultation period could not be distended. And finally, since this project is not a formal SEA of a plan or program (since there is no official wind development plan) but rather a review which is aiming to inform the policy makers for future policy developments, the project does not have any legal obligations to abide specific periods for public consultations. The Consortium has made its best to engage as much as possible all stakeholders throughout the whole project. You recommend an EIA for every turbine above 100 kW, even in the very few white areas on the map – effectively this means every single commercial turbine, a requirement far exceeding established practice elsewhere in Europe.


The threshold of 100kW is based on a several factors: 1) International experience – there are countries such as Spain and Ireland in which all wind power projects above 100kW undergo EIA; 2) Anticipated legislation changes – it is expected that the new RES law will contain a clear distinction between wind turbines for domestic electricity production, for local industrial production and for commercial electricity production, where 100kW is used as a threshold between the first and second category; and 3) Size of wind turbines - 100kW wind turbines are considered large enough to have considerable impacts on biodiversity. The fact that EIA becomes mandatory, for all the turbines above 100kW, reduces the possibility that current practice is continued, i.e. thousands of wind turbines that have been approved without undergoing EIA. Please consult Section 7.8 of the SER Report. You recommend not to install turbines in places where the swept area of the rotor intersects a road. Since every turbine has a service road leading to it, this recommendation is effectively to have no wind power at all.


This recommendation applies to main roads, highways, not to secondary or access roads especially developed for wind projects. In addition, if icing can occur, this distance should be expanded in order to lower the potential risks to humans and infrastructure. So the first impression I have is that the latest report is a one-sided document written with a clear intent to stop all wind power development in Bulgaria, at untold cost for the country in terms of economic development and energy security. Although I cannot attend the public comment session myself, I will make sure that my company, AmCham, and the wind industry in general are fully represented – we cannot let this go without comment.


Wind energy stakeholders were engaged in the preliminary stages of this project, as well as all other stakeholders, identified in the Public Consultation and Disclosure Plan.

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The following consultation meetings with wind energy industry, additional to the formal consultation process, were held:

Meeting 4

Date January 11th, 2010

Location Sofia

Participating Stakeholders Kalina Trifonova - Member of the Management Board of Directors at EVN Bulgaria

Participating Team Members

Manuel Clar– Manager of pm&E;

Jesus Gimeno – Wind Expert at BEPTE.

Meeting objective Investigate EVN, its current activities and responsibilities and the problems, concerns and proposals of EVN, related to the wise introduction of wind power energy.

Meeting outcome

It was found that the grid must be improved and that wind power needs public investment for the grid update. Direct and indirect connection costs have to be taken into account when connecting wind power and other renewable (currently only direct costs are taken into account). A guarantee or deposit from wind power promoters for connection to the grid should be implemented in order to avoid speculations.

Meeting 6


Location Sofia

Participating Stakeholders Stilyan Burharlarski – Manager of Eolica Bulgaria



Joana Soares – Environmental Consultant at ENVIRON Iberia;

Jesus Gimeno – Wind Expert at BEPTE;

Diana Dimitrova – Environmental Consultant at POVVIK;

Irina Mateeva – Biodiversity Consultant to POVVIK;

Svetla Traycheva – Head of EIA and EA Department at POVVIK.

Meeting objective Obtain the investor’s point of view on the EIA permitting process as well as on various problems investors come across in Bulgaria when investing in wind power.

Meeting outcome Obtained detailed information about the challenges which EOLICA has faced when obtaining its EIA permit.

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Meeting 7


Location Sofia

Participating Stakeholders Marin Botsov – Head of GIS Department at CEZ Razpredelenie








Meeting objective Discuss the technical challenges related to connection of wind turbines to the electrical grid.

Meeting outcome Meeting objectives achieved.

Meeting 9


Location Sofia

Participating Stakeholders Velizar Kiryakov – President of Association of Producers of Ecological Energy







Bilyana Petrova – Manager of REA EOOD;


Meeting objective Obtain the investor’s prospective on the challenges facing the investors in wind power in Bulgaria.

Meeting outcome Provided information on the changes of the RES law which the business is proposing.

Meeting 10


Location Sofia

Participating Stakeholders Georgi Georgiev – Member of the Board of Directors of the National Union of the Independent Energy Producers

Participating Team Manuel Clar– Manager of pm&E;

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Members Joana Soares – Environmental Consultant at ENVIRON Iberia;







Meeting outcome Meeting objective achieved.

Meeting 11


Location Sofia

Participating Stakeholders Teodor Bobochikov – General Manager of AES Geo Energy Ltd.

Dimitar Hristov – General Manager of Geo Power Renewable Energy











Additionally, the Consortium has tried to meet with representatives of EON, but due to their unavailability, meetings were not held.

I must say also that the very concept is flawed – that ministerial technocrats should use maps such as the ones you have produced to determine where private investment should or should not take place. This puts us back to the planned economy. Practice from Germany, Turkey, and other countries have shown that such maps do not work in practice. There are simply not enough financial and human resources available for government to do a job that properly belongs in the hands of private project developers. Your report points out in numerous places the limitations of the available data, and often the lack

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of such data. It is those limitations that make such centralized decision-making an impossible task.


As previously mentioned, it´s not this project aim to define or prohibit development areas. The project recommends that detailed EIA’s should be performed for wind power projects, where the specifics of the recommendations depend on the sensitivity of the area. The EIA will indicate whether wind power development in the provisionally selected area is possible from an environmental point of view. Therefore, it is not expected that the authorities will accept or prohibit the installation of wind turbines only on the bases of the produced map – they will review the EIA and draw their conclusions accordingly. Having said that, this report has compiled a vast amount of data on environmental constraints – data which previously was available at various organizations, often not easily obtainable. Thus, it is Consortium’s strong believe that while this project cannot substitute the EIA of a particular project, it can provide ample information to both the investors and the competent authorities in the preparation and the evaluation of the EIA reports.

Despite my deep concern about the substance of the report, its premises, and its implications, I am very grateful for the opportunity to provide input and feedback, even at short notice. And despite the many questions raised, you have assembled a wealth of information in quite a short time, so I must commend you for the obviously tremendous efforts put into shedding light on this highly important topic.


The Consortium thanks Mr. Levkovitz for these words of appreciation for the Consortium’s efforts in this project.


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Appendix H2: Clarification notes on the statement received by N-Vision on the SER Environmental Report

Clarification Notes to the comments received by

Maria Mihaleva (attorney at law) and Sebastian Noethlichs

On behalf of:


Prepared by:


Date: June 2010


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1 Acknowledgements 9

2 INTRODUCTION 9

3 SECTION 1 19

4 SECTION 2 21

5 SECTION 3 24

6 SECTION 4 28

7 SECTION 5 31

8 SECTION 6 38

9 SECTION 7 48

10 SECTION 8 64

11 SECTION 9 70

12 ANNEX D 73

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Clarification Notes on the comments received by Maria Mihaleva (attorney at law), Sebastian Noethlichs on the SER Environmental Report


Introduction Through the whole project, the Consortium has welcomed comments, statements and recommendations by all stakeholders and has made its best to incorporate them appropriately. The consultation process for the draft SER report is an important stage of the project and we are glad to have received statements by various stakeholders.

The level of detail of the statement submitted by N-Vision shows that the report has been reviewed in a detailed way, which is appreciated by the Consortium. However, we note that in the statement the same criticism, often not supported with data, was repeated multiple times, and that single words, phrases or sentences were in occasions taken out of the context of the paragraph, in which they appear in the report.

While the Consortium believes that the submitted statement was quite unconstructive we have endeavoured to provide a comprehensive reply that addresses the issues raised by N-Vision. We trust that this will contribute to clarify some of the misinterpretations of the report, and we are thankful for the attention N-Vision has given to the project and for the identification of the few wording inconsistencies which we have corrected.

N‐Vision General Comments

Considering that most of these general comments are repeated multiple times in the page-by-page review of the report, to avoid duplication they have been answered only in the page-by-page review section. The comments which appear only in this section are addressed.

Balance of Information, Data Sources, Stakeholder Consultations

The report has generally failed to strike a balance in the information that it uses the

source of the data that it uses and the stakeholders that were consulted. From the

report a clear bias in favour of environmental protection NGOs, first and foremost bird

and bat protection NGOs, is apparent. The weight both in terms of the detailed

attention they received, the weight by which their input is represented in the report

and the weight attached to the corresponding objectives appears unfounded. This

makes the conclusions and recommendations as well as the entirety of the report one‐

sided and special interest driven.


This paragraph has been addressed in detail in the comments to the page-by-page review. Please see specifically Consortium Clarification Note 15 below.

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As can be seen from the table below the relative importance attached to the “flora,

fauna and biodiversity” section outweighs all other negative receptors in extent (items)

and weight (items & score). This appears arbitrary and subjective.

The report lists a total of 60 sources in the annex (excluding those sources that are

listed as not (yet) obtained). Of those sources 95 % (57 of 60) are sources for flora,

fauna and biodiversity. Of these 57 sources 44 are concerned with birds and bats only.

This amounts to 73 % of all data sources of the report. In contrast to this three

objectives go without data source while the remaining three all go with a single data

source. From this it appears that no effort was made to strike a balance in the focus of

the report, whatsoever.

Objective Items Total Score Average Score

Weight by items Even weight Sources in

Annex

Energy, Climate, Air Quality

4 70 17.5 17.4% 14.3% 0

Cultural Heritage 1 ‐3 ‐3 4.3% 14.3% 1 Flora, Fauna, Biodiversity

5 ‐63 ‐12.6 21.7% 14.3% 57

Soil, Water 4 ‐6 ‐1.5 17.4% 14.3% 1 Landscape 2 ‐24 ‐12 8.7% 14.3% 0

Public Health, Noise, Vibration

2 ‐2 ‐1 8.7% 14.3% 0

Socio‐Economic, Material Assets

5 3 0.6 21.7% 14.3% 1

Total: 23 ‐25 ‐12.0 100.0% 100.0% 60

Given the repeated reference to their inability to obtain data sets concerning other

objectives from the relevant authorities, it stands to reasons that the authors have

thus allocated an undue and excessive amount of attention and importance to the

single objective for which vast data was readily available.

In summary, given the relative weight and focus that the different objectives of the

report received, the report does not amount to a strategic environmental review, it

merely qualifies as an extensive though not necessarily verified study of birds and

their potential though not necessarily verified sensitivities to wind power

development.


The Consortium has actively and insistently tried to obtain relevant environmental information from multiple entities and data sources, and in fact a huge volume of data and information was received. It is fortunate that a large data set was available regarding flora, fauna and biodiversity, which allowed us to assess potential impacts on these evidently vulnerable

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receptors. However, the Consortium cannot be held responsible for existing data gaps, nor was it within the scope of the project to perform additional research to fill these gaps.

Furthermore, it is noted that some SER Objectives are not suitable for spatial analyses. Finally, regarding the issue of scoring, please review Consortium Clarification Note 57 and 126.

Evaluation at the local level

While the effort made by the authors is commendable, the report itself repeatedly

states that an effective addressing of the topic, namely the development of wind

power and its impact, cannot be made at the national level. Instead, the report states,

that this needs to be done at a local, case by case level. This appears to be the only

sensible approach. Case by case environmental impact assessments, including where

necessary bird monitoring, are the only adequate method to ensure the sustained

future development of wind power in harmony with the interest of all stakeholders. In

light of this the report including its conclusions, recommendations and GIS cannot be

used as a decision making or strategy development tool. To do so would be

dangerously in ignorance of the insufficient data and flawed balance of the report.


As part of this report, the Consortium has:

1) provided an assessment of the potential impacts of wind power on the environmental and social component;

2) compiled a large database with all environmental and social constrains and provided a spatial representation of these constraints; and

3) provided general recommendations for the more sustainable wind power development. All these “assets” of the report are done for the whole country of Bulgaria and are generally valid, regardless of the specific site locations of the wind projects.

In this regard, the SER report indeed can serve as a strategy development tool. What the SER report cannot do is to substitute the EIA process, and this has been stated in the report multiple times. Because of that, the SER report includes specific recommendations for the EIA process.

This issue has been addressed in various forms in the comments to the page-by-page review.

Resolution

The maps (data) are provided in inadequate resolution. Higher resolution maps (data)

are not available. The ministries have not been provided with higher resolution maps

(data) either. This means an informed appraisal of the conclusions of the report (the

maps) is not possible. The maps were intended to be used as a decision making tool by

state authorities. For this purpose the maps are not detailed enough.

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Maps are included in the SER report only with graphic purposes – to show the results of the performed spatial analysis.

Maps in any scale can be produced from the large data set with environmental and social constraints which has been compiled as part of this project. However, it will be up to the MEET and the MOEW how they would use the dataset and if and how they will provide the stakeholders with better access to the results of the spatial analysis performed in the SER (maps with better resolution).

No information on degree of certainty of data

The report identifies numerous areas where the baseline review relies on non‐verified,

non‐cross checked or other data with a low or unknown degree of certainty. The

report should contain a visual representation that identifies the level of certainty of

the findings of the report. This should be done in a map that shades the results of the

spatial constraint map according to their certainty. Without this users of the map have

no way of identifying the solidity of the basis they use for decision making.


Each data set used for the spatial constraints analysis is attributed a particular level of sensitivity. One of the factors determining the attributed level of sensitivity is the resolution and certainly of the data. When all other factor are equal, data sets with lower resolution and/or lower certainty are attributed lower level of sensitivity.

Recommendation

‐ A balance of negative and positive receptors/indicators should be struck in terms of

number and detail of sources as well as representation and weight in the report


Addressed above, as well as in the comments to the page-by-page review below.

‐ Those relevant stakeholders that have not been consulted thus far should be

consulted


All relevant stakeholders have been consulted. Please review the PCDP report, as well as Annex 1 to the Final SER Scoping report.

‐ The data sets listed as unavailable or not yet received should be obtained or replaced

appropriately

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This is also the recommendation of the Consortium. The Consortium has made all possible efforts to obtain all relevant spatial data but some data sets have not been provided during the project duration.

‐ Detailed data on the wind potential at adequate resolution should be gathered


This is also a recommendation of the Consortium.

‐ All available information from stakeholders, such as bird studies from developers,

should be gathered and included in the report


All available scientific information regarding the environmental and social constraints has been collected. It is the Consortium’s recommendation that the compiled database should be continuously expanded and all data gaps filled in.

‐ All modelled or approximated data sets should be verified by site surveys


The Consortium welcomes such recommendation, whenever this is possible.

‐ All datasets that are not yet independently verified should be independently verified Consortium Clarification Note 12

The Consortium has recommended that “work groups are established by the MoEW in collaboration with the MEET to review the data base and the sensitivity classification, in order to finalize the basic sensitivity classification of the country with regards to wind power.”

‐ Datasets that cannot be independently verified should be excluded from the report


It should be up to the working groups, mentioned above to decide which data sets to exclude and why.

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‐ Until the above recommendations have been implemented the report should not

be used as a decision making tool or otherwise by any stakeholders


As indicated above, all recommendations made by N-Vision were already addressed in the report

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N‐VISION Clarification Notes

Page-by-page review

1 Acknowledgements Not a single wind energy expert, association or firm appears to have been consulted


The acknowledgements paragraph mentions the contributions from several organizations and institutions that provide data and expert opinions, specifically to the SER Environmental report, on volunteer bases.

As described in the Scoping Report, meetings were held with several wind energy firms and associations in order to receive input regarding the next steps of the project, as well as on the characteristics of the Bulgarian wind sector.

Although data was asked from several wind associations, experts and firms, they have not provided any input similar to the one provided by the experts and associations referred in the acknowledgments paragraph of this report. This fact does not mean that the wind sector was not consulted.

Further, the main focus of the SER Environmental Report was the environmental aspects of wind power development in Bulgaria. Even though the wind energy companies and associations have provided some input on the technical, legal and financial aspects of wind power development, this information is more relevant to the technical guides, which will be issued in June 2010, as part of this project, and not as much to the SER Environmental Report.

And finally, both national and international level wind experts have been hired by the Consortium.

2 INTRODUCTION NON TECHNICAL SUMMARY

page v

par. 4‐5 adequate consultations with the wind energy industry have not taken place


The following consultation meetings with wind energy industry, additional to the formal scoping consultation process, were held in January 2010:

Meeting 4


Location Sofia

Participating Stakeholders Kalina Trifonova - Member of the Management Board of Directors at EVN Bulgaria

Participating Team Members Manuel Clar– Manager of pm&E;

Jesus Gimeno – Wind Expert at BEPTE.

Meeting objective Investigate EVN, its current activities and responsibilities and the

ES11BUL001 10

problems, concerns and proposals of EVN, related to the wise introduction of wind power energy.

Meeting outcome

It was found that the grid must be improved and that wind power needs public investment for the grid update. Direct and indirect connection costs have to be taken into account when connecting wind power and other renewable (currently only direct costs are taken into account). A guarantee or deposit from wind power promoters for connection to the grid should be implemented in order to avoid speculations.

Meeting 6


Location Sofia

Participating Stakeholders Stilyan Burharlarski – Manager of Eolica Bulgaria








Meeting objective Obtain the investor’s point of view on the EIA permitting process as well as on various problems investors come across in Bulgaria when investing in wind power.

Meeting outcome Obtained detailed information about the challenges which EOLICA has faced when obtaining its EIA permit.

Meeting 7


Location Sofia

Participating Stakeholders Marin Botsov – Head of GIS Department at CEZ Razpredelenie








Meeting objective Discuss the technical challenges related to connection of wind turbines to the electrical grid.

Meeting outcome Meeting objectives achieved.

Meeting 9


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Location Sofia

Participating Stakeholders Velizar Kiryakov – President of Association of Producers of Ecological Energy










Meeting outcome Provided information on the changes of the RES law which the business is proposing.

Meeting 10


Location Sofia

Participating Stakeholders Georgi Georgiev – Member of the Board of Directors of the National Union of the Independent Energy Producers











Meeting 11


Location Sofia

Participating Stakeholders Teodor Bobochikov – General Manager of AES Geo Energy Ltd.

Dimitar Hristov – General Manager of Geo Power Renewable Energy






ES11BUL001 12






Additionally, the Consortium has tried to meet with representatives of EON, but due to their unavailability in the week when the additional scoping consultation meetings were held, such meeting did not take place.

par. 6 citing 46 fold increase is meaningless, increase relative to other EU nations is

better alternative (i.e. what was added in Bulgaria compared to other EU nations

relative to the respective market size)


This citation is important to understand the growing importance of wind energy in Bulgaria. The project scope of the work focuses on the Bulgarian territory and is not intended to benchmark EU wind energy production. Further, appropriate EU statistics are provided in Section 2.1 of the report.

page vii bottom

30 day consultation period is not observed. Invitation was sent with 1 week notice and

inadequate time to prepare


Consultation period refers to the entire period; starting from the 14th of May, 2010 until 14th June, 2010 and stakeholders can submit comments and statements throughout the whole period.

In order to obtain as fully as possible the input of all stakeholders and the general public regarding the scope of the project, as well as to gather relevant data, the Consortium has extended the scoping consultation process from one month to more than two months (from November 30th 2009 to 8th February 2010). In the next 90 days the Consortium performed the analysis of the collected data and information and prepared the SER report. A decision was made to extend the scoping/data gathering stage and the analysis/report preparation stages in order to produce a good quality and meaningful project deliverable. As a result the consultation process for the SER report was slightly shortened. However, the Consortium believes that 30 days is sufficient amount of time for an organization that is interested in the topic to provide its feedback.

ES11BUL001 13

page viii

par. 1 there is no topic dealing with technical and economic constraints and feasibility

of wind power projects


European Directive 2001/42/EC, known as the 'Strategic Environmental Assessment' or 'SEA' Directive, requires a formal environmental assessment of certain plans and programmes which are likely to have significant effects on the environment.

Annex I, of the SEA Directive, specifies a broad list of environmental, social and economical topics that should be addressed by each SEA. The following table shows how the Directive required topics have been addressed in this SER process:

Table 1: Coverage of the SEA Topics

SEA Directive Topic Addressed in the SER process

Biodiversity Topic on Fauna, Flora and Biodiversity

Population Topic on Public Health, Noise and Vibration

Topic on Socio-Economic and Material Assets

Human health Topic on Public Health, Noise and Vibration

Fauna and flora Topic on Fauna, Flora and Biodiversity

Soil Topic on Soil and Water

Water Topic on Soil and Water

Air Topic on Energy, Climate and Air Quality

Climatic factors Topic on Energy, Climate and Air Quality

Material assets Topic on Socio-Economic and Material Assets

Cultural heritage, including architectural and archaeological heritage

Topic on Cultural Heritage

Landscape Topic on Landscape

Additionally, specific technical, economic constraints and feasibility of wind power projects will be addressed in the technical guides.

bottom ‐ consultations were not undertaken in relevant areas, not with large scale

investors and relevant and experienced industry associations and firms


Detailed information on the representative areas selection process is provided in a document titled “Selection of Representative Areas to Conduct the Public Consultation Process”, which is

ES11BUL001 14

accompanying the project documentation and can be consulted at project website: www.bgwindenergy.com. The final selection was determined with MEET and the MoEW approval.

Also, please see Consortium Clarification Note 16, which include some of the large investors in wind power who have been consulted individually. Further, please refer to the Annex I of the Final Scoping SER report, as well as Appendix G of the current report for a list of participants in the official consultation meetings, many of who were representatives of various business organizations.

page ix

par. 4 “It is noted that no reliable information was available on wind potential in the

country, and therefore this element could not be incorporated into the data analysis.”

This means:

‐ predictions on page vi are made without base

‐ the map for the agricultural land ban cannot be realized

‐ the potential negative impact of the report on wind power development is unknown


The correct interpretation of this statement is: no data on Bulgaria’s wind potential was used because it was not publically available for the whole country. Consequently:

The predictions on page vi are made using published information from the MEET, as well as the most recent data from the electrical distribution and transmission companies on the installed/operational wind power capacity and wind power capacity for which preliminary contracts have been signed. The lack of country-wide data on wind potential does not imply that no predictions on wind capacity can be made, which are based on information about projects which have been initiated and are in an advanced stage of their development. ‐ A map with the agricultural lands which are proposed to be forbidden for RES development was not created as part of this project because such data was not provided by the Ministry of Agriculture. If this data was provided, it would have been used to generate a layer with agricultural lands 1-4 category because this is one anticipated constraint for wind power development. The lack of a map with the wind potential does not lead to the conclusion that maps with the environmental and social constraints cannot /should not be made. ‐ It has not been one the report objectives to assess the impact of the report on the wind power development in the country. The report, on the other hand addresses the likely effects that wind power development can have on the relevant environmental and social topics and creates a framework for a more sustainable wind power development in Bulgaria.

ES11BUL001 15

par. 5 in light of par. 4 it cannot be possible to understand the likely impact of current

wind power development in Bulgaria as neither potential nor the degree to which

current projects are realizable can be understood


This project assesses the likely effects that wind power development can have on the relevant environmental and social topics, independently of whether there is sufficient wind potential or already installed wind turbines. The aim is to alert developers, investors, authorities and NGO´s of areas where impacts are likely to be greater and even unacceptable and therefore development should be carefully addressed.

page x

2.1‐7.5 what is the scientific basis for this level of significance


The methodology used to define the level of significance for all SER objectives and indicators, is explained in Section 3.3 of this report, specifically in Section 3.3.3. As it is referred in this section, best practice standards were used.

Additionally, it is important to mention that during the scoping stage of the project, the SER objectives and indicators were subject to broad public consultation. During the scoping project stage, several discussions with different experts were conducted and the SER objectives and indicators were refined, as well as their level of significance.

5.2 & 7.3 ascribing major negative impact on the visual value of landscape is subjective. Traditional

wind mills have been parts of the landscape of countries for centuries and they are valued as such.

The valuation of the visual value is up to individual taste. Ascribing negative value here and then

citing ‘no effects’ for tourism is not coherent as tourism is arguably driven by the visual value of the

landscape.


It is possible that large wind farms are seen by the local population as a negative landscape effect and by tourist as a country landmark. Nevertheless, in order to proper address this indicator effects will be considered uncertain. Changes will be made in the Final SER Report accordingly.

Sections 6.1.5 and 6.1.7 of the SER Report justify the approach taken.

page xiii

par. 3 the relative weight of importance of various sensitivities is not clear. i.e. how

important is the protection of birds vs. other animals vs. flora vs. landscape vs. wind

power vs. EU 2020 targets


ES11BUL001 16

Section 6 of the SER Report assesses the significance of the effects and therefore their importance regarding wind power development in Bulgaria. Section 7 and Annex D of the SER report provide detailed information on the reasoning behind the assigned levels of sensitivity. Additionally, the assessment of the significance of the effects of wind power on the respective environmental topic, as well as the determination of the level of sensitivity of the particular area type, are based on expert opinions of Bulgarian scientists and reviewed bibliography.

par. 4 the data for sensitivities was taken from special interest groups. It shows gaps

and it was not cross‐checked or otherwise verified. This makes the data set (maps) a

dangerous ‘special interest product’ without any effort of balance and scientific

verification.

Report recommends that the sensitivity classifications are verified between MoEW and

MEET. This means as it currently stands the report cannot be applied as final.


As it is mentioned in par. 4 of page xiii of the report:

However, it is recognised that many data gaps exist, and that the opinions regarding the sensitivity of specific species and habitats may not be shared among all experts. It was beyond the scope of the current project to perform extensive cross-checking of the received information. Therefore, the Consortium recommends that work groups are established by the MoEW in collaboration with the MEET to review the data base and the sensitivity classification, in order to finalise the basic sensitivity classification of the country with regards to wind power.

Page 79 par.4

It is important to note that although great effort has been invested by the Consortium and the involved stakeholders to compile the best scientific data that is currently available regarding the social and environmental issues that may be affected by wind power development, the currently available dataset will undoubtedly have to be expanded and updated in the future.

Additionally, the interpretation of the data in terms of sensitivity will have to be reviewed periodically, and to perform this task the MoEW may consider to establish workgroups, in collaboration with the MEET, with regional and national experts. The database and its interpretation, as described in this report, are intended to be the starting point for a dynamic policy development program that should safeguard in the best way the interests of Bulgarian society and the country’s natural heritage. In its current state it does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.

ES11BUL001 17

par. 5 Report recommends periodic updating of data set with information from

investors. Yet investors were not consulted in the initial preparation. This is not

coherent and undermines the value and credibility of the report.


As mentioned in Consortium Clarification Notes 15 and 16, investors have been consulted since the beginning of the project. The Consortium has used some information from monitoring of planned or existing wind turbines. However, since this information is property of the individual investors and since the number of investors is huge, more centralized data sources were used, such as BSPB and BAS. The Consortium agrees that if investors have provided data (turbines locations, monitoring results, wind potential, etc.) it would have been beneficial for the whole country and the value of this study would have been further strengthened.

Page xiv ‐ Table

the report affects the entire country. The scheduled meetings are not representative

of this fact. Their local focus is too narrow.


Please see Consortium Clarification Note 20, regarding the selection of the representative areas for the public consultation process.

bottom ‐ The statements regarding rich heritage etc. should be backed by actual,

quantitative and qualitative comparison to other nations. The same should be done to

back the statements on the negative impact of wind power.


The current study refers to Bulgaria, the analysis and comparison with other nations is out of the actual scope of work. Further, Section 5.1.3 (baseline review part) of the current report provides ample quantitative information about the richness of the biodiversity in Bulgaria.

The statement that EIAs for highly sensitive areas are likely to be negative, should be

backed up by data.


This statement is based on the analysis carried out in Section 7 of the SER Report. As stated previously, the analysis is entirely back up by the best scientific data that is currently available regarding the social and environmental issues.

ES11BUL001 18

The report recommends that it after all information is cross checked it should be used

to steer the development of wind energy. Given the prior statements that a)

information on the wind power potential is not available and that b) the data sets exhibit gaps, it is not reasonable to expect that the report can adequately be used to steer the

development of wind power.


The report identifies environmental and social constraints within the territory of Bulgaria, in accordance with the best scientific data that is currently available. If identified gaps are filled in, information is updated and cross-checked, this is a useful tool to steer wind power development in the country. Investors will have the chance to focus on less sensitivity areas, addressing mainly the issues that have been identified, investment can be directed to proper areas, not subject to extra costs or permits deny. Therefore, the identified environmental and social constraints can be used to streamline the process of wind power development.

Page xv ‐ par. 2

That wind potential data needs to be urgently gathered suggests that the report is not

useful until this has been done and incorporated into the report.


The need to gather wind potential data suggests that this data could be matched with the environmental and social constraints, and strategic national decisions could be taken after taking in consideration the country’s capacity to produce energy from wind power facilities. Nevertheless, environmental and social constraints exist and have been identified; these constraints should be taken into account when wind power development is planned. Further, wind potential data exists within the industry sector, although Consortium could not access to these data, wind industry can contrast the report with the existing data.

ES11BUL001 19

3 SECTION 1 Introduction Page 1

Par.1 The statement is unfounded and unqualified. How many MW would have been at

the same pace, how many MW would have been at lower pace? This statement

exhibits bias in the report from the beginning.


This statement is meant to reflect the current situation in regards to wind power development in Bulgaria. Wind power investments in Bulgaria have been increasing in the last decade. Nevertheless, this development has not been properly addressed by the governmental authorities. This cited statement is also based on the fact that currently wind power development in the country has raised several issues and conflicts between ministries, investors, NGO´s and the general public. As a result, the European Commission has opened two infringement procedures against Bulgaria on its systematic failure to protect NATURA 2000 sites from damaging development, including wind power development.

On 27 November 2008 the European Commission opened an infringement procedure against Bulgaria in respect of Kaliakra.

In October 2009, the Commission opened a 'horizontal' infringement against Bulgaria due to a systematic failure to protect its NATURA 2000 sites. Coming under pressure from the EC, the Bulgarian Government contemplated a full moratorium on all wind energy development until a Strategic Environmental Assessment had been carried out of the RES plan, which is currently under preparation.

Page 2

Par. 1 It is not reasonable to expect to understand the potential for impact of wind

power without data for the potential for wind power.


Please see Consortium Clarification Notes 21, 22, 31 and 32

Par. 2 ibid.


Please see Consortium Clarification Notes 21, 22, 31 and 32

ES11BUL001 20

Par. 3 ‘useful basis for future planning and decision‐making’ is incoherent with gaps in

data, non‐verified data and missing wind potential data


As stated, in this report page 79, par.4:

This report is meant to serve as “(…)starting point for a dynamic policy development program that should safeguard in the best way the interests of Bulgarian society and the country’s natural heritage. In its current state it does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.”

Page 3

Objectives the objectives again are not compatible with gaps in the data, non‐verified

data and missing wind potential data


Please see most of the previous comments, as they address this topic. Further, it is important to note that there are almost no cases in policy making when the decision makers have 100% of all data that can be used for the particular decision. Nevertheless, decisions and strategies are made with the best available data – something which this project has also done.

Page 4

Par. 1 wind industry stakeholders were not included in this process. Why?


Wind energy stakeholders were engaged in the preliminary stages of this project, as well as all the identified stakeholders as identified in the Public Consultation and Disclosure Plan. Nevertheless, wind industry will be included in this sentence.

Please also see previous answers on this regard.

Par. 3 the geographical scope of current and future developments cannot be evaluated

without wind potential data and without consultation with the industry stakeholders.

The report is without basis in this respect.


This topic has already been addressed. Please see Consortium Clarification Notes 21, 22, 31 and 32.

ES11BUL001 21

4 SECTION 2 Development of Wind Power in Bulgaria

Page 6

Par. 2 what is the data that was reviewed?


Data from the European Wind Energy Association (EWEA), the United States Agency for International Development (USAID) and the document prepared by Vladislava Georgieva – chief expert in Energy Efficiency and Environmental Protection Directorate, Ministry of Economy and Energy, titled “Wind energy in Bulgaria”.

Par. 3 a division of the country into three zones is oversimplified and of no use for

predicting wind power potential


This is just an approach that has been taken by the MEET. The mentioned publication was the only official publication available on this regard. Further, this statement does not influences the results of this report in any way.

Par. 5 States that wind potential data is inadequate; this means the report is without

scientific basis for its predictions, evaluations and recommendations


Please see Consortium Clarification Notes 21, 22, 31 and 32.

Page 7

Par. 3 The production data is unrealistically low. It represents just above 1000 FLH

whereas > 2000 FLH is typical. The data may be wrong.


Data is based on the MEET Report on achieving the national indicative goals for consumption of electricity generated by RES in 2009 and is the official data on the topic. Additionally, this data has been review by experts at the MEET.

ES11BUL001 22

Page 8

Table The assumption that all preliminary contract projects will go into operation is

unfounded. Experience dictates otherwise. The assumption is technically impossible.

The assumption of 2000 FLH for newly installed capacity is arbitrary and unfounded


Table 3 presents the data provided by three electrical distribution companies and the electricity transmission company and is the most current data, available to the Consortium. Further, local and international wind experts were consulted that the figure of 2000MW capacity being installed in the near future seems reasonable.

The prediction of stable electricity consumption is unfounded and arbitrary.


The assumption is based on several EU predictions that reflect the current market situation due to the world financial crisis. As stated previously, in the report it is clear that this is an assumption based on available information. It has not been the goal of this project to focus on predictions for electricity consumption. The calculations made with the cited assumptions have been used mainly to show the high positive impact of wind power development on achieving the RES target for 2020.

Page 9

Par. 1 the assumption is unfounded, the conclusion meaningless.


Please see Consortium Clarification Notes 44 and 45.

Par. 2 The authors now rely on ‘the wind conditions in Bulgaria’ for their argument

while before this stating that no adequate reliable information on the wind potential

(conditions) is available. This means the argument is without basis. It contradicts the

authors’ prior statements. The statement is thus non‐scientific and meaningless.


Although, reliable quantitative information about wind potential was not identified for this report, it is stated in various sources, that Bulgaria is a country with relatively strong wind power potential. Also, the significant investor’s interest in the country – applications have been received at NEK for thousands of MWs wind power – indicates that these predictions are not unfounded.

The comparison to three out of 27 EU countries is arbitrary and meaningless. Other

countries far exceed the percentage, others are below.

ES11BUL001 23


The current study refers to Bulgaria, the analysis and comparison with other nations is out of the actual scope of work. The referred countries are commonly used as examples on regards to wind power development. This statement is providing a context, so values can be understood and assumptions can be considered realistic.

Par. 3 The authors have made baseless predictions citing wind conditions of which the

authors themselves have said that they are unknown and now these baseless

predictions are used to underpin the importance of a strategy.


Please see Consortium Clarification Note 47. Also, sections 3.1, 3.2 and 3.3 of this report support the cited conclusion.

Page 10

Par. 3 The numbers of EWEA cited here conflict with the statements of the authors

elsewhere that Bulgaria will reach the EU 2020 targets. The discrepancy is not

reconciled.


The cited information from EWEA included in the report is a widely used and included in various reports at the EU level. However, there are other predictions for the development of RES, which differ from the EWEA’s. According to the RES forecast document, developed for the MEET in 2009, if Bulgaria improves its energy efficiency, it can reach 19% of RES from the final gross energy consumption. This last citation is now included in the report.

Page 11

Par. 5 (2.5) what are the current and predicted trends and problems? What is the basis

for their prediction?


Wind power in Bulgaria is expected to increase in the coming years; this statement is based on the reviewed literature and on the data provided by the electricity distribution companies. Please see Figure 1, Figure 2, Table 3 and Table 4, from the report.

The problems related to wind power development were indentified during the project and they range from technical issues (such as lack of grid capacity) to political and social issues (such as the creation of a speculative market for wind projects and the EU infringement processes started because of wind projects).

ES11BUL001 24

5 SECTION 3 SER Approach

Page 14

Bottom How were these topics chosen? Were any other topics rejected?


The topics were chosen based on the SEA Directive as it was explained in the Scoping report of the project. Please also see Comment 5.

Page 15

Par. 4 (3.3) wind developers / the wind industry was not (adequately consulted)


Please see Consortium Clarification Notes 15 and 16.

Page 16

Par. 5 wind data, grid access and other technical data is missing. This means the report

as is, cannot be used as a ‘useful basis for future planning and decision‐making’ (page 2

par. 3).


Please see Consortium Clarification Notes 21, 22, 31 and 32, as well as please review the report in its entirely.

Page 17

Par. 1‐2 predicting the environmental effects and assessing the likely impacts of wind

power development is impossible as wind data, grid access and other technical data is

missing. The predictions and recommendations are therefore unfounded and

meaningless.


Please see Consortium Clarification Notes 21, 22, 31 and 32, as well as please review the report in its entirely.

ES11BUL001 25

Par. 8 Relying on qualitative rather than quantitative information makes the report

prone to subjectivity.

Page 20

Par. 3 The statement is not quantified, it is not founded and it is biased.


As mention in the SER Report (page 14), “the following legislation and guidance documents have been used to structure and guide the SER:

• Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment;

• Protocol on SEA – Resource Manual to Support Application of the UNECE Protocol on Strategic Environmental Assessment, (UNECE et al, 2006);

• Applying SEA Good Practice Guidance for Development Co-Operation, (OECD, 2006);

• Strategic Environmental Assessment Good Practices Guide - methodological guidance, (APA – IST, 2007) Portugal;

• Manual for Environmental Assessment of Plans and Programmes in Bulgaria, (POVVIK-OOS et al, 2002), Bulgaria.”

This project is intended to be a strategic environmental review and not a Bulgaria national wide wind power environmental impact assessment. To avoid subjectivity, the Consortium has conducted workshops and meetings with multiple experts on most of the environmental topic. Many of the consulted experts are currently participating or have previously participated in EIAs of wind power projects, thus they are well familiar with the topic.

Page 22

Table 12 The scoring and the multiplying by values other than probabilities (i.e. 5, 3 or

1 instead of 0.9, 0.7 or 0.25) leads to an arbitrary distortion and overweighing of high

characteristic, high probability effects.

How where the scoring values of 1, 3 and 5 chosen? Why not 1, 2 and 3 or 0, 5 and 10?


As mentioned in the SER Report (page 20):

“It should be noted that the potential exists that such simplified scoring system may mask individual effects which might be significant even when considered in isolation. Therefore this scoring system was used primarily to provide a summary of the assessment outputs and the obtained scores be considered in conjunction with the more detailed assessment outputs.”

The described methodology was based on experience of the Consortium and on reviewed bibliography.

ES11BUL001 26

Page 23

Par. 1 what wind experts were consulted?


As previously mention, the Consortium has consulted with international wind experts and local Bulgarian wind experts, namely with BEPTE, S.L. a Spanish consultant firm, member of the Consortium, and with Ms. Byliana Petrova, hired as an independent local consultant of this project. Further, as mentioned earlier, multiple representatives of the Bulgarian wind sector were consulted as part of the official scoring process, as well as afterwards (see Comments 1 and 2).

Par. 3 elsewhere the authors’ have set out why the report cannot be used to ‘facilitate

the development of wind power in Bulgaria’. Namely, because the relevant data is

missing.


In the Report is not stated that this project cannot facilitate the development of wind power in Bulgaria, it is stated that:

Page 79 par.4

“It is important to note that although great effort has been invested by the Consortium and the involved stakeholders to compile the best scientific data that is currently available regarding the social and environmental issues that may be affected by wind power development, the currently available dataset will undoubtedly have to be expanded and updated in the future.

Additionally, the interpretation of the data in terms of sensitivity will have to be reviewed periodically, and to perform this task the MoEW may consider to establish workgroups, in collaboration with the MEET, with regional and national experts. The database and its interpretation, as described in this report, are intended to be the starting point for a dynamic policy development program that should safeguard in the best way the interests of Bulgarian society and the country’s natural heritage. In its current state it does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.”

This project is providing a framework for a more sustainable wind power development in Bulagria.

Bullet Point 3 data gaps identified again


Statement is coherent with the previously stated. Data gaps exist, were identified and therefore the report “does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.” However, as stated previously, the presence of data gaps does not diminish the value of the report and its finding.

ES11BUL001 27

Bullet Point 4 How did the report determine who qualifies as an expert? How was

expert status verified? Who were the experts? The authors’ say this is ‘often the best

way…’. How often? How accurate are the predictions on average? How much of the

judgment was backed up by evidence?


The members of the Consortium are well known and well recognized companies in the environmental consultancy field, not only at the local level, but also worldwide. The competence of the Consortium was confirmed by the MEET and the EBRD when the Consortium was selected to perform the project.

ES11BUL001 28

6 SECTION 4 SER Consultation

Page 25

Par. 2 Representative areas (Burgas, Momtchilgrad) were chosen on ‘wind potential’

and ‘future wind energy developments’. This is impossible as the authors’ repeatedly

state that data on the wind potential does not exist.


The report states that reliable and quantitative data on wind potential does not exist and was not used for the assessment of the potential effects.

Detailed information on the representative areas selection process is provided in a document titled “Selection of Representative Areas to Conduct the Public Consultation Process”, which is accompanying the project documentation and can be consulted at project website: www.bgwindenergy.com.

Page 26

Par. 1 This statement is non‐scientific. It’s biased in favour of bird protection. Quantify

great. Quantify ‘one of the few’. And do a quantitative comparison of the respective

bird populations.


The imperial eagle is one of the most rare birds in Bulgaria and is a globally threatened bird species. According to the new edition of the Red Book, the imperial eagle is critically endangered (CR) in Bulgaria, with only 25-30 couples left.

Par. 2 The information given here is non‐scientific. It is hearsay and speculative. A bird

expert should know whether something is a feeding ground, a nesting ground or both

for a bird. If an expert does not know this, they are arguably not an expert.


The region of Krumovgrad-Momchilgrad is feeding ground of some of the mentioned species and nesting ground for others. The aim of these paragraphs is simply to summarize some of the issues that were considered as relevant in these areas not to provide detailed information on the issues. Section 5, Section 7 and Annex D of the SER Report contain very detailed and specific information about these particular and many other bird species.

We have seen professional wind data from the area. The economic development of

wind energy in this area, while locals may talk about it, is not possible.

ES11BUL001 29


The Consortium has not have access to professional wind data - only to publicly available information. In this regard, the Consortium can not confirm or reject claims which are made in the publically available information.

Par. 3 Of what relevance are tensions between developers and NGOs? Why is this

mentioned in the report?


The SER project aims to provide the framework for a more sustainable wind power development in Bulgaria. In this regard, existing conflicts between wind power development and other activities in the country are very relevant to assess.


Par. 3 and 4 The statements are not quantified. Define ‘significant importance for bird

protection’. Also define ‘many endangered bird species’. Are 5 many? 50? 500? These

paragraphs are colloquial, biased and unfounded


The aim of these paragraphs is simply to summarize some of the issues that were considered as relevant in these areas. In Section 5, Section 7 and Annex D of the SER Report, where this issue is addressed, more specific information can be found.

Page 27

Par. 1 What about other areas of the country all of which are affected by this report?



Page 29

ES11BUL001 30

Par. 7 guidelines for the future wind power development would need information

about the wind potential. This does not exist, hence there should be no guidelines

derived from this report.


As mentioned in this SER Report, page 2,”two further key outputs of this SER process which will be informed by the outputs of the SER include:

Guide on Streamlining wind power project appraisal and environmental permitting process in Bulgaria:

- A Guidance Note on this subject is currently being developed. It is intended to make recommendations on how the wind power projects appraisal process and the environmental and administrative permitting process can be streamlined. (…)

Best Practice Guide for wind power investors in Bulgaria:

- (…)The objective of this guide is to provide a step by step explanation of wind power planning and development in Bulgaria taking into consideration technical, economic, financial, environmental and social issues related to wind power implementation in the country which will provide information for wind power investors on potential risks and constraints to development and assist then in aligning with regional and national plans for development. (…)”

These guides are based on general information about wind power development in Bulgaria, as well as on international best practices. They will be applicable and relevant, regardless of the presence or absence of quantitative data about wind power potential.

Page 30

Table 2 Other stakeholders should be included in the final discussion.


All relevant stakeholders were engaged at all important stages of the project. The second table on p. 30 refers to final project presentation between the Consortium, the beneficiary and the financial institution that overseen the project.

This project will be completed at the end of June and no further consultations are envisioned as part of the project. It will be up to MEET to further discuss at additional consultation meetings the project results with the stakeholders. Such discussions may be appropriate for the development of the Bulgarian National RES Action Plan.

ES11BUL001 31

7 SECTION 5 Policy Context and Baseline Review

Page 33

Point 11 Quantification? Basis? How can this statement be made without data on the

wind potential?


This conclusion is stated in many of the reviewed bibliography. Further, the strong investor’s interest, exhibited through the large number of initiated wind projects, also provides an indication.

Page 35

Point 5 What is the distance? What dimensions of WTG are the underlying

assumption?


All cultural heritage properties, inscribed on the World Heritage List, have delineated boundaries, buffer zones and protective prescriptions. Information about the seven (7) World Cultural heritage properties in Bulgaria was obtained from the UNESCO website. These sites have been mapped and included in the spatial analysis (Section 7).

The WTG dimensions are not relevant. The cited excerpt refers to the reviewed bibliography regarding recommendations about the distances between cultural heritage properties and industrial activities.

Page 40

Point 3 Statement is not quantified


Detailed information is referred in Topic Paper 3.

As described within Section 3.2 Stage A: Scoping and SER objectives of the SER Report, a topic-based approach for gathering information and identifying sustainability issues has been used to establish the baseline for this SER. The 7 developed Topic Papers with detailed information on regards to information sources are accompanying the project documentation and can be consulted at project website: www.bgwindenergy.com.

Point 8 Authors’ state that reliable distribution maps for invertebrates, amphibians and

small mammals exist. This makes the sensitivity maps guess‐work.


ES11BUL001 32

The maps are based on the best available scientific data that is currently available regarding the social and environmental issues. Further, according to the available scientific studies on the effects of wind power development on the fauna, invertebrates, amphibians and small mammals are not as vulnerable to wind turbines as birds, bats and larger mammals are.

Point 10 How were these species identified?


Please see Consortium Clarification Note 73

Page 41 The detail of bird migration, breeding and wintering data appears to far

outweigh any other data included in the baseline review in extent and detail.


The level of detail is in accordance with the available information, subject to review, as well as with the determined vulnerability to wind power development.

Page 42

Point 4 Which SPAs were included in the baseline review? The 22 or all 95 or 114? Why

is the word “only” used here? In a neutral review this word should not appear here. It

appears as if the baseline review is questioning the decisions of the government as to

which SPAs included specific restrictions for wind power and which don’t.


All the SPA´s were included in the baseline review. The word only is used, since it represents less than 20%. In any case, the word only can mislead to interpretation and will be taken from the final version of the SER report.

Point 9 What recommendations were these? Who provided them?


Please see Appendix F of the SER Report for detailed information.

Point 14 Does this mean that the data has a resolution of 10 x 10 km at its best?


The distribution maps of breeding birds of prey in Bulgaria, taken from the Bulgarian Breeding Birds atlas and used in the spatial analysis have one of the lowest resolutions among all spatial data sets. The resolution of each particular dataset is reflected in its assigned level of sensitivity (when all other factors are equal, data sets with lower resolution are assigned lower sensitivity level).

ES11BUL001 33

Point 15 How is a species identified as ‘vulnerable to wind farms’? Who identified

them as such? How was this verified? How is the practice in other EU nations? What

data is available?


This issue is discussed in detail in Section 6.1.3 and Section 7.3.4 of the SER Report.

Page 43

Points 7‐9 Non of the statements are quantified. These are opinions.


This is part of the identification of SER Objectives and indicators based on the baseline reviewed information. Detailed information is referred in Topic Paper 3.


Page 45

Point 7 Quantify ‘considerable’. This is an opinion.

All points How does this data bear relevance to the development of wind power?


This is part of the identification of SER Objectives and indicators based on the baseline reviewed information. Detailed information is referred in Topic Paper 4. Also, please see Consortium Clarification Note 81.

Page 46

Points 1‐5 How does this bear relevance to the development of wind power?


Please see Consortium Clarification Note 82.

ES11BUL001 34

Point 6 Does this mean the creation of dust by construction vehicles?


This statement means that if wind power foundations are constructed in contaminated areas, contaminants can be mobilized to other non-contaminated areas and cause environmental impacts.

Page 47

Point 8 What studies? How were they verified and cross‐checked?

Points 9‐12 How was the visual impact evaluated?

All points How does this data bear relevance to the development of wind power?


This is part of the identification of SER Objectives and indicators based on the baseline reviewed information. Detailed information is referred in Topic Paper 5.


Page 48

Point 11 Detailed, 3rd party verified data on environmental noise levels for all relevant

wind turbines is readily available from the manufacturers. Was this reviewed? If not,

why was it not reviewed?


This environmental noise levels refer to noise levels around settlements and it is used to understand if local populations are being affected by any noise levels.

Point 13 What is the ‘optimal’ distance?


The original aim of the Consortium was to try to define an optional distance which can be used as a general guidance in future projects. However, after reviewing numerous studies and consulting with experts on the topic, it was found that such distance cannot be defined and it should be determined case by case.

ES11BUL001 35

Page 50

Point 9 Does this mean no ‘sensitive areas’ with respect to tourism and recreation

have been included in the report?


This means that the effects of wind power development on tourism and recreation in Bulgaria have not been identified within the reviewed information. Furthermore, as explained in Section 7.3.8, no sensitive areas have been included in the spatial constraints analysis due to the lack of specific GIS information on the topic.

Point 10 Quantify ‘substantial’. This is an opinion.


Detailed information is referred in Topic Paper 7.


In any case, the word ´substantial` can mislead the interpretation, so will be taken out from the final version of the SER report.

Point 14 Have areas of ‘positive sensitivity’ with regard to this point been identified?

Point 15 What data was used? How was it cross‐checked and verified? Have areas of

‘positive sensitivity’ with regard to this point been identified?


As explained in Section 7.3.8 no sensitive areas have been included in the spatial constraints analysis due to the lack of specific GIS information on the topic.

Page 51

All points Are these effects positive or negative? Have areas of ‘positive sensitivity’

with regard to this point been identified? How were effects on wind power

infrastructure identified?



Further, this is part of the identification of SER Objectives and indicators based on the baseline reviewed information. Detailed information is referred in Topic Paper 7.

As described within Section 3.2 Stage A: Scoping and SER objectives of the SER Report, a topic-based approach for gathering information and identifying sustainability issues has been

ES11BUL001 36

used to establish the baseline for this SER. The 7 developed Topic Papers with detailed information on regards to information sources are accompanying the project documentation and can be consulted at project website: www.bgwindenergy.com.

And finally, the assessment of the effects of wind power development on the SER topics is outlined in Section 6 of the report – in this case – Section 6.1.7, as well as in Annex B.

Page 52‐54

Section 3 How are these indicators / receptors quantified? They appear to be

recommendations rather than quantifiable indicators useable for a balanced /

scientific evaluation.



Also, please, review carefully the text at the beginning of Section 5.2. of the report.

Furthermore, the establishment of SER objectives and indicators are discussed in more detail in the Final Scoping Report which also can be consulted at project website: www.bgwindenergy.com.

Page 54

Sections 4‐5 The receptors / indicators imply a negative impact of wind power on all

receptors and indicators. This is one sided. It leaves out positive contributions of wind

power. It would appear that ‘positive sensitivities ‘ have not been identified.


The aim of SER indicators and objectives are not to be positive or negative. Please review carefully the text at the beginning of Section 5.2. of the report, as well as the Final Scoping Report in order to understand SER objectives and indicators reasoning.

Section 5.2.2 Who says that wind turbines lead to a loss in aesthetic value of

landscape? What about added value?


As mentioned in the report page 54, “the landscape objectives and indicators have been provided by Ms. Svetla Bratanova from the Central Laboratory for General Ecology at the Bulgarian Academy of Sciences (BAS)”. Ms, Bratanova is a licensed landscape expert. Also, the actual assessment of the effect of wind power on the landscape objectives is outlined in Section 6.1.5 of the SER report.

ES11BUL001 37

Page 55

Section 7.1 What about positive impact on real estate values?


The aim of SER indicators and objectives are not to be positive or negative. Please review Final Scoping Report in order to understand SER objectives and indicators reasoning. Also, the actual assessment of the effect of wind power on the socio-economic aspects and material assets is outlined in Section 6.1.7 of the SER report.

Section 7.3 The report said prior to this that the impact on tourism was not

considered. Now it is being considered. Which of the two is it? If it was considered,

how was this done? How was the impact qualified and quantified?


The report says that the effects of wind power development on tourism and recreation in Bulgaria have not been identified within the reviewed information. Nevertheless, the potential impact on other sectors (conventional tourism, hunting, eco-tourism, etc.) was assessed with the conditions referred in Section 6.1.7 of the SER Report, where it is mentioned that, due to the lack of information, no formal assessment was conducted.

Section 7.4 How was this qualified and quantified?


The assessment process is explained in Section 6.1.7 of the SER Report.

ES11BUL001 38

8 SECTION 6 Results of the Assessment

Page 56

Par. 1 “Evidence based” and “peer reviewed” appears to be in conflict with earlier

statements that information was neither cross‐checked nor verified and that ‘expert

testimony’ was essentially accepted at face value.


The assessment is presented as evidence base discussion whenever it was possible to find literature, information, studies, analysis, etc. Additionally, expert judgment was also taken into account, wherever appropriate.

Page 57

Par. 1 What is this expectation based on? How can the report have an expectation

when data on the wind potential has not been available and was not considered?


The assumption is based on data provided by the MEET, by the electricity distribution and transmission companies and takes into account the currently available information.

Taking into account that MEET is using these figures to justify EU targets, it is the Consortium’s belief that figures are appropriate to be used as an indication of the wind power potential in the country.

What is the probability level in %?


According to the methodology explained in Section 3.3.3 of the SER Report, probability is high, above 90%.

Par. 2 ibid.

Page 58

Par. 1 ibid.



Par. 2 Since all individual impacts are positive the cumulative impact is not ‘likely’ but

‘certain’ to have a positive impact.

ES11BUL001 39

Par. 3 & Table If even data on the location was not available for all sites, how does the

report arrive at a 50 – 90 % probability of an impact on these sites?

Since the impact (or lack thereof) depends on the location of future wind power

developments and since data on wind potential is not available, how did the report

identify the level of probability? This would require an expectation of future

development locations. Such expectations would, however, be without scientific basis

and amount to but opinions and guesswork.


Probability is based on whether an effect will happen. The effects on cultural heritage are assessed as likely to occur and therefore the level of probability is medium because of the expected rapid development of wind power in Bulgaria, as well as because of the large number of national and local cultural heritage properties.

Page 59

Par. 2 The report recommends that the impact on heritage sites should be considered

at the local level as it is location specific and cannot be conducted at the national level.

This means no respective sensitivity areas should be included in the report.


The sensitivity areas included in the report are based on world cultural heritage site locations, which are available. No assumptions were made regarding national and regional cultural heritage properties.

Nevertheless, it is important, as mentioned in the report, that the EIA process for wind power development is carried out sufficiently with relation to potential impacts on cultural heritage, and during the wind power development, all potential impacts should be adequately mitigated.

Par. 4 Does this coincide with actual experience from other EU nations? What has the

impact on flora, fauna and biodiversity been in other EU nations with a larger share of

wind power developed?


The aim of this project is to perform an environmental strategic review in Bulgaria and not to benchmark Bulgaria to other EU countries. Nevertheless, international bibliography, including from other EU countries, has been consulted in order to obtain the best available information.

Table 24 All objectives would require knowledge of the location of future wind power

development. This knowledge does not exist. Hence the probability levels of 50 – 90 %

appear unfounded. Hence, as with heritage sites this should be evaluated at the local

level.

ES11BUL001 40


As previously mentioned SER Objectives were determined in the early stages of the project and are based on expert opinion. SER objectives are defined to characterize the SER process, independently of wind project site locations.

The SER is assessing the probability of the effects in the case that the wind projects are located at a place where the particular environmental constraint is present. Therefore, the current assessment of the probability requires mainly an assessment of the vulnerability of the receptor. Therefore, independently of the site location as long as the receptor is present these effects will likely occur and therefore the level of probability is medium.

A SER is not as detailed as an EIA (Environmental Impact Assessment). This is because a SER is used to assess relatively broad strategies rather than site specific proposals. The purpose of this SER is to identify where environmental effects may occur as a result of the development of wind power in Bulgaria. Therefore, this SER will not highlight detailed site specific impacts. Rather, the SER is aimed at identifying large-scale potential effects on a particular environmental or social aspect – for example, type of community, particular type of environmental designation or a key species or habitat;

Indeed because site location is very important, the Consortium recommends that it is necessary to perform specific EIA in accordance to the sensitivity of an area.

How this matter, being inherently more fluid (birds move, heritage sites don’t!) can be dealt

with at a national level, does not seem congruent with the conclusion regarding heritage sites.


Please see above answer on this regard.

The fact that heritage sites have one score while flora, fauna and biodiversity have five

scores appears to be a random, subjective valuation by the report of the one versus

the other.

How is the potential impact on the latter 21 times (63 vs. 3) more significant than the

potential impact on the former?


The analysis is based on the described methodology explains in Section 3.3.3 and the definition of the attributed scores is explained in detail in Appendix B2 and Appendix B3.

Further, as it is explained in Section 3.3.3 “It should be noted that the potential exists that such simplified scoring system may mask individual effects which might be significant even when considered in isolation. Therefore this scoring system was used primarily to provide a summary of the assessment outputs and the obtained scores be considered in conjunction with the more detailed assessment outputs.”

As mentioned earlier, validation was performed by several international and Bulgarian experts, based on the best available information and when possible as evidence base discussion.

ES11BUL001 41

Page 60

Par. 1 How is it unique? Are there other nations with the same or more?


The scope of this project is the territory of Bulgaria and the project does not aim to perform comparison with other EU countries. Nevertheless international references are made and considered in different parts of this project, where this is found appropriate.

Detailed information on bats can be found in Section 7.3.3 and in Appendix E of the SER Report.

Page 61

Par. 6 ‘Confirmed’ and ‘could’ would appear to be in conflict. The importance of the

parameters and location of the wind power development are highlighted here. This

means without knowledge of the future development of wind power and thus

knowledge of the wind potential, no reasonable estimate of the impact of wind power

on this objective can be formed.


The fact that wind farms have impacts on fauna and flora is confirmed by data and bibliography cited in this report. Nevertheless, as it is mentioned: “(…) the type and scale of impact very much depends on the affected species, their ecology and conservation status, as well as the location, size and design of the wind farm.”

For this reason, the Consortium recommends site specific EIA studies which are to be conducted in accordance with the area sensitivity.

In any case, the expression “could be harmful on” can mislead the interpretation and will be replaced in the final version of the SER report for “have impacts on”.

Footnotes 38‐40 are missing!


Footnotes will be corrected in the final version of SER Report.

Par. 8 The statement is not quantified. Decreasing trends and ‘many’ species are

meaningless to arrive at an informed evaluation.


As previously explained, the SER is not a detailed EIA, as it is performed at the national level. Due to this fact, it is acceptable to make generalizations in certain statements. Nevertheless, this particular statement is based on a publication of Hotker at al. (2005). (Hötker H., Thomsen K.-M. & Köster H. (2005) Auswirkungen regenerativer Energiegewinnung auf die biologische Vielfalt am Beispiel der Vögel und der Fledermäuse – Fakten, Wissenslücken, Anforderungen

ES11BUL001 42

an die Forschung, ornithologische Kriterien zum Ausbau von regenerativen Energiegewinnungsformen. - BfN-Schriften 142, Bonn and Michael Otto-Institut im NABU, Bergenhausen.)

Page 62

Par. 1 Quantify ‘there could be a significant effects’ in terms of likeliness and effect.

This way the statement is non‐scientific and pointless.


The fact that wind farms have impacts on fauna and flora is confirmed by data and bibliography cited in this report. The likely significant effects to the most vulnerable bird species are presented in detail in Appendix D3, based on cited published data. However, a detailed quantification of the expected significant effects is out of this project scope of work.

Nevertheless, as it is mentioned: “(…) the type and scale of impact very much depends on the affected species, their ecology and conservation status, as well as the location, size and design of the wind farm.” For this reason, the Consortium recommends site specific EIA studies which are to be conducted in accordance with the area sensitivity. The spatial constraints analysis proposed in this report can be used as guidance for the assessment of the expected significant impacts.

The term “significant” is used to identify the potentially high level on impact.

Par. 2 Quantify ‘may’. What is the likeliness and what is the likely statistical extent of

this?

The suggestion that studies may be falsified by ‘wind farm wardens’ goes to document

bias and subjectivity on part of the report. If this is an argument to be included in the

report, than the fact that dead birds may be added by bird protection NGOs should be

mentioned as well. This paragraph lacks scientific base and relevance.


This statement is not suggesting that studies have been falsified by wind farms wardens. It is suggesting however that because of predators and regular clearing of the sites around wind turbines by wind farm wardens, it is likely that some of the mortality numbers are lower than the actual ones.

Furthermore, there are no reported cases of NGO´s spreading dead birds in wind farms.

Par. 3 What is the relevance of these studies to Bulgaria?

The cited number of 125 birds is NOT the average for Belgium. It is the most extreme

number cited for all of Belgium. The number is for a few select turbines. Namely:

During previous years, for a few wind turbines at the eastern port breakwater in

Zeebrugge, up to 111 and 125 fatalities were calculated as a result of the correction

ES11BUL001 43

factors for some small birds that were occasionally found (Everaert et al. 2002;

Everaert 2003).

The further numbers are numbers for “Wind turbine locations with relatively large

numbers of protected birds”. This is a distorted portrayal of data. This is not scientific.

It is opinionated and subjective.


The numbers used are referred to particular studies, which have been carried out by scientific experts. These statistics show the scale of the impact on birds when wind turbines are not properly sited. Please see the paragraphs which follow the cited paragraph.

From the text of the report “up to 125 birds collide annually per turbine in Belgium” it is very clear that the maximum number is cited.

The study shows that placement of wind farm within area with big concentration of birds will lead to significant effects. The relevance to Bulgaria is as follows: In Bulgaria there are certain places, especially along the Black Sea coast, along the Danube and several wetlands inland the country, where there are big congregations of waterfowl and migratory species. Having in mind the above study and also the number of other studies, which have been identified, high potential risk for birds is expected in these areas. The Consortium has tried to use the best available data and practice to identify the sensitivity areas in order to prevent big damages to birds. As far as evidence is already available, it is not a good practice to carry out new several-years study to count number of killed birds per turbine.

Page 63

Par. 3 The Barrier Effect has recently been disproved by scientific studies. Migratory

birds avoid arrays of wind turbines on a micro‐location not a macro‐location level. This

means that the added energy expenditure for migratory birds is negligible.

It should be noted that not a single source is stated for this argument. This makes this

effect and an un‐supported hypothesis. Its inclusion in the report makes the report

non‐scientific and its findings ill suited for decision making.


References will be included in the final version of the SER Report. According to the reviewed publications, the Consortium has not found arguments to support the statement cited above, that “The Barrier Effect has recently been disproved by scientific studies. Migratory birds avoid arrays of wind turbines on a micro-location not a macro-location level. This means that the added energy expenditure for migratory birds is negligible.” If the author of the statement is sure about this, it will be helpful to provide concrete publications with concrete arguments that proof the statement. In the long list of the publications reviewed for the purposes of this report, there are no arguments in support of this statement but there are arguments supporting that the barrier effect could be significant for birds, including the increase of energy consumption.

ES11BUL001 44

Page 64

Par. 4 The second part of the argument is made without source and contradicts the

first source. This is not scientific. The 75 % figure or chance of collision is not backed

up. The study by Winkelman (1992) cited earlier puts the risk of collision at between

0.005 % and 0.089 %.


The SER report does not aim to make a critical review of the scientific studies on birds and wind farms, but uses only scientific data and publications to support assumptions made in the report. The numbers used are referred to particular studies, which have been carried out by scientific experts.

Page 65

Par. 2 The cited range of the impact (300 – 800 meters) suggests that the impact of

wind power development is of a limited local range. This undermines the need and

effectiveness of a nationwide strategic approach as attempted here. This is even more

so given the lack of knowledge of wind power potential of the report.


The project aims to provide a spatial representation of the identified environmental and social constraints for which data is available. It is true that most of the effects are local and have range of impact similar to the cited one. However, this by no mean diminishes the usefulness of the strategic national approach because this project is indeed aimed to help the Bulgarian government design a more sustainable wind energy strategy.

The importance of this particular impact on a local level which has reflection on a national level can be illustrated with the Red-breasted Goose. The species concentrate in winter in very specific areas in Bulgaria – mainly in Dobrudzha, and less along the Danube and around Burgas lakes. Even the cited parameters of the impact relatively small and local, the huge development of wind farms in Dobrudzha during the last 4 years will lead in next several years (if all the consented turbines are built) to lost of majority of the foraging areas (even more than 50%) of this globally endangered species in Dobrudzha on a base of the cumulative impact. Similar development of wind farms in Romanian Dobrudzha makes the future of the species even worst. So even the impact could be “small scale on local level”, it could have significant impact on a national level and this is the role of the strategic assessment - to evaluate and predict such impacts which is difficult to assess properly by single EIA for a particular small project. Nevertheless, as it is mentioned multiple times in the SER report, the Consortium recommends that site specific EIA studies are conducted in accordance with area sensitivity.

ES11BUL001 45

Par. 4 The use of the words ‘could’ and ‘may’ does not allow for the conclusion that

‘habitat loss is observed”. This is an opinion. It is not support by the arguments of the

paragraph.


The wording in the text of the final SER report will be changed to “habitat loss could be observed” as it is more accurate.

Page 66

Par. 2 The report cites extreme examples (the most extreme in the world) here. This is

not conducive to a scientific evaluation.


The report uses real examples to explain the reasons why wind power development should be well planned and why environmental consideration should be incorporated at very early stages of the investment process.

Page 70

Par. 1 Can this be expected or IS it expected? How do wind turbines increase soil

erosion?


This effect can be expected - it is a potential effect. It is not a matter of wind turbines in particular, it´s a matter of construction works in soil where the erosion potential might cause some problems, although this impact is evaluated as partial minor negative.

The wording in the text of the final SER report will be changed to “These effects are expected to be long term even though the risk of erosion is increased only during the construction stage of the projects. The spatial rage of these effects is local.” as it is more accurate.

Par. 4 The exact data is publically available from the website of the ministry. The

authors of the report appear to not have researched this topic adequately. According

to the numbers of the ministry of agriculture the amount of category 1 – 4 land

potentially affected by wind power amounts to up to 0.017 %.


As mentioned in the SER Report:

“(…) Based on information, publically available on the website of the Ministry of Agriculture and Food, in 2008, the portion of the country which is occupied by agricultural land is around 51% while the portion of the cultivated agricultural land is around 28% of the country’s territory (3 060 543 ha). It is unclear what portion of this land is within categories 1 to 4, which are considered to be with highest economic value. (…)”

ES11BUL001 46

For the reason mentioned, the magnitude of the effect is considered very low to low.

Page 71

Bottom The report recommends, again, that an objective be taking into consideration

on the local level as it cannot be dealt with at a national level. This, again, shows that

the report cannot serve as a decision making tool at any level.

This further undermines the reports valuation of the impact of wind power on the

landscape as a major negative. If the authors say that the impact cannot be evaluated

at the national level, then how can they assign a value to its impact?


The cited paragraph is referring to the effects on the landscape. The report indeed states that these effects are very much site-specific. However, even though the effects may vary from one location to another, if wind farms are improperly located and their layout is not adequately addressing the local landscape, the effects on the landscape can be significant and negative. If Section 7.3.6 is consulted, it will become apperant that the Consortium recognizes that fact the landscape component is not suitable for nation-wide spatial representation, and as a result, such has not been attempted. On the other hand, many other environmental topics are suitable for nation-wide spatial representation, which can be a valuable tool for the decision-makers.

Page 72

Par. 2 If only 12 % of people have concerns against projects in operation, then this

means that 88 % of people are either indifferent or positively disposed to the projects.

In light of this, this should be a positive rather than a negative receptor.


This is an example was given to show subjectivity of people perception. However, to avoid confusion the example was taken from the final version of the SER Report.

Detailed assessment of these indicators can be consulted at Appendix B6 of the SER Report.

Page 73

Entire page While the conclusion of the authors’ appears correct, there is in fact

significant, detailed, 3rd party verified data on all the concerns listed. This data is

available from turbine manufacturers. Its absence from the report goes to

demonstrate the one‐sidedness and bias of the report.


ES11BUL001 47

The aim of this project is to raise awareness regarding the environmental and social constraints which need to be considered for the correct and sustainable development of wind power in Bulgaria.

Investors, authorities, NGO´s, population, etc. should carefully address these issues so proper development is carried out in the country.

Page 74

Entire Section The positive economic impact of wind power (employment, investment,

tax revenue) are not discussed at all. Its absence from the report goes to demonstrate

the one‐sidedness and bias of the report.


As mentioned in the SER Report,

“(…) The availability of wind power projects related to Socio-Economic and Material Assets data would enable a more detailed assessment of these topics. Even so, it can often be difficult to establish the links between apparently or possibly related phenomena, for example wind power projects and property value. (…)”.

The creation of hundreds of jobs, billions of Euro of investment and millions in tax

revenue is valued at 1. This means the report values the negative impact of wind

power as 63 times worse than the positive impact of wind power on employment and

economy. This seems unbalanced and one‐sided.


The relation between wind power development and the Social-Economics and Material Assets is not a strict line. Nevertheless, it is Consortium recommendation, as mentioned in the SER Report:

“(…) Future related projects can continue with the assessment and monitoring of the effects of wind power development on Socio-Economic and Material Assets in Bulgaria (…)” .

Further, as it was stated previously in there notes and as it is mentioned in Section 3.3.3, the scoring approach has been taken to simplify the comparison of the effects on the different environmental and social topics. The scores of all SER Objectives in each category are not meant to be summed up for many reasons, one of which is the fact that for different topic different number of SER Objectives have been identified.

It is important to mention, that the current project has never indicated that wind energy is not considered to be positive for the country. Rather, the study is meant to contribute to a sustainable development.

ES11BUL001 48

9 SECTION 7 Constraint Analysis

page 76

Par. 1 The introduction claims that “data was formally requested from all relevant

institutions, organizations and individual experts […]”. A review of the list of the data

providers in Appendix D, though, leads to the conclusion that the choice of sources is

one‐sided and the data gaps are considerable to the extent to undermine the

credibility of the provided data altogether.


Please see Consortium Clarification Notes 15 and 16. As previously explained, data was formally requested from all relevant stakeholders. Nevertheless, the ones mentioned in Appendix D, are the ones that provided spatial data. No spatial data from the wind industry was made available for this project.

7.1. Data gathering

The database is allegedly intended to provide MEET with “a solid scientific platform for

development of a defendable and justifiable wind power development strategy”. The

report, however, has failed to achieve this target since the collected database can

neither be deemed to be defendable, nor justifiable as the sources have not been

checked as stated repeatedly in the report.


As previously explained and mentioned in the SER Report:



ES11BUL001 49

Par. 4 The report lacks the objectivity essential for a “solid scientific platform” since

the predominant part of the database is provided by environmental non‐governmental

organizations which have clearly conflict of interest with the other stakeholders in the

renewable energy sector. Meanwhile the report states that the data from the

governmental institutions is not up‐to‐date or verifiable (e.g. “lack of …spatial data on

key matters such as the location of the constructed wind turbines”).


Please see Consortium Clarification Note 128. Also, the fact that a sizable portion of the data has been provided by non-governmental organizations is a function of the data availability in the different organizations. All environmental data used in the SER report has been first requested by the MOEW but the ministry provided only limited information. Further, data has been obtained from respectable NGO’s, many of which are part of EIA studies conducted for and maid by investors in wind power, which is to prove that the industry is also respecting and recognizing the expertise and the professionalism of these NGOs. And as it has been stated many times before, the best available information has been used for each topic.

7.2. Levels of area sensitivity

Par. 1 Since the “available information” is neither sufficient nor complete or justifiable

(see the comments on Appendix D), the grounds of the suggested classification is, at

best, questionable.

Black areas

Justification Unclear, no specific restrictions cited, only general comments without

factual backup. Even though the paragraph is intended to be a summary, instead of

presenting the criteria in brief, it lacks the criteria altogether.

Implications Unclear, general statement


Black areas are defined, in the SER Report, as:

“Areas with explicit legislative prohibition for wind power development”

These areas are not subject to judgment or experts opinion. They are mentioned in the indicated legislation and the designation acts and the MoEW has confirmed the presence of legal prohibitions for them.

Red areas

Justification No justification, only opinion on possible negative impact without grounds

for the conclusion

ES11BUL001 50

Implications Based on the opinion listed above as “justification”. Thus the factual and

scientific basis for the recommendations is unclear and questionable. Also, half of the

main recommendations are redundant since the suggested measures already exist in

the effective Bulgarian legislation.


Red Areas were defined based on experts’ opinion, the existing legislation and the best available data, as previously stated.

“The assigned level of sensitivity is supported by current enacted Bulgarian and EU legislation, as well as by published and non-published scientific information, including data from field studies”.

Red Areas are defined as areas where wind power development is expected to cause significant negative impacts on the identified environmental and/or social aspects. Therefore, it is Consortium opinion that wind power development in these areas should be approached with upmost care.

The suggested measures which already exist in the effective Bulgarian legislation have been mentioned to emphasize their importance and because they are often not properly implemented.

Par. 2 The suggested centralized approach contradicts with one of the key principles of the

Bulgarian Code of Administrative Procedure, namely, that the administration should provide

efficient service and reduce the bureaucratic hurdles to business. Furthermore, no arguments are

provided to justify that forwarding all applications for EIA to the MoEW will improve the quality of

the EIA. Since the MoEW does not have the resources to administer properly the process, the only

viable result of such concentration of authority might be overloading of the administration and

significant delays in processing the applications and conducting the EIA procedures.


Due to the feedback provided during scoping consultation and the additional technical meetings held by the Consortium, it was clear the RIEW´s did not had a clear criteria to define and evaluate the need for EIA. Therefore, it is recommended that in the red areas (areas with high sensitivity to wind power development) a centralized approach is recommended in order to ensure: 1) uniformity in the criteria to the projects, 2) the highest level of public attention and 3) the highest expertise of the experts assessing the EIAs, thus ensuring minimized impacts on the environment. It is expected that such approach may help solve the issues surrounding the EU infringement procedures, filed because of wind power developments in Bulgaria.

Nevertheless, these recommendations are trying to solve specific problems that might have more than one solution. It´s government responsibility to find the most efficient solution to the specific problem.

Page 78

Par. 1 to 3 Redundant. According to the Bulgarian Environmental Protection Act the EIA report is

subject to public discussion whereas the access to the public discussion is not limited i.e. the

ES11BUL001 51

suggested the participation of the “academic institutions, NGOs and other relevant stakeholders” is

already granted by the current legislation. Furthermore, there are no arguments how the proposed

listing of the stakeholders will serve to improve the EIA procedure.


According art. 9 par. 1 of the Bulgarian Regulation on the terms and procedure for conducting EIA, based on the complexity and specify of the project, the investor determines the competent authorities which should be consulted as part of the EIA procedure. There is no particular requirement that interested academic institutions, NGOs and other organizations are invited to participate in the EIA process. During the scoping stage of the SER project, stakeholders from Burgas and Momchilgrad have indicated that often few of the local public interest groups (NGOs) are informed in time and that sometimes the affected population finds out about the project only after the wind turbines start to be erected. Further, according to art. 9, par. 3, the investor is provided with a wide variety of choices for the conduct of the consultations, including the newspaper ads, posters, etc. Some of these information vehicles are not very effective in informing the affected population about the investment project and do not provide sufficient information to the general public. Because of that, the SER report recommends the conduct of meetings with the interested stakeholders, where all relative stakeholders are invited. Such meetings will provide a venue for sharing and discussing the different views on each topics and will help to better inform the affected communities about the risks and advantages of the proposed projects.

Par. 4 Redundant. The MoEW has already issued instructions to the RIEWs (in February

2010, available on the website of the Ministry). Also, the requirement exists in the

effective legislation.


Although the assessment of cumulative effects is required under the current legislation, the practice shows that cumulative effects have not been properly been taken into consideration in the wind power development in Bulgaria, which is evident by the two EU infringement procedures, as well as by the two Bern recommendations. Please also see the maps and text of the amended Section 7.8 of the SER report. Because of that, the SER report emphasizes the need to systematically assess cumulative effects.

Par. 5 No arguments are provided as to why the suggested “comprehensive inventory”

is necessary.


The arguments on the suggested comprehensive inventory are based on the consulted bibliography. Also, as mentioned after all the areas definition, in the SER Report: “Details on the proposed additional requirements for the EIA process are in Section 8.3 of this report.”

ES11BUL001 52

Orange areas

Justification No arguments or conclusions, only opinion on possible negative impact

without grounds for the conclusion

Implications No implications – only a recommendation that a “detailed

analysis/research should be carried out”. Despite the lack of arguments, the

Consortium goes on to recommend measures. Such recommendation is to be valued,

at best, as an opinion without factual or scientific basis.


The scientific base is well explained in throughout Section 7 and Annex D of the SER report.

Par. 1 Not clear how the criteria of 100kW is selection and for what reasons.


The threshold of 100kW is based on a several factors:

1) International experience – there are countries in which all wind power projects above 100kW undergo EIA;

2) Anticipated legislation changes – it is expected that the new RES law will contain a clear distinction between wind turbines for domestic electricity production, for local industrial production and for commercial electricity production, where 100kW is used as a threshold between the first and second category; and

3) Size of wind turbines - 100kW wind turbines are considered large enough to have considerable impacts on biodiversity.

4) Help to solve the current environmental problem with the cumulative effect of stand-alone wind turbines implemented in the country which don´t need at the moment the conduct of an EIA. Please consult new Section 7.8 on that regard.

Par. 2‐4 Redundant. According to the Bulgarian Environmental Protection Act the EIA report is



already granted by the current legislation. Furthermore, there are no arguments how the proposed

listing of the stakeholders will serve to improve the EIA procedure.



ES11BUL001 53






Par. 6 No arguments are provided as to why the suggested “comprehensive inventory”

is necessary.



Additional recommendations enlisted in Section 8.3.

Yellow areas

Justification No arguments or conclusions, only general opinion on possible negative

impact without grounds for the conclusion. Further, the data is not complete or

sufficient.


Please see above answers on this regard.

Page 79

Implications No implications – only recommendations which are to be valued, at best,

as an opinion without factual or scientific basis.



Par. 1 Not clear how the criteria of 100kW is selection and for what reasons.



Par. 2‐4 Redundant. According to the Bulgarian Environmental Protection Act the EIA report is



already granted by the current legislation. Furthermore, there are not arguments how the

proposed listing of the stakeholders will serve to improve the EIA procedure.



ES11BUL001 54






Par. 6 No arguments are provided as to why the suggested “one‐year inventory” is

necessary.


The yellow areas are, while being labeled as areas with “low” sensitivity do contain receptors vulnerable to wind power development. In this regard, a one-year monitoring of the fauna is generally accepted and often practiced in the conduct of EIAs of projects expected to potentially pose impact on the flora (in the particular case mostly to birds and bats).

Additional recommendations enlisted in Section 8.3.

White areas

Justification No arguments or conclusions, only general opinion.



Conclusion Considering the reservation about the quality of the database, the

recommendations listed with regard to the sensitivity areas are, at best, questionable.

The report lacks the objectivity and argumentation to be used as grounds for

development of wind energy in Bulgaria.


From the text included in bold font at the end of Section 7.2 does not infer that the report cannot or should not be used for informing the future wind power development in Bulgaria. The text only states that the “dataset will undoubtedly have to be expanded and updated in the future” – something relevant to all spatial datasets, which include relatively dynamic environmental data and which can always be enriched with data from new field studies. The report further calls to the MoEW to further review the sensitivity classification – as it may have information which was not available to the Consortium. And of course, as legislation changes in the country, the sensitivity classification may need to change accordingly. As stated in the report “In its current state it does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.”

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Page 80

7.3.1. Energy, Climate and Air Quality

Par. 1 Key criteria for assessing the level of sensitivity of the areas are not researched

since the underlying information is incomplete. Thereby, instead of undertaking a

more diligent research, the Consortium chose to treat the missing data as one of

“limited value”.


The missing data is not treated as limited value; the correct sentence mentioned on the SER Report, page 80 is:

“(…) Furthermore, it is the opinion of the Consortium that the spatial analysis will only bring limited value to the evaluation of SER objectives (…)”

The reasoning behind this statement is that these SER Objectives are not suitable for spatial analysis. Some investigations could be spatially done, for example: comparisation on air quality measurements in areas where wind turbines are located with areas where wind turbines are not located. However, since data on wind turbines location was not available and data on air quality would be difficult to obtain in the project timescale, the Consortium took the decision to focus on already available data and to proceed with project deadlines.

Page 81

7.3.2. Cultural Heritage (Table 29)

Basis for inclusion: The reference to Article 50 and Article 65 of the Cultural Heritage

Act is irrelevant with regards to grounds for inclusion.


These articles set the importance to protect cultural heritage properties. Cultural Heritage Act is the main law for the protection of cultural heritage. It regulates the conservation and protection of cultural heritage of Bulgaria. Conservation and protection of cultural heritage is a systematic process of searching, identification, documentation, conservation - restoration and popularization of cultural heritage, which includes training of specialists in each field.

No arguments are provided such as to justify the classification of the monument with

national significance as to the orange sensitivity area.


There is no justification, since data was not available to be included in the spatial analysis. Only data used or expected to be included in the spatial analysis was subject to justification. The reason behind that is the fact that the assigned level of sensitivity, among other things is a function of the data quality. In this regard the assigned level of sensitivity is provisional and subject to confirmation, once or if such data becomes available.

ES11BUL001 56

No spatial data/sources have been researched.


Multiple institutions have been consulted and requested information from. The Consortium has asked for data and information the Institute of History at the BAS and the Religious Dept. at the Council of Ministers have been requested spatial information about all religious sites in Bulgaria but no information was provided. The map of national cultural and historical heritage properties was asked from the Cadastre Agency and the National Institute for Monuments of Culture but such information was not provided.

As it is mentioned and amended in the SER Report, page 82:

“The Geodesy, Cartography and Cadastre Agency, the Institute of History at the BAS, the Religious Dept. at the Council of Ministers and the National Institute for Monuments of Culture have been contacted about spatial information on the locations of the cultural monuments with national and local significance in Bulgaria. Such spatial information is not available for the national scale at either of the institutions.”

Page 82

Table 30 No spatial information is researched as for the location of the cultural

monuments with national and local significance. Thereby it is unclear how this filter

has been used to mark the sensitivity areas on the maps in the report since the only

data available to the Consortium is the one for the World Heritage Properties.


Please see Consortium Clarification Note 152. As previously explained the sensitivity areas included in the report are based on world cultural heritage site locations and in this case site specific. No assumptions were made regarding other potential cultural heritage properties.

The recommendation about the check on case‐by‐case basis for buffer zones of

cultural monuments is redundant – the Spatial Development Act effectively requires

co‐ordination of the construction of wind parks with the competent authorities of the

Ministry of Culture.

Appendix D1 The appendix refers only to the World Heritage Properties, no

comments/arguments are provided with respect to the cultural monuments with

national or local significance.


Annex D contains more detailed information on the spatial data sets which have been used in the spatial analysis or which at the time the draft SER report was written were still expected to be obtained within this project. Since no information was obtained or indicated that it will be provided at a later stage about national and local cultural heritage properties (please see Consortium Clarification Note 151 and 152), no information about them is included in Annex D.

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Page 84

7.3.3. Flora, fauna and biodiversity (…)

Par. 2 No arguments are provided to back up the opinion of the Consortium that the

separate analysis of the bird species is necessary beside the abundance of such data

readily provided by the relevant NGOs. This approach is non‐compliant with the

requirement for objectivity which is material for the report.


The abundance of data, the importance of birds in relation with wind power developments and the need to make the SER Report clear to all the stakeholders is considered by the Consortium to be enough to present the representation of the bird data on a separate map.

Table 31 The reference to Annex 3 of Article 37 of the Biodiversity Act provides a

general list of protected species ‐ no arguments are provided for the classification of

the conservation importance.


Detailed information is provided in Appendix D2 and Appendix E of the SER Report.

Page 85

Section 3.3. The red and black status of the sensitivity area is not justified by the cited

reference to the Protected Territories Act. The latter provides that restrictions on

construction might be imposed on case‐by –case basis within the order for the specific

protected area, not that construction is altogether prohibited.


The reasoning is explained in Appendix D2 H. Protected Territories

“Under the Bulgarian Protected Areas Act, six types of protected territories are designated in Bulgaria: strict nature reserves, managed nature reserves, nature parks, national parks, natural monuments and protected sites. Various levels of restrictions are set in the act for each protected territory type.

Strict nature reserves, managed nature reserves, national parks, natural monuments and protected sites are assigned as areas with explicit legislative prohibition for wind power development, while natural parks as areas with high sensitivity to wind power development. • Strict Nature Reserves – according to art. 17 (1), all activities shall be prohibited in strict nature reserves, except some activities which are directly related to the protection of the reserves; • National Parks – according to art. 21, any construction, with the exception of hikers' shelters and chalets, water catchments for drinking purposes, treatment facilities, park management and visitor service buildings and facilities, underground communications,

ES11BUL001 58

repair of existing buildings and roads, and sports and other facilities, shall be prohibited in the national parks. • Natural Monuments – according to art. 24, any activities that may disturb the natural state of natural monuments or impair the aesthetic value thereof shall be prohibited in natural monuments. • Managed Nature Reserves – according to art. 27 (1), any activities shall be prohibited in managed nature reserves, except some activities which are directly related to the protection of these territories; • Nature Parks – according to art. 31, all activities and construction, which are not permitted in the park designation orders , park management plans and the spatial and technical plans and projects, as well as all activities which are specifically prohibited in the parks designation orders and the management plans, shall be prohibited in nature parks.

Protected Sites – according to art. 34, any activities contrary to the requirements for conservation of the specific features subject to protection shall be prohibited in protected sites. “

Page 87

Section 3.5.2 The reference to Article 4 (2) of the Forest Act does not provide basis for

inclusion. Furthermore, no data has been provided to back up the conclusions since it

is still “expected”.


The full justification of the inclusion of forests with special designation is provided in Annex D2 L. Even though the data has not been obtained by the Consortium for the whole country of Bulgaria, experts in the Consortium are well familiar with the type of data that is expected, its quality, limitations, etc. Thus, even in the absence of the data set, it was possible to assign a level of sensitivity.

Section 3.5.3 The reference to Article 1 (2) of the Forest Act is a irrelevant – the

general statement regarding the purpose of the law does not provide arguments to

back up the choice of this type of sensitivity area. Again, no data has been provided to

back up the conclusions since it is still “expected”.


Please see Consortium Clarification Note 158 and also refer to Annex D2 M, where the justification is fully explained.

ES11BUL001 59

Page 95

7.3.4.1. Legal basis for inclusion (re Bird species and birds related areas)

Par. 1 The cited Bird and Habitat Directives are incorporated in the Bulgarian

Biodiversity Act.


Nevertheless, these are EU Directives and are relevant for the analysis since Bulgaria is an EU member and the EU legislation is applicable to all EU member states.

Page 96

Section 2 No reliable data is available to determine the migration corridors. Despite the

“insufficiently studied” migration corridors, it is “believed” that whenever proper studies are

done, they will confirm the conclusions of the NGOs protecting birds. Following the logic of this

approach a study commissioned by investors in wind parks will confirm that there are no

significant migration corridors within the territory of the Bulgaria.


The statement “it is believed that detailed studies will result in the identification of bottleneck sites” is based on the available information, which currently is insufficient to make a scientific conclusion about the presence of a migration bottleneck site but it is sufficient to indicate that there is high probability that after more studies these areas may be migration bottlenecks.

Analysis and studies performed by environmental NGOs, academic institution (BAS) and the industry are equally important to provide clarity regarding the environmental and social constraints to wind power development in Bulgaria.

Regarding to red zones, there are sufficient studies that confirm the presence of migration corridors and bottle-neck sites. In this respect detailed studies are needed to determine the bird behaviour – flight height, direction, soaring, roosting, landing during the day, daily dynamic of migration, migration dynamic during the season, bird composition and quantity. All this is needed to assess the risks and impacts and decide if a particular site is suitable for wind power to development and how this development will be appraised.

Regarding to orange or yellow zones, data is not considered sufficient, because in these territories there have not been targeted surveys on migration. There are scattered data that clearly show that there are migration corridors there. If full migration (spring and autumn) surveys would be conducted in these areas then there would be reliable data for the identification of the bottleneck sites.

ES11BUL001 60

Section 3 Despite the statement that the migration corridors are “relatively poorly

studied”, the conclusion is that wind energy will cause “high risk” for migrating birds.

Staging areas (…)



Par. 1 The data is incomplete. No reliable data is available except for six globally

threatened species.


Although the data is incomplete does not mean that data is not reliable. For example, if there are 50 nest of a particular globally or EU protected bird species in Bulgaria but there is precise information about the locations only of 10 of these nests, this information is absolutely usable and useful – it simply needs to be expanded in the future. Therefore, a clear distinction should be drawn between data with insufficient precision and data which is incomplete.

In order to incorporate the level of uncertainty into the spatial constraints analysis, different levels of sensitivity were attributed and one of the criteria for this attribution is the level on precision of the data set. This approach is a clear example that the Consortium has tried as much as feasible to incorporate the level of accuracy of the obtained data in the results.

Page 100

Special Protection Areas

Par. 4 The reasoning is flawed. If the respective protected area requires special

restrictions on construction, such restrictions are to be included in the order for the

respective protected area. The precautionary principle is unjustified.


The precautionary principle is used for SPA areas that not yet designated, as well as for the ones which are designated but not yet approved. As mentioned in the SER Report, page 100:

“(…)not designated as SPAs fall under the requirements of the Article 4.4 of the Bird Directive, according EU case law, in particular the ECJ decision in case C-374/98. These areas should be protected until it is confirmed that they designated as SPAs. These areas are the 19 approved but not yet designated SPAs, as well as the areas of IBAs Kaliakra, Lomovete, Central Balkan, Rila, Pirin and Western Rhodopes that are proposed but not approved as SPAs and thus are subject to an EU infringement procedure”.

Considering the vulnerability of many bird species to wind turbines, the fact that the SPAs are designated to protect the rich ornithofauna of Bulgaria, as well as the fact that Bulgaria is currently dealing with 2 EU infringement procedures, it’s the Consortium’s strong belief that the precautionary principle is well justified.

ES11BUL001 61

Page 113

Public health, noise and vibration (Table 36)

No data is available although it is expected to be provided by the Ministry of

Agriculture and Foods.


Correct. All the data that at the time of the preparation of the draft SER report was expected to be provided and included in the analysis and presented in the final SER Report was mentioned for transparency purposes.

7.5. Composite Constraints Analysis

Par. 2 No arguments are provided as to why agricultural lands of first through fourth category are

to be classified as “areas with explicit legislative prohibition for wind power development”.

Currently, there is no such restriction in the Protection of Agricultural Lands Act. Indeed an

amendment to that respect is proposed but the merits of this bill are highly questionable and it is

unlikely that a general ban for re‐designation of lands of first through fourth category will be

approved by the Bulgarian Parliament. The conclusion of the report is another evidence of the one‐

sided approach applied in its drafting that undermines its value as basis for the wind energy

development strategy of MEET.


This statement is incorrect. As explained in the SER Report, page 122:

“(…) A map with all areas with explicit legislative prohibition for wind power development is presented in Figure 10. According to the available information, it is expected that more areas, such as the new SPA´s areas or the Agricultural lands – categories I, II, III and IV, might be included in this map in the future.(…)”

Additionally, as stated in the SER Report, page 109:

“(…) The amendments to the act were approved in April 2010 by the Council of Ministers and now have to be voted in the Parliament. As shown in Section 6.1.4, the potential impact of wind power on soils with high economic value is assessed as being partial negative and because of that a low level of sensitivity has been assigned to agricultural lands category 1st to 4th. However, given the potential that the referred areas may become unavailable for wind power development if the amendments to the act are approved by the Bulgarian parliament, these areas have been assigned a special intermediate level, only applicable for this particular case - low sensitivity level (yellow) with black overlaying stripes.(..)”

The approach followed by the Consortium supports the principle that wind power development can be combined with other sectors and activities.

ES11BUL001 62

Par. 6 Considering the reservation about the reliability of the database used for the

report and the recommendation for cross‐check, the conclusions and

recommendations of the Consortium are questionable. Thus, the report has failed to

achieve one of its objectives e.g. to serve as a basis for the national plan for

development of renewable energy in Bulgaria.


The Consortium has created a database of the best available scientific information regarding the environmental and social constraints to wind power development, which is provided by reputable scientists, institutions and organizations. The Consortium has performed some basic verification of the provided data. Even though the Consortium has all reasons to believe that most if not all of the used data has the stated precision, full cross-checking and verification of the data was far beyond the initial scope of work for this project.

Par. 7 The report cannot be used for a “starting point” by the MEET because (i) the

underlying data is incomplete and unverified; (ii) the conclusions are not justified with

arguments but with opinions and (iii) the approach applied in compiling the data and

reaching the conclusions is one‐sided and lack objectivity essential for every scientific

research.


Please see previous answers in this regard.

Page 126

7.6. Limitations of the performed spatial constraints analysis

As discussed above, the reservations about the accuracy and reliability of the database

used for the report undermine the conclusions and the classification of the sensitivity

areas suggested by the Consortium. The argument that verification of the underlying

data is not within the scope of the assignment, does not justify the one‐sided approach

and the random choice of recommendations.


Please see previous answers in this regard.

ES11BUL001 63

Page 127

7.7. Recommendations

Par. 2 The reasoning is flawed. As discussed above in the report (i) there is no reliable

study of the wind potential that covers the territory of the entire country and (ii) such

study is to be made on case‐by‐case basis by the investors.


If data on wind potential is provided at a national level both, investors and authorities can define wind power development targets for the country based on official and published information. Further, once a relatively reliable wind potential data is available for the whole country, investors should study case-by-case the areas subject to wind power implementation and ensure that wind power development can be technical, economic and environmentally viable.

The possibility to have a common starting point is an advantageous approach for all the stakeholders and can prevent future problems and wasted investments.

The Consortium’s suggestion aims to a transparent wind power development in Bulgaria serving as an example for other EU countries.

Par. 3 The recommendation to the MEET and MoEW to undertake calculation of the

wind potential is unrealistic as discussed above. Moreover, this approach is not

appropriate for a market‐based economy.



ES11BUL001 64

10 SECTION 8 Page 128

Par. 5 If the significance of the recommended mitigation measures can only be

assessed in individual EIAs, then how were they chosen and why are they mentioned

here at all?

If the mitigation measures can only be assessed case by case, then why is it that the

report can assess the impact at a national level nonetheless?


As mentioned in the SER Report, page 128:

“(…) The mitigation measures given in this section have been devised to avoid, reduce or off-set any likely significant adverse environmental effects of developing wind power. As this SER provides a strategic overview of developing wind power in Bulgaria in the future, the mitigation measures given in this report are intended for strategic planning purposes only. Therefore, more detailed EIA would need to be carried out, and bespoke mitigation measures devised, in connection with individual wind power development projects.(…)”

The effects can be assessed at the national level, nevertheless, it is the Consortium’s recommendation that detailed EIAs are carried out on a case-by-case basis.

The mitigation measures outlined in Section 8.1 of the report follow the logic that general and commonly applied procedures can in many cases reduce, avoid or off-set significant adverse effects, therefore they are mentioned in this section of the SER Report.

Page 129

Par. 3 This means that the authors have made no effort to investigate the one

objective for which they identify wind power as having only significant positive effects.

This goes to demonstrate a focused effort of the authors to make the report about

negative impacts rather than finding a balance.


As mentioned, in the SER Report, page 129:

“(…) only significant positive effects on Energy, Climate and Air Quality have been identified. Therefore, mitigation measures are not necessary at the strategic level. (…)”

Meaning, that if the mentioned SER objectives are positive there is no need to recommend any mitigation measures.

As explained in the SER Report, page 128:

“(…) The mitigation measures given in this section have been devised to avoid, reduce or off-set any likely significant adverse environmental effects of developing wind power.”

ES11BUL001 65

Point 8.1.2. This is already the case.

Bottom This is already the case.


The Consortium does not state whether these recommendations have been applied or not. These are general recommendations which can be also used by investors unfamiliar with all procedures in Bulgaria. Therefore, the inclusion of these measures can only be beneficial.

Page 130

Turbine Shut Down This is not a viable solution. The economic risk cannot be

evaluated. This makes debt financing of projects impossible. Further the statistical

chance of a collision with a rotor blade is virtually the same regardless of whether the

turbine has been shut down or now.


According to the reviewed literature and based on the experience of international wind experts, this system has proved to be useful and effective in some cases. It is not suitable for the whole country.

Nevertheless, this is a decision to be taken by the Authorities based on a case by case approach, which, as previously mentioned, is not part of our strategic level of study.

Fencing This recommendation demonstrates that the authors have made little effort to understand

the parameters of wind power projects in any detail. Wind turbines do not need fencing. As fencing

would simply amount to a useless additional cost, it will be avoided naturally. Fencing is required

for ground level high voltage installations. These are substations. For those fencing is mandatory

for good reason, given the risk of electrocution for humans and animals alike.

This means this recommendation is ill‐informed, it is dangerous and negligent.


This is not correct. The correct sentence mentioned in the SER Report, page 130 is the following:

“(…) Where possible, the construction of additional fencing as part of wind power projects should be avoided in order to protect habitat and animal species.(…)

The sentence does not refer to fencing around wind turbines. Refers to fencing around wind projects, since by several reasons, such as: boundaries of the wind park, property delimitation for legal purposes, security reasons against property damage, etc. Nevertheless, in some particular cases, wind turbines can be fenced for some special designation. The following images are aimed to explain what it is mentioned:

ES11BUL001 66

Decommission This is already reasonable standard practice. No longer operating

turbines represent residual value and their removal is in the economic interest of their

owner.



Page 131

Landscape This is already standard practice. Significant negative effects on the landscape are a

subjective valuation and not backed up by the data cited by the report (12 % concerned people

after construction).



The location of wind turbines in industrial areas is non‐logical as it runs counter to restrictions that

the report cites regarding minimum distances to built‐up areas. Also, industrial areas have high

terrain turbulence levels stemming from buildings which make them ill‐suited for wind power

development.


This is suggested by different stakeholders and by wind experts as a suitable approach in several industrial sites. According to art. 141 from the Regulation 14 for the technical rules for the design, construction and operation of installations for the production, conversion, transmission and distribution of electrical energy, wind power turbines should be at least 500 meters away from the territory of the closest settlement. Some industrial sites are located outside the boundaries of settlements. Therefore, even if this recommendation may not be suitable for the whole country, in certain areas this approach could be beneficial.

ES11BUL001 67

Access of the public to visualizations for consultations is already part of the EIA

procedure. The recommendation is redundant.



Page 132

Noise Redundant. The recommendations regarding minimum distances, inclusion in

the EIA procedure and sound insulation and optimization are all already part of

standard practice. The report appears to be under the impression that developers or

investor may be able to modify turbines irrespective of certification and safety

concerns.



Page 133

Shadow Flicker Redundant. This is already standard practice.



Socio‐Economic The recommendations are blatant generalizations without any

applicable character. Some of the recommendations belong in other areas. It appears

that the report has chosen not to focus on this objective.


As mentioned, these are general recommendations which can be also used by new investors. Accordingly, citing these measures can only be beneficial.

Page 134

Section 8.3. Redundant. The recommendations and concerns here have already been

addressed by the authorities and are part of current standard practice.


As mentioned, after the scoping consultation process, meetings were held with different stakeholders. Further, meetings with representatives of the MoEW and the regional

ES11BUL001 68

inspectorates were also conducted. During these meetings, it was perceived that difficulties are continuously encountered during the environmental evaluation of wind power projects.

Due to the fact that Bulgaria is a country with a valuable natural heritage, and given its great richness in biodiversity and the occurrence of many species that are at risk of extinction, EIA are an important tool to support the sustainable development of wind power in the country. In this regard, the Consortium has emphasized certain existing requirements which are not sufficiently implemented, as well as has recommended some additional requirements.

Page 139

Bird Protection 2 year field studies are economically non‐viable. The recommendation

of a general minimum term runs counter to the realization that these issues need to be

dealt with on a case by case basis. Requiring 2 year terms from now on would with

certainty lead to Bulgaria falling short of the EU 2020 interim targets along with the

corresponding costs to the country. The attention and detail that the bird protection

topic receives in the recommendations section is again exemplary of the exaggerated

weight it has received compared to other topics.


The guidance for conducting assessment of the impact of wind generators on habitats and species in protected areas, which has been prepared together by MOEW and BSPB on assessing the impacts of wind turbines, in its section 2.1.1.5, it is written that regarding birds, studies which have been conducted for at least 3 years are considered representative. In the SER Report, the Consortium recommends 2 year field studies, lowering MoEW recommendations. Moreover, it is Consortium belief that if MoEW has approved such guidance, it also should have considered the commitments previously signed.

Nonetheless, due to the complexity of these issues and the different interests involved, decisions should be taken by the competent authorities and decisions discussed at the EU level.

Page 140

Landscape It is paradoxical to say that the topic was not addressed yet still to draw

conclusions. This amounts to nothing more than unfounded, non‐informed opinions of

the authors.


The correct sentence mentioned in the SER Report, page 140 is:

“(…) Even if landscape topic was not addressed in the spatial constraints analysis (Section 7.3.6), likely significant effects were identified (Section 6.1.5). (…)”

Meaning, that although no spatial analysis was conducted, due to the lack of data, the environmental topic was assessed and likely significant effects were identified.

ES11BUL001 69

Public Health Redundant.



ES11BUL001 70

11 SECTION 9 Page 143

Par. 1‐2 This is a platitude. In fact Bulgaria is an exception to this. Wind power has not

developed for most of the past two decades in Bulgaria at all. This would in fact be the

reason why the current development may be misinterpreted by many stakeholders.


Please see information provided in Section 2.1 of the SER Report, where data provided by the MEET and the electricity distribution and transmission companies provide evidence of wind power development in the country.

Par. 4 The method by which the relative impact on different objectives is weighted vis‐

à‐vis each other is arbitrary.


Detailed information on the assessment of the effects of wind power development on the different environmental and social aspects is provided in Sections 6, 7 and Appendix B and D.

Par. 9 Not all relevant stakeholders were consulted. This means a crucial component is

missing from the analysis.


Please see Consortium Clarification Note 15 and 16, as well as the PCDP report, which is available on the project website: www.bgwindenergy.com.

Page 144

Par. 1 The scoring system is flawed in that different areas of impact have a different

number of sub‐items. Instead of averaging the scores of the sub‐items the report

appears to sum them in order to arrive at its conclusions.


The proposed methodology is based on cited bibliography and Consortium member’s experience. No sums are made in the methodology applied.


“(…) When determining how likely the current wind power development is to support the achievement of the SER objectives (and therefore be a significant effect), the following factors are considered:

- Characteristics of the effects (magnitude, spatial extent, probability, duration, frequency and reversibility of the effects);

- The sensitivity of the receptors involved (the value and vulnerability of the receptor).

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There is a considerable variety of potential issues that could occur during wind power development and these have been documented within the assessment matrices. However, as indicated above it was decided that a simple scoring system would be used to assist with the interpretation of results.”

Different topics have different characteristics and in such analysis averaging is not adequate.

Par. 5 The quality of the data should be included in the GIS to make this information

readily accessible and to allow users of the GIS to arrive at an informed evaluation of

the output of the GIS.


To ensure data quality and transparency, the Consortium has collected metadata for all data sets included in the spatial analysis (this is information on the data source, purpose of creation of the data set, precision, data gaps, data availability and accessibility, etc.). Example of such metadata sheet is presented in Appendix C and the information from all metadata sheets is summarized in Appendix D of the SER report.

Bottom This means that the current data set is prone to included unverified, special interest driven

information. As such it represents a one‐side, ‘wind negative’ evaluation. This in turn can lead to

major, unwanted, negative consequence for the nation as a whole when the data set is used by

decision makers under the assumption that it does in fact represent an informed, crosschecked and

verified scientific consensus.


This is not correct. As it has already been mentioned multiple times here and as it is stated in several sections of the SER Report:



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Page 145

Par. 5 A map of the national grid and available grid capacity will be helpful. A map of

adequate resolution for the wind potential cannot be prepared in a timely manner and

at a reasonable expense by the government. The risk and expense of doing so are best

located with the developers.



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12 ANNEX D Page bb The data quality seem to be overstated considering that a downloaded map

was digitized instead of the use of underlying data. What is the (border) accuracy of

this data set?


As stated in Annex D1, “the map with the location of each Bulgarian Cultural World Heritage Property has been downloaded from the UNESCO website:

http://whc.unesco.org/en/statesparties/bg. Using these maps, the boundaries of the buffer zones around the properties were digitized in GIS and a single GIS layer (.shape file) was created.” The Consortium has always used the best available information. In the particular case of the locations of the World Heritage Properties, the best available data was the scanned maps provided at the above cited website. The boundaries included in the data set are within no more than a couple of meters from the actual boundaries.

Page cc The data set is based on one single expert who is a declared ‘wind opponent’.

Data was prepared in Google earth meaning without on‐site verification on all cases

and based on outdated satellite imagery. The data quality should hence be low.


Mr Boyan Petrov is a well known, credible and serious scientist, being considered as one of the best scientists with international recognition on the field of bat protection. Mr. Petrov works at the Bat Research and Conservation Center at the National Museum of Natural History and his credentials are considered valid for the current project. Further, Mr.Petrov has visited most of the sites, included in the data set and has used a large amount of published and unpublished scientific information. All details about the used approach, bibliography and results for the creation of this data set is exposed in Appendix E of the SER Report.

Page dd Single source, not verified, not crosschecked


The scope of this project was not to validate sources and cross-check information. As previously explained, Consortium tried to gather all the best available scientific information to serve as a future working base.

The Consortium has been as transparent as possible in referring data sources, data quality and data gaps, so the competent authorities can further work on this involving all the stakeholders in this process.

Page ee Single source, not verified, not crosschecked

Some of the information is based on computer simulations without any actual site

survey

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Page ff Single source, not verified, not crosschecked


survey



Page gg Single source, not verified, not crosschecked


survey



Page hh Single source, not verified, not crosschecked

The data resolution is not useable (10 x 10 km)


Please see Consortium Clarification Note 197. Further, even though the resolution of this data set is low, it is still useful to inform investors and the competent authorities about the potential presence of an environmental constraint. The low level of resolution is reflected in lower the attribution of a lower sensitivity level.

Page hh Single source, not verified, not crosschecked

The data resolution is not useable (5 km center points)


Please see Consortium Clarification Note 197 and 200.

Page kk The data set contains the proposed (not just the actual) SCIs!


Please see Comment 183. This comment also suggests that the writer of the comment is not familiar with the Habitat Directive and its transposition into the Bulgarian Biodiversity Act.

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Page mm Single source, not verified, not crosschecked (3rd party)

Resolution / accuracy not clear


Please see Consortium Clarification Note 197. Regarding the comment about the accuracy of the data – indeed information about data quality has unintentionally been omitted in the draft SER report but will be included in the final report.

This data is the result of an international project conducted between Bulgaria and Romania and it was financed by the Danish Foundation Aage V. Jensens. A book has been published with the results of the study.

Page nn Single source, not verified, not crosschecked



Page oo data for special designation forests has not been used / obtained from forest

agency stating .zem file conversion problems


Indeed, this data set was expected to be provided by the Executive Forest Agency. However, since it has not been received by the Consortium yet, it will not be included in the spatial constraints analysis.

The statement that the data base “ will be provided in .zem format. In order to use this data set together with the other data sets in the GIS database, major data processing will have to be undertaken. It is anticipated that the conversion of the .zem files into .shape files will take at least four weeks.” is made only to explain that in order to incorporate the data set in the report, the Consortium would need at least one month of processing time. The Consortium had the readiness and capability to process the data set but such has not been provided.

Page pp data for forest areas has not been used / obtained from forest agency



Page ss The BSPB database is not 3rd party verified. The accuracy of bird observations

recorded by ‘bird observation enthusiasts’ may be doubted.


BSPB is a well recognized organization with serious and credible data. BSPB is frequently asked to provide expert opinion at the EU level and has been involved in many projects working

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together with the wind industry aiming for the sustainable development of the wind power in Bulgaria.

Page tt The data set is largely insufficient as per the statement of the authors.


It is the goal of the Consortium to provide MEET (and MOEW) with a dataset in which all data sets and their respective quality are transparently and clearly described. The need for additional studies, analysis, etc. is explicit and continuously mentioned in different parts of the report. However, please also see Consortium Clarification Note 163 which elaborates on the difference between insufficient data quality and incomplete data set.

Page uu Single source, not verified, not crosschecked, not quantified, approximate



Entire bird section: largely: Page uu Single source, not verified, not crosschecked, not

quantified, approximate



Page aaaa data missing


Correct. This data set has been requested from the Cadastre Agency but has not been provided. Considering the significance assessment shown in Section 6.1.4, the lack of this spatial data at the national level is not a big issue.

Page bbbb data missing


Correct. This data set has been requested from the Ministry of Agriculture but has not been provided. Should the proposed ban become a reality, the addition of this data set to the compiled database will be material.

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Page dddd data missing


Correct. Accurate data about the boundaries of the settlements in Bulgaria was requested from the Cadastre Agency and the Ministry of Agriculture and Food but was not provided. Instead, CORINE Landcover Class 1 data set was used as a proxy – it is described on page eeee of the SER report.

This means no accurate data set was used for the 500 m black zones around

settlements. It is not clear how the black zones were added to the maps despite the

absence of this data set.


Data set was expected to be provided by the Ministry of Agriculture and Food. However, since data didn´t arrived on time to be included in the SER Report, an alternative approach was followed. The CORINE Landcover Class 1 data set was downloaded from the website of the Ministry of Regional Development and Public Works and used for this purpose. This data set represents all major elements of the artificial surface - described on page eeee of the SER report. A buffer zone of 500m was created around each polygon of a settlement.

To avoid confusions, Table D6-A will amended in the final version of the SER Report.

Page eeee data set omits some restricting installations


As mentioned in the SER Report, page eeee:

“It should be noted that this map does not include the electrical transmission lines, underground and aboveground pipelines, and other “thin” linear objects, which however require buffer zones. The maps also don’t include buffer zones around the included facilities, such as airports, railroads, etc.”


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Appendix H3: Clarification notes on the statement received by the Coalition "For the Nature in Bulgaria" on the SER Environmental Report

Clarification notes to the statement received by the Coalition:


Prepared by:


Date: June 2010


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Table of Contents

Introduction 3


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Clarification notes on the statement received by the Coalition "For the Nature in Bulgaria" on the SER Environmental Report


Introduction The Consortium wishes to thank the Coalition “For the Nature in Bulgaria” for the support given to the completion of this project. The Consortium understands that the Coalition is an important stakeholder for this project and therefore the Coalition’s participation in the public consultation process is much appreciated.


Clarification Notes

Coalition For the Nature in Bulgaria General Comments

It is believed by the Coalition that the inclusion of territories from Sites of Community Interest (SCI) which are protecting habitats from Annex 1 and habitats of species from Annex 2 of the Biodiversity Act in zone “red‐high risk” is inadequate and insufficient.

1. According to the presented maps, at least ¾ of the territory of the country falls within this zone but the only recommendations are related to the implementation of the Environmental Impact Assessment (EIA) procedures and of art. 6 (3) of Directive 92/43, i.e. the conduct of Appropriate Assessment (AA). Such recommendation is extremely insufficient and by itself it is pointless because it repeats the existing imperative legal requirements.


Red Areas are defined as areas where wind power development is expected to cause significant negative impacts on the identified environmental and/or social aspects. Therefore, it is Consortium’s opinion that wind power development in these areas should be approached with upmost care.

Due to the feedback provided during the scoping consultations and the additional technical meetings held by the Consortium, it became clear the RIEW´s have not used clear criteria to define and evaluate the need of EIA. Therefore, it is recommended that in these areas, and in order to minimize impacts, all wind power projects, except for small size domestic turbines, should undergo EIA and that the review of the performed EIAs should be centralized, since it´s government interest to safeguard country natural heritage. By doing so, it is expected that situations as the EU infringement procedures can be avoided in the future.

It is recommended by the Consortium that EIAs preformed in areas with high sensitivity to wind power development (Red Areas) should include additional requirements evaluated by the MoEW. As mentioned in the SER Report, page 135:

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“The EIA, with the additional requirements (…) should be evaluated at national level by the MoEW. Clarifications and support may be asked from the regional inspectorate, within which jurisdiction the project falls, but the final official decision should be taken by the MoEW.

Such centralized decision making is expected to ensure that these projects are assessed with the highest attention by the public and by the competent authorities because decisions on the EIAs will be taken by the Supreme Environmental Expert Council, which consists of highly knowledgeable and experienced experts from the MoEW (Preventive Activities Directorate, National Nature Protection Service, etc.), Ministry of Regional Development and Public Works, Ministry of Health, Ministry of Agriculture and Food, academic institutions, NGOs, etc.”

The Consortium understands the point raised by the Coalition, however, since the “imperative legal requirements” are not currently followed by the Government, it´s Consortium’s belief that it is important to restate and reinforce them. Additionally, it is not the Consortium objective to determine EIA´s or AA´s criteria. The Consortium just proposes the minimum points that need to be properly addressed, so decisions can be taken.

2. The approach in the black zone (with full ban) to include only territories for which there is an explicit legal ban for construction of wind turbines is entirely formalistic and does not correspond to the goal of the environmental report to assess the risk on the bases of objective and substantial criteria. This approach entirely ignores all other parts of the environmental report and makes them pointless, including the implementation of the criteria for sensitivity.


It was the opinion of the Consortium that Black areas should be defined in the SER Report, as:


(…)

“According to current enacted Bulgarian legislation, almost all economic activities including wind power development are explicitly prohibited in these areas”

These areas are not subject to judgment or experts opinion. They are mentioned in the indicated acts and are in accordance with MoEW’s indications, previously consulted on this issue. Black Areas are assumed directly as areas where the criteria for sensitivity do not apply, since these areas are already addressed and defined by the currently enacted legislation.

The inclusion of Black Areas in the maps, allow stakeholders to visualize currently prohibited areas and understand the criteria underneath this prohibition.

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3. The fact that the habitats in the SCI zones are protected, which makes all industrial scale significant construction activities incompatible in these zones, has been ignored. Therefore, there is a real need not to allow such construction.


“All wind power projects proposed in these areas should be subject to comprehensive EIAs, (…). These EIAs should cover all new or upgraded infrastructures, associated with the proposed project (…).” Further, according to the Bulgarian legislation, all projects proposed inside or in the vicinity of protected zones from the NATURA 2000 network should be subject to Appropriate Assessment (AA). It is during the AA when the compatibility of the proposed project with the objects and grounds for protection of the protected zone(s) is assessed.

4. The final result (of the SER report) will be very small, as long as the report does not change the current conflict situation – the presence of many proposed investments harming the environment, ineffective EIA and AA procedures, which do not guarantee the implementation of the law, unclear rules for the investors and burdening the investors with entirely superfluous procedures and costs.


As it’s described in the SER Report:

“The outcome of the SER is intended to advise and inform the development of wind power at a national level through forthcoming MEET documents, regulations, etc. The degree to which recommendations will be incorporated into Bulgarian policy has to be determined by the MEET and other institutional stakeholders.”

In this regard, it is suggested by the coalition:

1. The team preparing the SER to take a responsible decision and include all territories of SCIs, in which habitats from Annex 1 and habitats of species from Annex 2 of the Biodiversity Act are protected, in the black zone, which recommends no construction of wind power installations, except for domestic types on currently urbanized territories.



Further, many of the layers concerning Annex 1 habitats or habitats of Annex 2 species are based on either CORINE Landover or on scientific modeling for determining the most suitable habitats for the particular species. It is the Consortium’s opinion what while this data is sufficient for determining high level of sensitivity for the respective area, thus requiring more attention and more stringent EIA process, it is not sufficient to base on it total prohibition of wind power

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development. And finally, as far as the Consortium is informed, the MOEW is planning a large project for detailed mapping of habitats in NATURA 2000 areas. The results of this project may be used by MOEW to pose the level of restriction sought by the Coalition.

2. An alternative option is to create a separate color ‐ “dark red”, meaning proposed full ban for the construction of wind power installations on wetlands, forests, rocks and permanent grasslands (meadows, abandoned and non‐cultivated agricultural lands, territories unsuitable for forestry) and high risk for the construction of such installations on other territories with agricultural use.



Also, the Consortium has adopted the view that no more than five sensitivity classes should be used (black, red, orange, yellow and white). This by itself already created quite a complex set of requirements, and introducing additional classes may make the system inapplicable.

3. The coalition considers that it is necessary that the recommendations for the conduct of EIA and AA for all other territories in the “red” zone are specified in accordance with the reasoning for the inclusion of these territories in this zone. Simply referring to the conduct of complete EIAs cannot change the negative situation in the country. Therefore, specific requirements should be outlined for the scope of the EIA and AA and to the parameters of the installations in order to simplify the administrative process. This will only result in lessening the burden on the investors and to the creation of more clear, streamlined and good quality rules for the conduct of EIA and AA procedures.


The Consortium believes that the recommendations made in Section 8 of the SER report are general enough to be relevant for a strategic study that covers the whole country of Bulgaria but at the same time specific enough to serve as a useful tool to the competent authorities and the investors in the EIA process.

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4. The coalition also believes that the inclusion of the “High conservation value forests (HCVF)” in the “orange” zone is inadequate. The potential construction of wind farms in forests of this category will undoubtedly lead to devastation of all surrounding forests – the deforestation of the entire site is inevitable. It is inadequate to state that this is low risk to the environment. Therefore, all such territories should be included in the “red” zone.


The inclusion of the “High conservation value forests” in the orange zone is based on the assumption that extensive wooded areas are in principle less favourable for the development of wind power. The basic condition that no massive deforestation in such areas should be allowed should inevitably be the outcome of the EIA that needs to be conducted prior to any wind turbine installation.

The members of ‘For the Nature in Bulgaria” Coalition are the Association of parks in

Bulgaria, Bulgarian Association of Alternative Tourism, the Bulgarian Society for

Protection of Birds/BirdLife Partner, the Bulgarian Association of Phytocenology –

2001, the Bulgarian “Biodiversity” Foundation, Information and Education Center of

Ecology, Community Center "Future Now", “Agrolink” Society, BALKANI Wildlife Society,

“For the Earth” Society, “Borrowed Nature” Society, “GREEN BALKANS”, the Association

“Nature Fund”, the Ecology and Sustainable Development Club UNECO of the Student

Council of the Sofia University, Shtastlivetza Sofia Civil Association (SSCA), the Citizens’

Groups “Let’s Save Irakli” and “Citizens for Rila”, Bulgarian Climbing and

Mountaineering Federation and WWF Danube‐Carpathian Programme Bulgaria.

Currently more than 30 organizations support the Coalition.


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Appendix H4: Clarification Notes on the statement received by the Bulgarian society for the protection of birds on the SER Environmental Report

Clarification Notes to the statement received by the:

BULGARIAN SOCIETY FOR THE PROTECTION OF BIRDS


Prepared by:


Date: June 2010


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Clarification Notes on the statement received by the Bulgarian society for the protection of birds (BSPB)

Version: June 2010-06-06

Introduction The Consortium wishes to thank BSPB for all the support throughout this project. The Consortium understands that BSPB is an important stakeholder for this project and therefore BSPB’s participation in the public consultation processes is much appreciated.


BSPB Clarification Notes

The Bulgarian society for the protection of birds (BSPB) fully supports the statement of the

Coalition “For the nature in Bulgaria” Coalition, regarding the «Strategic Environmental

Review (SER) of the development of wind power in Bulgaria», prepared for the Ministry of

the Economy, Energy and Tourism.

After our representatives participated in the public consultation meetings organized on May

25, 27 and 28, 2010, in addition, we would like to express the following comments and

recommendations:

1. We are satisfied, that the report uses a big volume of data regarding migrating, wintering and nesting birds in Bulgaria, including data presented by the BSPB, namely: a. Data on the nesting raptors, based on the precise location of nests of species such as the Imperial eagle, Egyptian vulture, white‐tailed eagle, golden eagle, griffon vulture, long‐legged buzzard, eagle owl and others, as well as data for the precise locations of the black stork. All of these nests have been subject to regular monitoring by the BSPB, other NGO and scientific institutions for years. b. Data of the BSPB and the Hungarian partner of BirdLife International regarding the staging and feeding areas and concentration of globally threatened raptor species such as the imperial eagle and the saker falcon, supplied by GPS studies within the framework of large‐scale conservation projects financed by the Life+ program of the European Union. c. Data for the winter congregations of waterfowl in the wetland areas of Bulgaria, collected during the mid‐winter counts from 1997 to 2008. d. Data on the locations where wintering red‐breasted geese and lesser‐white fronted geese regularly feed – two especially globally threatened bird species. e. General data for the bottleneck sites and migratory corridors, collected by the BSPB for the period between 2003 and 2009 from more than 33 observation points, for each of which there have been observations for at least one full migratory season (3 months).

The spatial presentation of these data (on the map), as well as the volume of the used

ornithological data for the first time presents at the national level a sense of the most

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significant places for the birds, which are most vulnerable by the construction of wind power

generators. This information is the basis for the best current information that can be used for

decisions regarding the construction of wind generators and avoiding risk for the birds.

This map should be expanded, as there are many not studied or insufficiently studied

territories. We stress that the data presented by the BSPB and used for this report are checked

and validated before being presented.


As mentioned in the SER Report, page 79, it´s Consortium suggestion that:

“(…) It is important to note that although great effort has been invested by the Consortium and the involved stakeholders to compile the best scientific data that is currently available regarding the social and environmental issues that may be affected by wind power development, the currently available dataset will undoubtedly have to be expanded and updated in the future. (…)”. Furthermore, the Consortium does not place any doubt in the quality of the data presented by BSPB. However, since the Consortium did not have the resources to perform in depth cross-checking and validation of all data provided by the various stakeholders, the Consortium has cautiously declared that all data needs further verification.

2. With regard to the above, as well as due to the fact that we have participated in the process of defining the criteria for the selection of the different sensitivity areas for the birds, we have to state, that the interpretation of the data and the results in the report have been altered significantly, and do not correspond to the areas of vulnerability for the birds defined by the expert. a. As “red zones” for the birds, the expert ornithologists from NGO and scientific institutions have defined territories, where construction of wind turbines should be avoided, due to the existence of excessively high risk from mortality, disturbance and driving away of very threatened bird species. These territories were defined as buffers around precisely localized nests of birds and around wetland areas. The buffers were estimated on the basis of impact monitoring of wind turbines in other countries, as well as the ecological characteristics of the species. The feeding areas of geese, and congregations of raptors were defined based on satellite or radio telemetry studies and site visits, and do not include buffer zones around them. Migration corridors were defined based on the most intensive migration routes, for which there are reliable data about the numbers of passing bird species. This spatial information has been preserved; however the definition of the zone has been altered, so that instead of recommending avoidance of construction of wind turbines, in these areas only a detailed EIA with two‐year preliminary monitoring is recommended. We feel that the alteration of the definition is entirely improper, especially when it concerns globally threatened bird species.


The Consortium is aware of the suggestions provided by the experts, including by BSPS. Nevertheless, having into account international experience and other expert’s opinion, it was decided and assumed by the Consortium to change the definitions initially provided by the experts and placing more emphasis on the role of the EIA in the definition of the suitability of specific zones for wind power development. Moreover, it is not the role of the Consortium to

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define or delimitate wind power development. Therefore, suggestions and recommendations were provided in order to provide to the competent authorities the best available information and allow them to make more informed decisions.

Presented below is a map of the highest risk areas for some of the most globally threatened

species – imperial eagle, saker falcon, Egyptian vulture and red‐breasted goose. These areas

should mandatorily be avoided when constructing wind turbines.

Map 1. Risk areas for 4 nesting and wintering globally threatened bird species.


Please see Consortium Clarification Note 2. Also, very clear criterion has been used to distinguish between black areas (areas where wind power development is explicitly prohibited) and red areas (areas with high sensitivity to wind power development) – this criterion is the presence of a piece of legislation which states the prohibition in a way which cannot be challenged. In this regard, while several EU and Bulgarian legislation acts can be interpreted (probably rightly) that the areas indicated on the map above should be avoided by wind power turbines, suggesting avoidance or prohibition of wind power development in these areas can be challenged and thus does not meet the criterion for black areas.

b. «Orange» and «yellow» zones defined for the birds, reflect the level of knowledge, and in most cases not enough studies have been completed, the data defining the level of vulnerability of the territory is not specific enough. In this regard these areas should be considered as areas where not enough information exists, and should be treated in accordance with the precautionary principle, and not as areas of lower risk. At this stage for these areas it cannot be stated whether the construction of wind turbines should be avoided. More detailed studies should be carried out in these areas, which should define where within the areas wind turbines can be constructed, as well as how many and how they should be placed, and whether there are territories, which should be avoided.’ We feel that the alteration of the definitions of the areas by the consultant team, after they

have been initially coordinated with more than 30 expert ornithologists, is unacceptable.

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Perhaps, the present map could be better politically accepted, but in the way, in which the

read area is defined, we believe that it will not achieve its goals for avoiding the risk for wild

birds.


Since the level of information is not detailed enough it is not possible to access the impact of wind power development. Nevertheless, and because the Consortium has applied the precautionary principle in the whole project, additional studies are recommended in the SER report.

3. When defining the areas with legislative restrictions for the birds (“black areas”), protected areas for the birds from the NATURA 2000 network are not defined as areas, in which construction of wind power should be avoided, unless there is a specific legal prohibition. We feel that in this way the requirements by the Birds Directive are not implemented. As these special protection areas for the conservation of bird species in Bulgaria are subject to protection of many bird species, vulnerable to wind generators, these zones must be avoided when constructing wind turbines.


Black areas are defined, in the SER Report, as:


These areas are not subject to judgment or experts opinion. They are mentioned in the indicated acts and in accordance to MoEW indications, previously consulted in this issue. While the Consortium agrees that SPAs have indeed been designated for the protection of multiple bird species, according to the current Bulgarian law, wind power development in such areas is not fully forbidden, unless this is specified in the designation order or in the management plan of the SPA. Instead, the Bulgarian legislation mandates an Appropriate Assessment, which in most case will show that wind power development in the SPA is not possible.

4. When defining areas with legislative restrictions for the birds (“black areas”) the recommendation 130 (2007) of the Bern Convention, which requires Bulgaria to introduce a moratorium on future construction of wind generators on the Black Sea Coast has not been taken into consideration. This recommendation, made within the framework of an international treaty ratified by Bulgaria, must be considered to have legal standing.


5. The report does not present the present development of wind energy in Bulgaria; does not present an analysis regarding the number of permitted wind parks, the number of wind energy facilities, the spatial distribution on the territory of the country, etc. It lacks analysis of the effectiveness of the EIA procedure during the development of the wind energy sector to the present day. BSPB has presented information about investment proposals to construct wind generators, collected during 3 years, in accordance with the procedure defined by the Bulgarian Access to Information act, as well as information,

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published on the web sites of chosen regional inspections on the environment and water. The analysis and presentation of this information is necessary, so that the probable impact of the wind generators on the most vulnerable areas of biodiversity should be assessed, on which the corresponding recommendations regarding the improvement of the EIA procedure should be based. Consortium Clarification Note 6

Efforts were made by the Consortium to present this data in the SER Draft Report. However, due to the amount of work that this task represented (for example, matching coordinate systems with information provided by the RIEW´s), it was not possible to conclude this section of the report in the draft version of the report. Nevertheless, the Consortium will address this issue in the final version of the SER Report.

Having in mind the above stated opinion, we present the following specific recommendations

in order to amend the presented report and use the results of the strategic environmental

review:

1. The places defined as areas, for which it is necessary to avoid construction of wind turbines – “black areas”, should include the places of congregation during feeding, roosting or migration, or the nesting areas of the following globally threatened species: Egyptian vulture, Imperial eagle, Saker falcon, Dalmatian pelican, Red‐breasted goose, Small white‐fronted goose, White‐headed duck and Slender‐billed curlew. Please see Consortium Clarification Note 3

2. Protected areas for the conservation of bird species in NATURA 2000 must be defined as areas, in which construction of wind turbines must be avoided (“black areas”).


3. The municipalities in Bulgaria, bordering the Black Sea, must also be defined as areas, where construction of wind turbines must be avoided, in accordance with Recommendation 130 (2007) of the Bern Convention. Please see Consortium Clarification Note 5

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4. The report must present information not only about notified wind energy projects, but also about the wind energy parks or individual wind turbines permitted by the RIEW, their spatial distribution in the country, as well as what portion of them have been approved after the elaboration of EIA reports. Information should be presented for the already permitted, and for the planned projects, i.e. the ones currently undergoing EIA assessment. Information should be presented about the portion of planned wind turbines, which are located within NATURA 2000 protected areas. Please see Consortium Clarification Note 6

5. The report should be publicly accessible on the Internet pages of the Ministry of the economy, energy and tourism, and the Ministry of the environment and water, so that it may be used as a reference for institutions, investors, financial institutions and the public in order to inform the respective stakeholders regarding the environmental and social constraints for the development of the wind energy sector in the country, and to direct the process of planning and decision‐making.


Suggestion will be taken into account; however it´s not Consortium decision to disclosure this report in the official web pages of the above mentioned ministries.

Sincerely: Stoycho Stoychev Director of Nature Protection BSPB


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Appendix H5: Clarification Notes on the statement received by the Bulgarian Ministry of Environment and Water on the SER Environmental Report

Clarification notes to the statement received by the:

RR EE PP UU BB LL II CC OO FF BB UU LL GG AA RR II AA

MINISTRY OF THE ENVIRONMENT AND WATER


Prepared by:


Date: June 2010


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Clarification Notes on the statement received by the Ministry of Environment and Water


Introduction The Consortium wishes to thank the MoEW the comments provided on the SER Report. The Consortium understands that the MoEW is an important stakeholder for this project and therefore his participation on the public consultation processes it is much appreciated.


Clarification Notes

MoEW General Comments

In connection with the meeting held on May 25, 2010 at the MEET building, regarding the

abovementioned report, and after we familiarized ourselves with the report, we would like to

express the following statement, which was prepared between the experts from the “EIA and

SEA” Department at the “Preventive Activities” Directorate, as well as the “NATURA 2000”

division with the “National Nature Protection Service” Directorate at the MoEW:

1. Regarding the used methodology for carrying out the SER: In numerous instances in the text there are references to Directive 2001/42/EC regarding the

assessment of the impact of some plans and programs on the environment (Strategic

Environmental Assessment Directive), while at the same time, the SER does not have the

characteristics of an environmental assessment (EA) of a plan/programme, for which the EA

procedure is applicable. In this regard, we think these references are unnecessary, even if they

have been used only to clarify that the methodology of SEA has been used.



“(...)The process of Strategic Environmental Assessment (SEA) has been identified as a useful tool for the appraisal of the current state of wind power development in Bulgaria and the identification of the appropriate directions for future wind power development. The SEA is a systematic way to examine the likely effects of a strategic action on the environment and to suggest ways to either enhance or to mitigate these effects. The formal SEA process as required by European1 and National2 law applies to the assessment of specific plans or programmes. Given that, there is no formal wind power development plan or programme in Bulgaria at present, the development of wind power in Bulgaria cannot be assessed by a formal

1 Directive 2001/42/EC of the European Parliament and of the Council of 27 June 2001 on the assessment of the effects of certain plans and programmes on the environment 2 Regulation on the Conditions, Procedures and Methods for Environmental Assessment of Plans and Programs (SG issue 57/2.07.2004, last amended SG issue 29/16.04.2010).

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SEA which complies with all of the mandatory requirements under the SEA Directive or under Bulgarian legislation. Therefore, the Consortium, with the approval of the MEET, the Ministry of Environment and Water (MoEW) and the EBRD, decided to undertake a Strategic Environmental Review (hereinafter SER) which draws on best practice and relevant approaches from the application of SEA but which will not be totally compliant with Directive 2001/42/EC on the assessment of the effects of certain plans and programmes on the environment and the Regulation on the Conditions, Procedures and Methods for Environmental Assessment of Plans and Programs.”

For the above mentioned, it was decided to follow SEA Directive procedure and methodology, which are recognised and accepted both at national and international level. The Consortium believes that references to the SEA directive are appropriate, as they refer to the used methodology.

2. Regarding the content of the SER report, we have the following comments and remarks, which we feel must be addressed in the final report:

• In the text on p. 77 (of the English version of the report) the Consortium recommends measures “adequate to properly assess the existing risks”, which require amendment of the currently enacted legislation (e.g. in order to review EIA procedures at the central level) or represent repetition of current legislative requirements (definition of stakeholders, cumulative impact assessment) and existing methodological guidance documents (e.g. the preliminary 1‐year monitoring of the fauna);


Recommendations provided by the Consortium are based on the best scientific data, the current legislation and the expert opinion of the members of the Consortium. However, it is up to the Authorities to assess the suitability of the recommendations and to decide to what extend to implement them.

The recommendations which already exist in the current Bulgarian legislation have been included in the SER report to emphasize their importance and because there appear to be a significant number of cases where the regulations do not seem to be properly implemented. The proper assessment of the cumulative effects is a good example. While assessment of cumulative effects is already part of the EIA legislation, it has not been implemented for many wind power projects, which is evident from Section 7.8, which shows around 75% of all permitted wind power turbines.

The aim of this project is to provide a scientific base for discussion and support Authorities on future planning and decision making on wind power developments.

Further, the recommendations which require amendments of the currently enacted legislation can be easily incorporated in the next edits of the EIA regulation and the EPA. For example, in order to require that all installations above 100kW require an EIA, wind power installations above 100kW should be included in Annex 1 of the EPA, etc.

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• With the text on p. 79 (of the English version) a requirement is delegated to the MoEW to create workgroups for periodic review and analysis of the data regarding area sensitivity. We remind you that the SER is done for the purposes of the MEET, and should not delegate responsibilities to the MoEW;


The aim of this report is not to delegate responsibilities. Suggestions are provided in order to support and facilitate decision making.

Even if the MEET is the formal beneficiary of the SER project, the SER addresses mainly issues and decisions that are MoEW’s responsibility and/or within MoEW’s competence. In the recommendation on p.79, cited above, the Consortium suggests that the MoEW should supervise and manage this process, since the MoEW has the expertise, the liability and the most interest to ensure that wind power development is conducted in the country in the most sustainable manner. MoEW is a key decision maker in this development.

The Consortium suggests that the capacity of the RIEWs on the assessment of EIA should be improved under the supervision of the MoEW, in order to solve some of the main problem. This means that specific training to the RIEWs staff on the EIA of wind parks could be proposed. This will be included as an additional recommendation in the final SER Report.

• In connection to the text on p. 88 (of the English version), it must be noted that Bulgaria has transposed in the national legislation Directive 92/43/EEC on the conservation of natural habitats and of wild flora and fauna and Directive 79/409/EEC on the conservation of wild birds. Precision requires that the table should list the national designation of sites of community importance – protected zones for the conservation of natural habitats and wild flora and fauna, and respectively, special protected areas for the conservation of wild birds. This refers also to the designations used in the report – pSCI/SCI and SPA;


The Consortium will reflect this wording correction in the Bulgarian version of the report.

• The risk assessment regarding the subject and goals of protection of the protected areas presented in the report, is done without an assessment of the wind potential, i.e. the places suitable for such project. Currently planned and/or approved investment proposals of this kind have not been taken into account – a significant criterion, which, in our view, significantly increases the risk or makes impossible the fulfillment of the goals, especially in the designated “red” areas.


Data on wind potential were unfortunately not available to the Consortium, as has been mentioned in the report. Even so, this project assesses the likely effects that wind power development can have on the identified environmental and social topics, independently if there is wind potential or already installed turbines. The aim is to alert developers, investors, authorities and NGO´s of areas where impacts are likely to be greater or even unacceptable and therefore, development should be carefully addressed.

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• We would like to bring your attention to the fact that the abovementioned report on the review, despite being elaborated using the SEA methodology, is not associated with and does not refer to a project/plan/programme, for which the procedure, in accordance with Ch. 6 of the Bulgarian Environmental Protection Act, and Art. 31 of the Bulgarian Biodiversity Protection Act are applicable. In light of this, the present letter with comments and remarks on the SER report cannot be considered, and does not have the legal standing of a statement on the coordination / approval / enactment / acceptance of the presented report.


Since the beginning of this project, the Consortium has tried to get the MoEW involvement and support by asking several times comments and suggestions on how to approach certain issues. However, the involvement of the MoEW has been limited, particularly during the initial stages of the project.

Since the SER Report is not a formal SEA, the approval/enactment or acceptance of this SER Report by the MoEW is not necessary. Nevertheless, it is Consortium belief that the MoEW could use this project results and conclusions to lead the way for the planning of a more sustainable wind power development in Bulgaria.

Sincerely, Head of “EIA and SEA” division: Head of division «Natura 2000»: (J. Metodieva) (N. Nedyalkov) Prepared: Head expert. From “Natura 2000” division: ………………………….

(Rositsa Dimova) Senior expert at the “EIA and SEA” division: ......................................... (Raina Georgieva)


FINAL

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Appendix H6: Clarification Notes on the statement received by the Association of the Producers of Ecological Energy on the SER Environmental Report

Clarification notes to the statement received by the:

Bulgarian Association of Producers of Ecological Energy (APEE)

on the SER Report of the

Development of Wind Power in Bulgaria

Prepared by: ENVIRON Iberia, pm&E, POVVIK AD

Date: June 2010


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Clarification Notes on the statement position received by the Bulgarian Association of Producers of Ecological Energy (APEE)


Introduction The Consortium thanks APEE for the statement provided on the SER Report. The Consortium understands that APEE is an important stakeholder for this project and therefore its participation in the public consultation process is much appreciated.


Clarification Notes

Position/Standpoint

Regarding the SER Environmental Report of the Development of Wind Power in Bulgaria,

Conducted by ENVIRON Iberia and POVVIK

The presented report on the development of wind power in Bulgaria is helpful in terms of

raising the issue that wind energy development in Bulgaria must be regulated in order to lead

toward sustainable growth.

The report aims to support the institutions by highlighting problems and proposing solutions.

By doing this, it seeks to draft an appropriate strategic development and offer rules for

regulating the wind power industry.

Unfortunately, in terms of methods and content, this report is biased and looks at the problem

from one perspective only. It does not contribute to solving the problems between wind

power producers and the environmental organizations. As a consequence, we believe the

methods and guidelines mentioned in the report will be ineffective and will result in

unnecessary restrictions, thus prolonging the development process and further confusing the

investors.

The report emphasizes exclusively on part Biodiversity. There is no disclosed data or

arguments representative of the regulated side – the wind power industry. The wind power

strategic development being proposed is hardly well‐argument since it only describes the

negative aspects of wind energy and aims to constrain it.


It is important to note that it has never been questioned by the Consortium that wind energy is useful for Bulgaria. The report clearly states that wind energy will make Bulgaria less dependent on foreign energy sources and will help Bulgaria to increase the share of RES in its energy mix, following requirements of the EU. These are undeniable facts and were mentioned in the report (see for example Sections 2.4 and 2.5).

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As described in the Scoping Report, meetings were held with several wind energy firms and associations in order to receive input regarding the next steps of the project, as well as on the characteristics of the Bulgarian wind sector.

Although data was asked from several wind associations, experts and firms, they have not provided any input similar to the one provided by the experts and associations referred in the acknowledgments paragraph of this report. This fact does not mean that the wind sector was not consulted.

Further, the main focus of the SER Environmental Report was the environmental aspects of wind power development in Bulgaria. Even though the wind energy companies and associations have provided some input on the technical, legal and financial aspects of wind power development, this information is more relevant to the technical guides, which will be issued in June 2010, as part of this project, and not as much to the SER Environmental Report.

Due to the fact that Bulgaria is a country with a valuable natural heritage, and given its great richness in biodiversity and the occurrence of many species that are at risk of extinction, this SER report should absolutely take biodiversity in great account. Nevertheless, all other aspects of wind power development have also been addressed.

And finally, it has not been the goal of the SER report to solve “the problems between wind power producers and the environmental organizations”, even though the meetings and workshops that have been organized did in fact offer opportunities for different stakeholders to come together and discuss issues of common concern. The report reflects the degree in which the various organizations have chosen to use these opportunities.

Even so, it has been the goal of the project to provide a framework in which the development of wind power in Bulgaria to be carried out in a more sustainable manner in the future and the Consortium belief that valuable material has been created for future use by the Bulgarian authorities and relevant stakeholders.

In terms of quality, we consider the report as indicative. Furthermore, the data used for

identifying potential environmental impacts is not entirely reliable. A better evaluating system

with appropriate reference indicators could have been implemented.

Listed below, please find the major weaknesses we have considered:

• Due to the limited scope of this project, the authors have been unable to conduct a more detailed evaluation of their source data and verify its quality to a better extent. The information used in the analysis comprises of attribute geospatial data and associated meta data provided by the relevant sources which is insufficient. It is not clear what methods and equipment have been used for monitoring. It is also not clear what quality standards have been used to analyze and store the raw data. As a consequence, there is a possibility of disagreement between experts on how well are depicted the habitats and species’ sensitivity areas. This can result in ambiguous and unreliable final information.

• A significant portion of the biodiversity research has been conducted 5‐10 years ago. The radar bird surveys date from 1982‐1983. This brings up the question how relevant are these mappings given the strong anthropogenic effect starting from the 1980ies and the dynamics of the parameters.

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• It is unclear if field tests have been done recently for gathering updated information.

• The criteria for selecting biodiversity experts are unclear. Subsequently, there is no reliable guarantee their expert judgment is accurate and unbiased.

• The suggested methods and evaluation elements are based on expert judgment which is not always supported by reliable document sources.


To ensure data quality and transparency, the Consortium has collected metadata for all data sets included in the spatial analysis (this is information on the data source, purpose of creation of the data set, precision, data gaps, data availability and accessibility, etc.). Example of such metadata sheet is presented in Appendix C and the information from all metadata sheets is summarized in Appendix D of the SER report. As it has been stated in the SER report, while the compiled database is the best available information on the environmental constraints in Bulgaria at the moment, further crosschecking and data verification needs to be done and the database needs to be further expanded and continuously updated. Nevertheless, it is the Consortium’s belief that this database and its visual representations (the maps) have put the beginning of a better informed strategic planning in the field of RES in Bulgaria.

Regarding the comment on the recentness of the used data – APEE has selected to cite one of the less recent dataset. However, many of the GIS layers are based on information collected in the last 5 to 10 years and some is as recent as 2009. Details about each dataset are provided in Annex D of the SER report.

And finally, the members of the Consortium are well known and well recognized companies in the environmental consultancy field, not only at the local level, but also worldwide. Further, the members Consortium have proven their capacity to perform expert judgment or to identify other experts that can provide feedback and suggestions. During the tender process for this project, the Consortium team members were selected based on their expertise, education and experience.

During the whole project, whenever robust data was available it was preferred before expert judgment. When expert judgment was used, it was usually supported by reviewed publications or the expert’s experience on similar issues and topics.

Typically, expert judgment is a basic method used when quantifiable measurements are not available or there is no evaluation system implemented. This method is highly dependant on the person’s expertise. As a result, significant deviations can be expected when comparing different expert judgments on the same subject. Therefore, such a method should be employed in preliminary stages only.


The assessment is presented as evidence base discussion whenever it was possible to find literature, information, studies, analysis, etc. Additionally, expert judgment was also taken into account, wherever appropriate.

Data validation was performed by several international and Bulgarian experts, based on the best available information and when possible as evidence base discussion.

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To avoid subjectivity, the Consortium has conducted workshops and meetings with multiple experts on most of the environmental topic. For the elaboration of the sensitivity criteria for birds, more than 30 of the best Bulgarian ornithologists were consulted from the Bulgarian Academy of Science, Birdlife Bulgaria, other environmental NGOs and independent experts. Many of the consulted experts are currently participating or have previously participated in EIAs of wind power projects, thus they are well familiar with the topic.

• The methodology for evaluating the potential impact by wind energy is done on a point‐based system which categorizes impacts as important, unimportant, partially positive, partially negative and no impact. These categories are not quantifiable and can result in ambiguity. Furthermore, the significance of the impact is based on expert judgment which can also add to the uncertainty of the final evaluation.


The analysis is based on the methodology, described in Section 3.3.3 and details about the analysis themselves are explained in Appendix B. As it is explained in Section 3.3.3 “It should be noted that the potential exists that such simplified scoring system may mask individual effects which might be significant even when considered in isolation. Therefore this scoring system was used primarily to provide a summary of the assessment outputs and the obtained scores be considered in conjunction with the more detailed assessment outputs.”

Also, please see Consortium Clarification Note 3 regarding comment on expert judgment.

The analysis is too general and one‐sided evaluation of Bulgarian wind power development.

The analysis cannot fulfill one of its main purposes – to provide the appropriate information to

potential investors regarding the best wind turbine locations. It is not clear how this

information can be provided without the relevant geospatial data comprising of the site’s wind

potential, transmission power grid connectivity, as well as other technical aspects.

Technical, economic, financial and sociological sides of the problem have not been addressed

appropriately. Therefore, the results from SER Report should not be used as reference

guidelines for wind power development on national level.


The project aims to provide a spatial representation of the identified environmental and social constraints for which data is available. The Consortium has attempted to obtain spatial data about the wind potential and the transmission power grid connectivity. However, such data was not provided and/or is not available.

If data on wind potential is provided at a national level both, investors and authorities can define wind power development targets for the country, based on official and published information. Further, once a relatively reliable wind potential data is available for the whole country, investors should study case-by-case the areas subject to wind power implementation and ensure that wind power development can be technical, economic and environmentally viable. The possibility

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to have a common starting point is an advantageous approach for all the stakeholders and can prevent future problems and wasted investments.

The lack of a map with the wind potential and the transmission power grid connectivity does not lead to the conclusion that maps with the environmental and social constraints cannot /should not be made. The Consortium’s approach aims to contribute to a transparent wind power development in Bulgaria, which can serve as an example for other EU countries.

There is a public tender issued by the Ministry of Environment and Waters that aims to

accomplish the same purpose as ENVIRON but in larger scale including the following:

A Map and a GIS model depicting bird habitats and wind turbine conflicting areas including zoning with restrictions for wind turbine construction.

Wild birds protection manual adjusted for wind power developers in Bulgaria Development of an early warning system for regulating wind parks.

The MOEW tender will have the budget to cover Bulgaria entirely. Funds have been budgeted

for listing and processing historical data. According to the project’s agenda, the accumulated

data will be subject to controlled methodology by foreign and Bulgarian experts. An important

part of the project will be a wind resource map covering the entire Bulgarian territory.

Unlike the zones used in ENVIRON’s project, the resulting zoning from MOEW’s tender will

include rules for construction and exploitation.

The above mentioned details will ensure a better representation and accuracy of the

information and maps.

It would be unwise to have two official maps on the same subject. This will bring additional

confusion in the sector and will surely lead to investors backing away.

In this regard we believe the logical course of action would be ENVIRON’s maps and

information to remain for internal use of the institutions that participated in creating them.

Eventually, after the MOEW’s tender, these maps could be circulated amongst the institutions

and presented to the EU Commission.


It is the Consortium’s opinion that the information from the SER report should be used in the best interest of the country and that the results of this project should be further analyzed by the competent authorities and used by them in the best possible way. As it is stated in several sections of the SER Report:


Additionally, the interpretation of the data in terms of sensitivity will have to be reviewed periodically, and to perform this task the MoEW may consider to establish workgroups, in collaboration with the MEET, with regional and national experts. The database and its interpretation, as described in this report, are intended to be the starting point for a dynamic policy development program that should safeguard in the best way the interests of Bulgarian

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society and the country’s natural heritage. In its current state it does not represent a finished work product as detailed cross-checking of the data and sensitivity classifications was beyond the scope of this project.”

The Consortium agrees that a project financed by MoEW, with a time frame of a few years and an adequate budget will most likely be able to reach more definite conclusions and guidance on the zoning issue. However, the MoEW project does not have the same objectives as the current project - only one subsection of the cited MoEW’s project will address the issue of wind power development and the impacts on birds. The rest of the MoEW’s project objectives are very different. Furthermore, it is clear that having “two official maps” which address the same issues will serve no one any good. To the contrary, the Consortium is hoping that the relevant results of the MoEW’s project will be incorporated in the framework created by the SER project and will be used to expand and update the database, compiled as part of this project.

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